Privacy Policy

OUR COMMITMENT TO YOUR PRIVACY

Mediflow®  Inc. and its affiliate, IWI Ltd., ("Mediflow® ", "we", "our" or "us"), are committed to maintaining the accuracy, security and privacy of Personal Information which is provided to us by our customers and suppliers ("you" or "your").

This Privacy Policy sets out the principles and practices which we will use in protecting Personal Information that you provide to us.

WHAT IS "PERSONAL INFORMATION"?

"Personal Information" in this policy, means information about an identifiable individual as that term is defined in Canadian privacy legislation. As a general rule, Canadian privacy legislation does not consider "business-card" information such as the name, title, position, business address, telephone number, facsimile number, or e-mail address of an employee of an organization, to be Personal Information. Data that we collect with personal identifiers removed, so that it is impossible to determine the identity of the person to whom the information relates, is not considered Personal Information.

OUR TEN (10) PRIVACY PRINCIPLES

As part of our commitment to maintaining the accuracy, confidentiality and security of your Personal Information, we have adopted the following 10 Privacy Principles as part of our business practices:

Accountability: We are responsible for maintaining and protecting Personal Information which you provide to us. We have designated an individual to oversee our compliance with these principles.

Identifying Purposes: We will identify the purposes for which Personal Information is collected, either before or at the time of collection.

Consent: We will only collect, use and disclose your Personal Information with your knowledge and consent, except where otherwise required or permitted by law.

Limiting Collection: We will limit the collection of your Personal Information to only those details that are reasonably necessary for the purposes identified. Limiting Use, Disclosure and Retention: Your Personal Information will only be used or disclosed for the purpose for which it was collected, unless you have otherwise consented, or unless we are otherwise required or permitted by law. We will retain your Personal Information only for as long as reasonably required to fulfill the purposes for which it was collected.

Accuracy: We will keep Personal Information we collect from you as accurate, complete and up-to-date as reasonably required to fulfill the purposes for which it was collected.

Safeguards: We will protect your Personal Information with security safeguards that are reasonable and appropriate to the sensitivity of the information. Openness: Information about our policies and practices relating to the management of Personal Information will be made available to you on request from you in writing.

Access: At your written request, we will inform you of the existence, use and disclosure of your Personal Information and give you access to your Personal Information. You have the right to challenge the accuracy and completeness of your Personal Information, and to amend it as may reasonably be required.

Challenging Compliance: You may contact us with any questions or complaints with respect to this Policy by writing to our Personal Privacy Representative at the address give below.

YOUR CONSENT

By submitting Personal Information to us, (i) you agree that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy and as permitted or required by law, and (ii) you represent, in the case of Personal Information of any other individual that is provided by you to us, that you have the authorization and consent of that individual to permit us to collect, use and disclose that individual's Personal Information in accordance with this Privacy Policy and as permitted or required by law.

Consent requirements vary depending upon circumstances and upon the type of Personal Information that is collected, used or disclosed. In determining whether consent is required and, if so, what type of consent is required, we will take into account the purposes for which we intend to use the information and the sensitivity of the Personal Information at issue. Consent may be express, implied, or deemed by law. In most cases, consent is not required and consent will be implied where it is reasonable to do so. From time to time, we may advise you of other purposes for which we will collect, use or disclose Personal Information, in which case we will, if necessary, obtain your consent for the collection, use or disclosure of that Personal Information.

WITHDRAWING YOUR CONSENT

Subject to legal and/or contractual requirements which may apply and provided that you give us reasonable notice in writing, you have the right at any time to withdraw your consent to our collection, use or disclosure of your Personal Information.

You should know that where you withdraw your consent, we may not be able to offer you credit or provide you with products and/or services.

TYPES OF PERSONAL INFORMATION THAT WE COLLECT

We may collect Personal Information from you or about you in person, over the telephone, in written documents, on the Internet or through third parties such as credit collection and reporting agencies.

Examples of the types of Personal Information that we may collect about you could include your name, home address, mailing address, shipping address, email address, telephone number, date of birth, credit card information, and information required for credit approval and/or authorization.

HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Information to:

    Identify you;

    Confirm and fulfill orders placed by you;

    Perform credit checks;

    Administer our relationship with you including invoicing, collecting and processing payments;

    Communicate with you, including dealing with you on customer service matters;

    Develop and manage our business information systems and operations; and

    Comply with legal requirements.

It is always your choice whether or not you provide us with your Personal Information.

However, a decision to withhold Personal Information may prevent us from fulfilling your order, approving credit card purchases made by you or authorizing increases to your credit limit.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We only disclose your Personal Information to fulfill the purposes that it was collected for. Examples may include:

    Service providers, including: organizations or individuals who perform functions on our behalf, such as product delivery, freight forwarding, customs brokerage, website hosting, data processing and organizations or individuals retained by us to evaluate your creditworthiness or to collect outstanding debts

    Financial institutions for the purpose of processing payments for products or services

    Third parties, where you consent to the disclosure of your Personal Information or where the disclosure is required or permitted by law

IMPORTANT:We do not sell or rent your Personal Information for commercial gain to any third party.

SECURITY OF YOUR PERSONAL INFORMATION

Your Personal Information is stored at secured locations either at our offices or at the offices of our service providers.

To protect the confidentiality of your Personal Information, we employ administrative and technological safeguards appropriate to the sensitivity of your Personal Information. For instance, we operate computer systems which are protected by industry standard firewall and password protection systems. In addition, where Personal Information is provided to a third party for processing, we make sure, through our contracts with them, that your Personal Information is kept secure.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

Upon your written request, subject to certain exceptions and conditions, we will inform you of the existence, use, and disclosure of your Personal Information and will give you access to your Personal Information. At the time of your request, we may request you to provide specific information in order to permit us to verify your identity. In the event that any of your Personal Information is found to be incomplete or inaccurate, we will take reasonable steps to correct your Personal Information record.

Access requests and requests for correction of your Personal Information must be made in writing and must be sent to our Personal Privacy Representative at the contact address below.

Please note that there may be instances where we will not be able to provide you with Personal Information that you request. Examples of this could include Personal Information which

    contains references to other persons

    has already been destroyed due to legal requirements or because we no longer needed it for our purposes

    is subject to solicitor-client or litigation privilege

    cannot be disclosed for legal reasons

PRIVACY AND OUR WEBSITE

Our website may use cookies to collect information such as the type of browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique alphanumeric identification number that identifies the visitor's browser, but does not capture any personally-identifiable information.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post the revised policy on our website and we will make the revised policy available to you upon a written request to our Chief Privacy Officer. This Privacy Policy is effective as and from the effective date shown below and will remain in effect until modified or supplemented.

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