Last modified: October 2, 2015
Effective date: April 7, 2014
If you have questions or concerns regarding our policy or practices, please contact our privacy officer by email at firstname.lastname@example.org or at the following address:
OWL Practice Inc.
889 Broadview Ave.
Toronto, Ontario, Canada
If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you can contact the Privacy Commissioner of Canada at:
112 Kent Street,
Ottawa Ontario, K1A 1H3
Registration is required if you want to use the OWL Software Product. As part of this registration, we will require that you submit certain information that is relevant to providing the OWL Software Product. We collect the following information from our subscribers: registration information (first and last name, address, phone number, date of birth, gender, username, password, email address, clinic name and health care provider details) and credit card information (the “Personal Information”). Any information provided to the OWL Software Product relating to your clients' personal information (“Clients' Information” together with “Personal Information”, the “Information”) shall be restricted and not disseminated to any other party, except with individuals or entities required to provide the OWL Software Product.
You may send electronic information or physical documentation to us in the following forms: messages or transaction information relating to your interactions with your clients, receipts, personal data in text and picture form; and other subscriber-generated content provided to us in the normal course of your use of the OWL Software Product and the OWL Social Properties, including but not limited to posts, profiles, comments, suggestions, forwarded messages, feedback information, usage information, transaction information and Traffic Data (as defined below).
We may collect your Personal Information when you communicate it to us by use of one of our web forms or other interactions with the OWL Software Product, by email, or by any other means of communication (the “Aggregated Data”). OWL shall be entitled to anonymize the Aggregated Data, in its sole discretion, and utilize the Aggregated Data for benchmarking purposes.
The OWL Software Product and the OWL Social Properties offer publicly-accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We take no responsibility for any information which you or your employees, agents, contractors and representatives post or publish on the OWL Software Product and you agree to indemnify and hold us harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from any such post or publication. We may post your testimonials along with your name on the OWL Software Product from time to time if such information is provided to us.
“Traffic Data” is collected by the OWL Software Product and our third-party traffic analysis provider through the use of software that is included on the OWL Software Product as well as cookies that are stored temporarily on your computer. Together, these technologies help us manage our content by identifying which content is effective.
Cookies are small data files that are stored on a subscriber's computer for record-keeping purposes. Cookies track where you travel on the OWL Software Product and what you look at. A session ID cookie expires when you close your browser. When you log into the OWL Software Product, your browser may ask if you want it to remember you as a registered subscriber of the OWL Software Product. If you accept, the session ID becomes a persistent cookie, which remains on your hard drive for an extended period of time. Although cookies are used by most major websites and are accepted by default by most web browsers, it may be possible to disable cookies via your browser settings.
We use session cookies and usage data to make it possible to navigate the secure environment inside the OWL Software Product and to keep, and sometimes track, information about you for the purpose of creating a personalized web experience and improving the OWL Software Product or measuring and conveying to others the performance levels of the OWL Software Product. We may link the information we store in cookies to any personally identifiable information you submit while on the OWL Software Product for the purpose of creating a personalized experience within the OWL Software Product, to assist OWL in understanding its users and subscribers and designing improvements to the OWL Software Product and for the purpose of collecting OWL usage and performance metrics.
When you access the OWL Software Product using a web browser or other application, we may gather and store certain types of information including traffic data from your browser, your IP address, location, cookie information, and the pages you visit on the OWL Software Product. Traffic data is helpful in identifying and fixing problems with the OWL Software Product.
The Company will not use or disclose Information for purposes other than the identified purposes of the OWL Software Product. We may use your Personal Information listed above to:
• provide customer service and support, resolve disputes, and troubleshoot problems;
• fulfill your requests for certain features of the OWL Software Product;
• customize, measure and improve the OWL Software Product;
• inform you of targeted marketing, service updates, and promotional offers unless you opt out;
• assist us to measure our performance and to share performance information with others;
• comply with legal or regulatory requirements (as described below); and
• fulfill other purposes, subject to your explicit consent.
In the event that the Company, or all or a portion of our business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, your Personal Information shall be one of the transferred assets.
Notwithstanding the foregoing, the Company reserves the right (and you authorize the Company) to share or disclose your Personal Information when the Company determines, at its sole discretion, that the disclosure of such information is necessary or appropriate:
• To prevent prohibited or illegal activities; or
• When required by any applicable law, rule, regulation, subpoena, or other legal process.
In addition, as described above, OWL is entitled to anonymize the Aggregated Data, in its sole discretion, and utilize the Aggregated Data for benchmarking purposes.
The Company relies on you to ensure that the Personal Information you enter into our system is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You may make changes or corrections to your Personal Information at any time. If you would like to review or update your Personal Information, please contact our Privacy Officer at the contact details listed above.
We also make every effort to ensure the accuracy of the information in our reports, displays, articles and support queries. However, you must verify all information created from your use of the OWL Software Product and we recommend that you consult a professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk. You are responsible for ensuring that that the information you have entered into our system is accurate, reliable and complete.
In order to keep the Information secure, we restrict unauthorized access through protective policies, procedures, and technical measures, including:
• encryption of your personal information using secure socket layer technology (SSL). To learn more about SSL, follow this link:
• providing reasonable physical and electronic safeguards with regard to the storage of the Information;
• limiting access to the Information to those employees or contractors who we reasonably believe need to come into contact with that information to provide products or services to you or in order to do their jobs; and
• governing employees and other contractors by strict standards and policies to ensure that the Information is secure and treated with the utmost care and respect.
In addition, OWL maintains the following physical safeguards:
• the office reception area is physically separate from the records processing area;
• access to both areas is key-controlled;
• access to the Information is restricted to required personnel only and access is monitored and recorded; and
• OWL pre-screens its employees, and provides training and orientation on their obligations to maintain the confidentiality and security of their client's records.
Please note that no data transmission over the Internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect the Information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.
If you have a security related concern, please contact us at the contact details provided above. We will work closely with you to ensure a quick and personal response to your concerns.
In the unlikely event that we believe that the security of the Information in our possession or control may have been compromised, we shall seek to notify you of that development. If a notification is appropriate, we may notify you by the email address registered to your account.
We will never send email messages to customers requesting confidential information such as passwords, credit card numbers, or social security or social insurance numbers. Please do not act on any such emails as you may compromise the Information by replying or by following links to a fraudulent website.