This Privacy Policy describes how we collect, use, share and secure the personal information you provide. It also describes your choices regarding use, access and correction of your personal information. 

Your Consent 

By using or registering for a user account on our Platform or otherwise providing us your personal information you agree with the terms of this Privacy Policy as it may be modified from time to time and consent to the collection, use and disclosure of your personal information in accordance with the terms of this Privacy Policy. 

Meaning of Personal Information 

For the purposes of this Privacy Policy, "personal information" means information about an identifiable individual. 

The Personal Information We Collect & How We Use It 

Except as otherwise provided in this Privacy Policy, the personal information we collect from you is comprised entirely of the information you provide to us. Specifically, we may collect personal information from you (i) when you visit one of our clinics or retail stores or (ii) through our Platform, for example, when purchasing a product, subscribing to our newsletter or making an appointment at one of our clinics. 

Clinics  

When you make an appointment with, or otherwise visit, one of our clinics or stores for an eye exam, we may collect the following information from you: your name, address, email address, date of birth, health card number, insurance information and medical history, including any medication you are currently taking.  

In addition, as part of the services our optometrists and clinic and staff provide to you, we may collect or generate personal information about you such as medical images and prescription information. In addition, our optometrists may access your provincial electronic health records subject to, and in accordance with, applicable provincial law.  

We use this information to: 

• book and confirm your appointment,  

• conduct your eye exam,  

• communicate with you regarding your eye exam, including sending appointment reminders and notifying you when you are due for an eye exam, 

• subject to our obligations under applicable anti-spam laws, send you our newsletter or other marketing materials, although rest assured that we do not use any medical information in determining what materials we send to you, and 

• as otherwise required or permitted by applicable law. 

Platform and Purchases 

When you register an account on our Platform, or make a purchase from us, whether in-person or at one of our clinics or retail stores, we may collect the following personal information from you: your name, address, phone number, email address and prescription information. We may use this personal information for the following purposes: 

• providing you with access to and use of our Platform, 

• completing and processing any purchases you have made, 

• communicating with you with respect to your use of our Platform or your purchase,  

• subject to our obligations under applicable anti-spam laws, sending you our newsletter or other marketing materials, although rest assured that we do not use any medical information in determining what materials we send to you, and 

• as otherwise required or permitted by applicable law. 

Please note that when you provide payment information through our Platform or at one of our clinics or retail stores, we do not collect the payment information directly. We have engaged a PCI-DSS compliant third-party payment processor to process payments on our behalf.  Your payment information is sent directly to our third-party payment processor who will use such information for the purpose of processing your payment.  

In addition to the foregoing, we may use personal information we have collected from you to generate aggregated or anonymized data (“Aggregated Data”). Aggregated Data cannot and does not identify you and does not constitute personal information. We may use and disclose Aggregated Data for several purposes including improving our Platforms, products and services. We may also share Aggregated Data with universities and other research institutions that will use it to further scientific research and development, as well as insurance benefits providers. 

How We Disclose Your Personal Information 

We will not disclose any personal information we collect from you to any third parties except as follows: 

• Our Affiliates. We may disclose your personal information to any of our affiliates within the FYihealth group. Only employees and service providers (including optometrists) of these affiliates which require such personal information to perform their duties will have access to it. 

• Insurers. We may disclose your personal information to your insurer to facilitate direct billing or reimbursement for products and/or services we have provided you, or where you have expressly consented to such disclosure. 

• Service Providers. We may disclose your personal information to our service providers who perform certain services necessary to run our business (for example, data hosting and payment processors) to the extent that they require such personal information to perform their duties. 

• When Reasonably Required. We may disclose your personal information when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law. 

• Corporate Circumstances. We may disclose your personal information in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business. 

Cookies and Similar Technologies 

We use cookies, third-party analytics and other tracking mechanisms to collect personal and non-personal information to track your use of our Platform. Such tracking mechanisms may automatically collect information such as: your IP address, domain name, browser type and operating system; web pages you view; links you click; how you move through our Platform and the length of time you visit our Platform and use the services offered thereon. 

Cookies are small text files that are saved by your browser when you access our Platform. We (and our third-party analytics providers, such as Google Analytics) may use both session cookies and persistent cookies to identify that you've logged on to our Platform and to tell us how and when you interact with our Platform. We may also use cookies to monitor aggregate usage and web traffic routing through our Platform and to customize and improve the services offered on our Platform. Unlike persistent cookies, session cookies are deleted when you log off from a Platform and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. On the Platform, you may also choose whether to accept the use of cookies and similar technologies by changing the settings located in Cookie Preferences, accessible via a link at the footer of the Platform. Please note, however, that if you don't accept cookies, you may not be able to access all portions of, or features offered on, our Platform. Certain cookies cannot be disabled as they are essential to the operation of our Platform and enable basic functions, such as page navigation and controlled access to secure parts of our Platform. 

One of the third-party services that we use to track your activity on our Platform is Google Analytics. Information that we collect via the data collection technologies described in this section may be linked to other information about you such as location and may be personal information. We use the technologies described in this section, alone or in combination, to understand user behavior, target and measure the effectiveness of advertisements, help diagnose problems, recognize repeat visitors, and facilitate your access to and use of the services offered on our Platform. You can find more information on how Google uses data at https://policies.google.com/technologies/ads. You can opt out of receiving interest-based Google ads, or customize the ads Google shows you at https://adssettings.google.com/u/0/authenticated. If you do not want Google Analytics to collect and use information about your use of our Platform, then you can install an opt-out in your web browser by visiting https://tools.google.com/dlpage/gaoptout. 

Protecting Your Personal Information 

At FYihealth group we take the protection of your personal information seriously. We make every reasonable effort to prevent unauthorized use, disclosure, loss or theft of your personal information. Employees who have access to your personal information are made aware of the importance of keeping it confidential.  

Where we use service providers who might have access to your personal information, we select them carefully and require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent such information from being used for any other purpose. 

Please be aware that no data security measures can guarantee complete security. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private.  

Transfers outside  Canada 

Some of our service providers are located outside of Canada, including in the United States, the European Union, the United Kingdon, India and Brazil.  As a result, your personal information will be used, stored and/or accessed in countries outside of Canada, including in the aforementioned jurisdictions. However, all such information will be protected in accordance with this Privacy Policy. Please note that when your personal information is located outside of Canada it will be subject to the laws of the country in which it is situated.   

Retaining Your Personal Information 

We will only retain your personal information as long as necessary for the fulfillment of the purposes for which it was collected or as required by law. Your personal information is securely stored until such time as it is no longer required, after which it is destroyed, rendering it unable to identify you. 

Your Choices and Rights 

• Access And Modify: You may be able to access or modify certain information in your user account on our Platform by logging in to the "My Account" or similar area of the Platform. Where the Platform does not have the "My Account" feature, or does not include the applicable information, you may access or amend the personal information we hold about you by contacting us using the contact information in the “How to Contact Us” section below or by visiting your applicable clinic or store.  

Please note that your right to access the personal information that we hold about you is not absolute.  There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you such as when such information also includes the personal information of a third party.  In addition, personal information may have been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

• Withdrawal Of Consent. You also may also withdraw your consent to certain of our uses and disclosures of your personal information. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.  

• Right To Lodge a Complaint. Although we ask that you first contact our Privacy Officer at the contact details below if you believe that any of your rights regarding our collection, use, and disclosure of your personal information may have been violated, you have, at all times, the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy thought the courts. 

We will not retaliate against an individual who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their personal information. 

When requesting access to or seeking to enforce any of your rights regarding your personal information, we may request specific information from you to enable us to confirm your identity. 

Updates to this Privacy Policy 

This Privacy Policy or our other privacy related documents will be updated from time to time. You are responsible for reviewing this Privacy Policy periodically and informing yourself of any changes to this Privacy Policy. This Privacy Policy may be obtained by contacting our Privacy Officer (please see the “How to Contact Us” section below) 

How to Contact Us 

If you have any questions related to our practices with respect to the collection, use or disclosure of personal information, including our policies and practices with respect to our use of service providers outside Canada, or if you wish to complain to us in writing about how we have handled your personal information, please feel free to contact our Privacy Officer us at: 

FYihealth group Legal Department 
300 2424 4 Street S.W. 
Calgary, Alberta T2S 2T4 
privacyofficer@fyidoctors.com