Last updated February 23, 2022
This privacy notice for Canadian Network for International Surgery (doing business as CNIS) (“CNIS,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:
- Download and use our application(s), such as our mobile application — Kampala Trauma Score, or any other application of ours that links to this privacy notice
- Engage with us in other related ways ― including any sales, marketing, or events
Questions or
concerns? Reading this privacy notice will help you understand your privacy rights
and choices. If you do not agree with our policies and practices, please do not
use our Services. If you still have any questions or concerns, please contact
us at [email protected].
SUMMARY OF KEY POINTS
This summary provides key points
from our privacy notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using our table of
contents below to find the section you are looking for. You can also click here to go directly to our table of
contents.
What personal information do we
process? When you
visit, use, or navigate our Services, we may process personal information
depending on how you interact with CNIS and the Services, the choices you make,
and the products and features you use. Click here to learn more.
Do we process any sensitive
personal information? We do
not process sensitive personal information.
Do you receive any information
from third parties? We do
not receive any information from third parties.
How do you process my
information? We
process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent.
We process your information only when we have a valid legal reason to do so.
Click here to learn more.
In what situations and with which
parties do we share personal information? We may share information in specific situations
and with specific third parties. Click here to learn more.
How do we keep your information
safe? We have
organizational and technical processes and procedures in place to protect your
personal information. However, no electronic transmission over the internet or
information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Click here to learn more.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you have certain
rights regarding your personal information. Click here to learn more.
How do I exercise my rights? The easiest way to exercise your
rights is by filling out our data subject request form available here, or by contacting us. We will
consider and act upon any request in accordance with applicable data protection
laws.
Want to learn more about what
CNIS does with any information we collect? Click here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4.
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7.
WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR
DO-NOT-TRACK FEATURES
9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO THIS NOTICE?
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION
DO WE COLLECT?
Personal information
you disclose to us
In Short: We collect
personal information that you provide to us.
We collect personal
information that you voluntarily provide to us when you express an interest in
obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.
Sensitive Information. We do not process sensitive
information.
All personal
information that you provide to us must be true, complete, and accurate, and
you must notify us of any changes to such personal information.
2. HOW DO WE PROCESS
YOUR INFORMATION?
In Short: We process your
information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your
personal information for a variety of reasons, depending on how you interact
with our Services, including:
- To save or protect an
individual’s vital interest. We may process your information when
necessary to save or protect an individual’s vital interest, such as to
prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON
TO PROCESS YOUR INFORMATION?
In Short: We only process your personal
information when we believe it is necessary and we have a valid legal reason
(i.e., legal basis) to do so under applicable law, like with your consent, to
comply with laws, to provide you with services to enter into or fulfill our
contractual obligations, to protect your rights, or to fulfill our legitimate
business interests.
If you are located in the EU or
UK, this section applies to you.
The General Data Protection
Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we
rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:
- Consent. We may process your
information if you have given us permission (i.e., consent) to use your
personal information for a specific purpose. You can withdraw your consent
at any time. Click here to learn more.
- Legal Obligations. We may process your
information where we believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
- Vital Interests. We may process your
information where we believe it is necessary to protect your vital
interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
If you are located in Canada,
this section applies to you.
We may process your information
if you have given us specific permission (i.e., express consent) to use your
personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can withdraw your
consent at any time. Click here to learn more.
In some exceptional cases, we may
be legally permitted under applicable law to process your information without
your consent, including, for example:
- If collection is clearly in
the interests of an individual and consent cannot be obtained in a timely
way
- For investigations and fraud
detection and prevention
- For business transactions
provided certain conditions are met
- If it is contained in a
witness statement and the collection is necessary to assess, process, or
settle an insurance claim
- For identifying injured,
ill, or deceased persons and communicating with next of kin
- If we have reasonable
grounds to believe an individual has been, is, or may be victim of
financial abuse
- If it is reasonable to
expect collection and use with consent would compromise the availability
or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a
contravention of the laws of Canada or a province
- If disclosure is required to
comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records
- If it was produced by an
individual in the course of their employment, business, or profession and
the collection is consistent with the purposes for which the information
was produced
- If the collection is solely
for journalistic, artistic, or literary purposes
- If the information is
publicly available and is specified by the regulations
4. WHEN AND WITH WHOM
DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share
information in specific situations described in this section and/or with the
following third parties.
We may need to share your
personal information in the following situations:
- Business Transfers. We may share or transfer
your information in connection with, or during negotiations of, any
merger, sale of company assets, financing, or acquisition of all or a
portion of our business to another company.
5. HOW LONG DO WE
KEEP YOUR INFORMATION?
In Short: We keep your
information for as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by law.
We will only keep
your personal information for as long as it is necessary for the purposes set
out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements). No
purpose in this notice will require us keeping your personal information for
longer than __________.
When we have no
ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for
example, because your personal information has been stored in backup archives),
then we will securely store your personal information and isolate it from any
further processing until deletion is possible.
6. HOW DO WE KEEP
YOUR INFORMATION SAFE?
In Short: We aim to protect
your personal information through a system of organizational and technical
security measures.
We have implemented
appropriate and reasonable technical and organizational security measures
designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able
to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Services is at your own
risk. You should only access the Services within a secure environment.
7. WHAT ARE YOUR
PRIVACY RIGHTS?
In Short: In some regions,
such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you
have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.
In some regions
(like the EEA, UK, and Canada), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure;
(iii) to restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also have
the right to object to the processing of your personal information. You can
make such a request by contacting us by using the contact details provided in
the section “HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?” below.
We will consider
and act upon any request in accordance with applicable data protection laws.
If you are located
in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection
supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located
in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your
consent: If we are relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can withdraw your
consent at any time by contacting us by using the contact details provided in
the section “HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?” below.
However, please note that this
will not affect the lawfulness of the processing before its withdrawal, nor
when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than
consent.
If you have questions or comments
about your privacy rights, you may email us at [email protected].
8. CONTROLS FOR
DO-NOT-TRACK FEATURES
Most web browsers
and some mobile operating systems and mobile applications include a
Do-Not-Track (“DNT”) feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy notice.
9. DO CALIFORNIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a
resident of California, you are granted specific rights regarding access to
your personal information.
California Civil
Code Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain from us,
once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing
purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your
request in writing to us using the contact information provided below.
If you are under 18
years of age, reside in California, and have a registered account with
Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact
us using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We
will make sure the data is not publicly displayed on the Services, but please
be aware that the data may not be completely or comprehensively removed from
all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code
of Regulations defines a “resident” as:
(1) every
individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every
individual who is domiciled in the State of California who is outside the State
of California for a temporary or transitory purpose
All other
individuals are defined as “non-residents.”
If this definition
of “resident” applies to you, we must adhere to certain rights and
obligations regarding your personal information.
What categories of
personal information do we collect?
We have collected
the following categories of personal information in the past twelve (12)
months:
|
Category |
Examples |
Collected |
|
A. Identifiers |
Contact details,
such as real name, alias, postal address, telephone or mobile contact number,
unique personal identifier, online identifier, Internet Protocol address,
email address, and account name |
NO |
|
B. Personal
information categories listed in the California Customer Records statute |
Name, contact
information, education, employment, employment history, and financial information |
YES |
|
C. Protected
classification characteristics under California or federal law |
Gender and date
of birth |
NO |
|
D. Commercial
information |
Transaction
information, purchase history, financial details, and payment information |
NO |
|
E. Biometric
information |
Fingerprints and
voiceprints |
NO |
|
F. Internet or
other similar network activity |
Browsing history,
search history, online behavior, interest data, and interactions with our and
other websites, applications, systems, and advertisements |
NO |
|
G. Geolocation
data |
Device location |
NO |
|
H. Audio,
electronic, visual, thermal, olfactory, or similar information |
Images and audio,
video or call recordings created in connection with our business activities |
NO |
|
I. Professional
or employment-related information |
Business contact
details in order to provide you our services at a business level or job
title, work history, and professional qualifications if you apply for a job
with us |
NO |
|
J. Education
Information |
Student records
and directory information |
NO |
|
K. Inferences
drawn from other personal information |
Inferences drawn
from any of the collected personal information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics |
NO |
We may also collect
other personal information outside of these categories instances where you
interact with us in person, online, or by phone or mail in the context of:
- Receiving help
through our customer support channels;
- Participation
in customer surveys or contests; and
- Facilitation
in the delivery of our Services and to respond to your inquiries.
How do we use and
share your personal information?
More information about our data
collection and sharing practices can be found in this privacy notice.
You may contact us
by email at [email protected], or by referring to the contact details at the
bottom of this document.
If you are using an
authorized agent to exercise your right to opt out we may deny a request if the
authorized agent does not submit proof that they have been validly authorized
to act on your behalf.
Will your
information be shared with anyone else?
We may disclose
your personal information with our service providers pursuant to a written
contract between us and each service provider. Each service provider is a
for-profit entity that processes the information on our behalf.
We may use your
personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not
considered to be “selling” of your personal information.
Canadian Network
for International Surgery has not disclosed or sold any personal information to
third parties for a business or commercial purpose in the preceding twelve (12)
months. Canadian Network for International Surgery will not sell personal information
in the future belonging to website visitors, users, and other consumers.
Your rights with
respect to your personal data
Right to request
deletion of the data — Request to delete
You can ask for the
deletion of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the
exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be
informed — Request to know
Depending on the
circumstances, you have a right to know:
- whether we
collect and use your personal information;
- the categories
of personal information that we collect;
- the purposes
for which the collected personal information is used;
- whether we
sell your personal information to third parties;
- the categories
of personal information that we sold or disclosed for a business purpose;
- the categories
of third parties to whom the personal information was sold or disclosed
for a business purpose; and
- the business
or commercial purpose for collecting or selling personal information.
In accordance with
applicable law, we are not obligated to provide or delete consumer information
that is de-identified in response to a consumer request or to re-identify
individual data to verify a consumer request.
Right to
Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not
discriminate against you if you exercise your privacy rights.
Verification
process
Upon receiving your
request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. These verification
efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on
the type of request you submit, we may ask you to provide certain information
so that we can match the information you provide with the information we
already have on file, or we may contact you through a communication method
(e.g., phone or email) that you have previously provided to us. We may also use
other verification methods as the circumstances dictate.
We will only use
personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if
we cannot verify your identity from the information already maintained by us,
we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes. We will
delete such additionally provided information as soon as we finish verifying
you.
Other privacy
rights
·
You may object to the processing of your personal information.
·
You may request correction of your personal data if it is incorrect or
no longer relevant, or ask to restrict the processing of the information.
·
You can designate an authorized agent to make a request under the CCPA
on your behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
·
You may request to opt out from future selling of your personal
information to third parties. Upon receiving an opt-out request, we will act
upon the request as soon as feasibly possible, but no later than fifteen (15)
days from the date of the request submission.
To exercise these
rights, you can contact us by email at [email protected], or by referring to the contact
details at the bottom of this document. If you have a complaint about how we
handle your data, we would like to hear from you.
10. DO WE MAKE
UPDATES TO THIS NOTICE?
In Short: Yes, we will update
this notice as necessary to stay compliant with relevant laws.
We may update this
privacy notice from time to time. The updated version will be indicated by an
updated “Revised” date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice,
we may notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this privacy
notice frequently to be informed of how we are protecting your information.
11. HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
If you have
questions or comments about this notice, you may email us at
[email protected] or by post to:
Canadian Network
for International Surgery
1650 Duranleau St
Suite 212
Vancouver,
British Columbia V6H 3S4
Canada
12. HOW CAN YOU
REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the
applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or
delete it in some circumstances. To request to review, update, or delete your
personal information, please submit a request form by clicking here.
This privacy policy
was created using Termly’s Privacy Policy
Generator.