Effective date: August 20, 2020
Frontline Medical Supply Ltd. (“us“, “we“, or “our“) takes your privacy seriously. This page describes our policies and practices concerning the collection, use, and disclosure of Personal Information.
- What Personal Information Do We Collect?
The types of Personal Information that we may collect about you includes:
- Contact and residency information, such as your full name, home or business address, telephone number, personal email address;
- Payment and financial information, such as billing, banking information, credit card information, credit record information, credit application;
- If you are applying to be an affiliate or are an affiliate in our affiliate marketing program, information related to your participation in our affiliate marketing program, which may include tax and payment information and information about your social media accounts and online presence;
- Cookies and website Usage Data
We do not intend to collect data from anyone under the age of 18. If you believe that we have collected the Personal Information of anyone under the age of 18, please contact our Privacy Officer at firstname.lastname@example.org or at the address provided in the Contact Information section below.
Like most other websites, we may monitor traffic patterns, website usage, and related website information to optimize your visit to our website (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
In general, we collect, use, and disclose Personal Information about our customers and service providers in order to better understand product and service needs and to offer and deliver relevant information, products, and services to meet those needs. As well, we collect Personal Information to provide our customers with newsletters concerning our activities and developments in the industry.
We use the collected Personal Information for various purposes, such as:
- To supply you with the requested goods, products, or services, including the use of our online store;
- To facilitate transactions, returns, and account registration;
- To verify and authenticate account information;
- To verify compliance with our website terms and conditions;
- To allow you to participate in interactive features of our platforms when you choose to do so;
- To respond to inquiries and provide customer support;
- To notify you about changes to our products and services;
- To gather analysis or valuable information so that we can improve our products and services;
- To monitor the usage of our website;
- To detect, prevent and address technical and security issues;
- To verify your identity, protect against error and fraud, and conduct investigations;
- To serve you with relevant search results;
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those you have already purchased or enquired about unless you have opted not to receive such information;
- To administer and operate our affiliate marketing program;
- To calculate affiliate fees and make payments of affiliate fees under our affiliate marketing program;
- To communicate with you about our affiliate marketing program and other matters;
- For any other purposes that are disclosed to you and to which you consent; and
- For any purposes required or authorized by law.
Your phone calls or enquiries via online-chat may be recorded for quality assurance, training, and management purposes, and to keep a record of our commitments to you.
In addition to any information that you choose to submit to us, we or selected third parties may use a variety of technologies that store or access information already stored on your personal computer, laptop, tablet or mobile phone (each a device) whenever you visit or interact with our website.
A few of the methods that may be used to store or access information already stored on your device include the following (and in the future, other technology and methods may be developed):
- Cookies – a cookie is a file placed on a device when a user visits a website. Cookies can be temporary (e.g. session) or permanent (e.g. persistent).
- Session Cookies – We use Session Cookies to operate our website.
- Preference Cookies – We use Preference Cookies to remember your preferences and various settings.
- Analytics Cookies – We use Analytics Cookies to monitor the use of our website and the effectiveness of our marketing campaigns.
- Tracking Cookies – We use Tracking Cookies to monitor your activities on our website and on other websites so that we can deliver targeted advertising based on your habits and preferences.
- Security Cookies – We use Security Cookies for security purposes.
- Flash cookies—a Flash cookie (or locally shared object) is a data file placed on your device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. This can operate across all your browsers.
- HTML5—HTML5 cookies can be programmed through HTML5 local storage and do not require a plug-in.
- ETag or entity tag—an opaque identifier assigned by a web server to a specific version of a resource found at a URL that acts as a form of device identifier.
Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies may also be used, such as beacons, tags, and scripts, to collect and track information and to improve functionality and performance of our website, including tailoring our website to increase the relevancy of content displayed to you.
Visitors of our website can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.
Please be aware that if you disable or remove these technologies some parts of our website will not work. Deleting or blocking these technologies may also interfere with your ability to participate in our affiliate marketing program. When you revisit our website your ability to limit cookies is subject to your browser settings and limitations.
You may withdraw your consent to our collection, use, and disclosure of your Personal Information at any time, subject to legal and/or contractual restrictions and reasonable notice. Your withdrawal of consent to our collection, use and disclosure of your Personal Information may impact our ability to provide you with products and services and may impact your ability to use our website or to participate in our affiliate marketing program. To withdraw consent, please contact our Privacy Officer at email@example.com or by using the contact information provided below in our Contact Information section.
In some cases, your information, including Personal Information, may be transferred to — and maintained and processed on — computers located outside of Canada. Therefore, your Personal Information may be available to government authorities under lawful orders and laws applicable in those foreign jurisdictions. When we transfer your Personal Information to a third party to provide administrative, processing, or other services, we use appropriate measures to require that the party will only use your Personal Information to perform the services we specified.
If you are located outside Canada and choose to provide information to us, please note that your data, including Personal Information, may be transferred to Canada and processed there or in other countries. By ordering any of our products or services, or by sending us any Personal Information, you consent to such transfers.
Disclosure of Personal Information
Generally, we do not disclose your Personal Information to third parties without your consent. However, in order to process your orders and applications, and to provide you with services and opportunities, we may need to transfer your Personal Information to our employees, contractors, consultants and other parties who require such information to assist us with managing and administering our relationship with you, including:
- third parties that provide services to us or on our behalf;
- third parties that assist Frontline Medical Supply in the provision of services to you (such as couriers); and
- third parties whose services we use to conduct our business (such as payment processors, email services providers, and third-party CRM providers).
Additionally, in order to provide you with products or services, we may need to transfer your Personal Information to third party technology companies for the purposes of processing and storing your Personal Information. Our business necessitates using: (a) a cloud-based Customer Relations Management system (CRM); (b) cloud storage and hosting providers; (c) email services providers, including email marketing service providers; and (d) and payment processors including PayPal and Stripe. We consider these services, platforms, and applications to be integral to our delivery of products and services to you.
Under certain circumstances, Frontline Medical Supply may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We reserve the right to disclose Personal Information to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition. We may also disclose your Personal Information for any other purpose permitted by law or to which you consent.
We may disclose your Personal Information in the good faith belief that such action is necessary to:
- To protect and defend the rights or property of Frontline Medical Supply Ltd.;
- To prevent or investigate possible wrongdoing in connection with our products, services, or our affiliate marketing program;
- To protect the personal safety of our customers or the public; or
- To protect against legal liability.
To operate our website, provide our products and service, and to administer and operate our affiliate marketing program, we may need to provide third-party service providers with access to your Personal Information.
- Analytics Services
- Behavioral Remarketing/Retargeting Services
Amazon Web Services
We use Amazon cloud based web services for hosting and to secure and protect our website and its database.
WordPress and its Subcontractors
We also use various “plugin” software made available by third-party vendors who service WordPress users. Our use of plugins may result in Personal Information being shared with the third-party vendors of the plugins.
We use Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/.
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.
To opt-out, Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/.
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405.
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy page: https://www.facebook.com/privacy/explanation.
Many of our products and services require payment from you. Additionally, our affiliate marketing program may involve payments to our affiliates. When payment is required, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Frontline Medical Supply uses appropriate safeguards to ensure that your Personal Information is protected against loss, theft, misuse, unauthorized access, disclosure, or alteration. These include security of our physical premises, and various security safeguard software and firewalls to prevent unauthorized computer access.
While we endeavour to keep your Personal Information safe, our collection, use, and disclosure of your Personal Information is not without risks. For example, our security safeguards may be compromised by viruses, hacking attempts, or physical break-ins. Consequently, we cannot guarantee the security of your Personal Information. If your Personal Information was wrongfully accessed, there is a risk that you may suffer a harm, such as identity or credit card theft or financial loss.
Please be careful whenever sending Personal Information to us via email. Email is generally not a secure means of transferring information. We therefore cannot guarantee that this information will not be lost or used in a fraudulent manner and we encourage the use of email encryption to communicate with us.
You have a right to challenge the accuracy and completeness of your Personal Information and to have it amended, as appropriate. You also have a right to request access to your Personal Information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal Personal Information about another individual, your request for access may be limited or denied.
To request access or to amend your Personal Information, please write to our Privacy Officer at firstname.lastname@example.org or at the address provided in our Contact Information section below.
OUR WEBSITE AND PRODUCTS AND SERVICES ARE NOT INTENDED FOR INDIVIDUALS UNDER AGE 18. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS OUR WEBSITE, PRODUCTS, OR SERVICES AT ANY TIME OR IN ANY MANNER.
We do not knowingly collect or maintain Personal Information from people under 18 years old. If we learn that Personal Information of people under 18 years old has been collected by us, we will take appropriate steps to delete this information unless we are legally required to keep it.
If you are the parent or legal guardian of a minor under 18 years old who uses our website, then please contact us at the address below to have your child’s account terminated and Personal Information deleted.
Attn: Privacy Officer
Frontline Medical Supply Ltd.
270-288 W 8th Avenue
Vancouver, British Columbia
If any complaint or inquiry is not handled to your satisfaction, you may contact:
Privacy Commissioner of Canada
112 Kent Street
Toll free: 1.800.282.1376.
Commission d’accès à l’information du Québec
480 St. Laurent
Toll Free: 1.888.528.7741
This Section M applies only to persons in the European Economic Area (“EEA”).
Legal Basis for Processing
We process (i.e. use) the personal data you provide us in contact forms, application forms, and registration forms (e.g. contact information, such as your name, email address, phone number; and payment and tax information) because, by submitting the information requested on those forms, you have sent us that personal data and authorized our processing of it.
We and our third-party service providers (such as Google Analytics) process Usage Data to provide us with information about the usage of our website and our affiliate marketing program. Consequently, the lawful basis for processing that data is that it is in our legitimate interests.
We also process your personal data where legally required. For example, we may need to process your personal data if a court orders us to do so.
Your Rights under the General Data Protection Regulation (“GDPR”)
If you would like to know what personal data we hold about you, to request its removal, or to exercise any of your other rights under the GDPR, please contact us at email@example.com.
Under the GDPR, you have rights related to your personal data:
- The Right to Access and Rectification – You may request a copy of your personal data free of charge and request that corrections be made to it if it is inaccurate or incomplete.
- The Right to Erasure – You may require us to delete your personal data in certain circumstances.
- The Right to Object to Processing – You may object to the processing of your personal data by us.
- The Right to Restriction of Processing – You may require us to restrict or limit how we process your personal data in certain circumstances.
- The Right to Data Portability – You have the right to access and receive your personal data in a structured, commonly used, and machine readable format.
- The Right Not to be Subject to a Decision Based Solely on Automated Decision-Making, Including Profiling
- The Right to Withdraw your Consent to the Collection and Processing of Your Personal Data
- The Right to Complain to an EEA data protection authority about our handling of your personal data.
The rights set out above are in summary format and are subject to limitations and exceptions as set out in the GDPR.