PRIVACY POLICY

PURPOSE
Your data privacy and security are important to us. Our Privacy Statement will give you more clarity and control over how we collect and use your personal data when delivering our products and services.

GUIDING PRINCIPLES

A concise & simple Privacy Statement. This means comprehensive and clear explanations of what data we collect, how we use it and the rights that are available to you.

We will comply with Privacy Laws & Regulations such as PIPEDA (Personal Information Protection and Electronic Documents Act), HIPAA (Health Insurance Portability and Accountability Act), the PCI security standard, etc. where applicable.

We apply Information Security best practices and controls as applicable and continuously evolve our Security & Awareness Programs.

We are preparing for the EU’s General Data Protection Regulation (GDPR). This means new requirements as to how we process EU personal data.

SCOPE
Synergy Medical cares about your privacy and protecting your personal information.  For this reason, we collect and use personal data only on a need to know basis, as it is needed to deliver our products, software and websites (collectively, our “Services”). Your personal data includes information such as:

• Name
• Address
• Telephone number
• Date of birth
• Email address
• Personal Health Information (PHI)
• Other data collected that could directly or indirectly identify you.

Our Privacy Statement is intended to describe to you what data we collect, and how and why we use your personal data. It also describes the options we provide to access, update or otherwise take control of your personal data that we collect, process, handle or store.

This Statement will be updated as required to comply with evolving International and Regional Laws & Regulations.

WHAT INFORMATION DO WE COLLECT?

We collect information so that we can provide the best possible experience when you use our Services.  Personal data is collected directly from you when you:

• create an account or purchase any of our Services (ex: billing information, including name, address, credit card number, other business identification information);
• request assistance from our customer support team (ex: phone number);
• complete contact forms or request information from us (ex: email); or
• apply for a job;
• or perform any other activities that might require information about you.

However, we also collect additional information when delivering our Services to ensure necessary and optimal performance such as:

• Account related information is collected in association with your use of our Services, such as account number, purchases, products renewal or expiration, information requests, customer service requests and notes or details explaining what you asked for and how we responded.
• Data about Usage of Services is automatically collected when you use and interact with our Services, including metadata, log files, device IDs and location information. This information includes specific data about your interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location. 
• Supplemented Data may be received about you from other sources, including publicly available databases or third parties. If you provide us with personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

HOW DO WE USE INFORMATION?
We believe in both minimizing the data we collect and limiting its use and purpose to only that:

1. for which we have been given permission
2. as necessary to deliver the Services you purchase or interact with
3. as we might be required or permitted for legal compliance or other lawful purposes.

These uses include:

Delivering, updating and enhancing the Services we provide to you.  We collect various information relating to your purchase, use and/or interactions with our Services. We may use this information to:

• Improve and optimize the operation and performance of our Services
• Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
• Detect and prevent fraud and abuse of our Services and systems
• Collecting aggregate statistics about use of the Services
• Understand and analyse how you use our Services and what products and services are most relevant to you.

Often, much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.

 Sharing with trusted third parties. We may share your personal data with affiliated companies within our corporate family, with third parties with which we have partnered, and with trusted third-party service providers as necessary for them to perform services on our behalf, such as:

• Processing credit card payments
• Serving advertisements
• Performing analysis of our Services and customers demographics
• Communicating with you, such as by way email
• Customer relationship management.

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

Communicating with you. We may contact you directly or through a third-party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:

• Email
• Text (SMS) messages
• Telephone calls
• Automated phone calls or text messages.

 Transfer of personal data abroad.  If you utilize our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or contact us, we may provide you with support from one of our global locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy.

Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third-party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

CONTACT INFORMATION
If at any time you have questions about our practices or any of your rights described, you may reach our Compliance Director and our team that supports this function by contacting us at info@synmedrx.com.  This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.