Last Revised: 2019-12-12
ON MEN takes your data privacy very seriously, through comprehensive security infrastructure and stringent data policies. We comply with the laws and regulations under applicable privacy laws in Canada, namely the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Health Information Protection Act (Ontario) and the regulations thereunder.
The following topics will be covered in this Privacy Statement:
- What is Personal Information?
- How do we collect your Personal Information?
- Where do we store your Personal Information?
- How do we use your Personal Information?
- To whom do we provide your Personal Information?
- When and how do we obtain your consent?
- How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
- How long will we utilize, disclose or retain your Personal Information?
- How can you review your Personal Information that we have collected, utilized or disclosed?
- How do you know that the Personal Information we have on you is accurate?
- What if the Personal Information we have on you is inaccurate?
- How fast will we respond to your written requests?
- Are there any costs to you for requesting information about your Personal Information or our privacy practices?
- What safeguards have we implemented to protect your Personal Information?
- How do you contact us regarding access to your Personal Information or our privacy practices?
Scope; Third Party Sites.
WHAT IS PERSONAL INFORMATION?
“Personal Information” is any information that is identifiable with you, as an individual. We collect this information you provide to us, for example when you create or modify your account, register to use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This information may include but is not limited to your:
- Email address
- Telephone number
- Payment information (credit card or debit card number, expiration date and credit card security code – solely for payment purposes)
- Date of birth
- ON MEN user name and password
- Information that relates to your physical or mental health, health history of you or your family
Please note if you sign up to use our service you will also be asked to submit your Photo ID, as well as demographic and other information relevant to diagnosis and treatment, lifestyle and general medical history (e.g. conditions, allergies etc.). You will be able to send confidential messages and communicate with a doctor regarding your diagnosis and treatment. ON MEN will keep these messages private and confidential.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We will always collect your Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent, or as otherwise required or permitted by law.
No Information collected or used from Individuals Under the Age of 18
If you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from someone under 18, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 18, please Contact Us or call us at [email protected]
WHERE DO WE STORE YOUR PERSONAL INFORMATION?
We will keep the Personal Information that we collect either at the ON MEN offices or our service provider’s data centers that may be within or outside of Canada. In addition, we may send Personal Information outside of the country for the purpose of processing and storage by out of country service providers. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
HOW DO WE USE YOUR PERSONAL INFORMATION?
To Provide Products, Services, and Information.
The intent to collect Personal Information is identified at the time of collection from you, and we obtain your consent, prior to such use. Personal Information is generally collected and used for the following purposes:
- provide products and services that you order using the Site;
- register and service your online account;
- to facilitate communications with third-party service providers with whom we have a contractual relationship such as, Physicians, Nurse Practitioners, and Pharmacists;
- provide information that you request from us;
- contact you about your orders;
- process credit card and debit card transactions;
- ship products to you;
- send you promotional materials or advertisements about our products and services, as well as new features and offerings;
- administer surveys, sweepstakes, promotions and contests;
- to investigate legal claims;
- provide interest-based targeted advertising to you; and,
- any other purposes disclosed to you at the time we collect your information or pursuant to your consent, as may be permitted or required by applicable law.
TO WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Generally, we will only make disclosures of Personal Information to such Third Parties for which you provide your consent. Notwithstanding the foregoing:
We may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as, Physicians, Nurse Practitioners, and relevant medical staff in connection with your diagnosis and treatment.
Vendors and Services Providers.
We may provide information to third party vendors and service providers that help us operate and manage our Site, process orders, Pharmacists that fulfill and deliver products and services that you purchase from us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.
We may share your personal information with our corporate affiliates which are subject to this policy and applicable law.
If you use third-party services, such as Facebook, Google, or Twitter, through the Site, to login to the Site, or to share information about your experience on the Site with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.
Public Posts and Activities.
If you choose to engage in public activities on the Site, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.
In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of ON MEN when we have your consent to do so.
We will share personal information with third party companies, organizations or individuals outside of ON MEN if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
- Detect, prevent, or otherwise address fraud, security or technical issues.
- Protect against harm to the rights, property or safety of ON MEN, our users, customers or the public as required or permitted by law.
Transfer in the Event of Sale or Change of Control.
WHEN AND HOW DO WE OBTAIN YOUR CONSENT?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your personal information with us. You may withdraw your consent by providing us notice. You may expressly instruct that your personal health information not be used or disclosed for healthcare purposes without your consent.
HOW DO WE ENSURE THE PRIVACY OF YOUR PERSONAL INFORMATION WHEN DEALING WITH OUR AFFILIATES AND OTHER THIRD PARTIES?
We may provide your Personal Information to third party vendors and service providers that: help us operate and manage our Site, process orders, Pharmacists that fulfill and deliver products and services that you purchase from us, Physicians/Nurse Practitioners/relevant medical staff in connection with your diagnosis and treatment. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to help us provide the service.
HOW LONG WILL WE USE, DISCLOSE OR RETAIN YOUR PERSONAL INFORMATION?
We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
HOW CAN YOU REVIEW YOUR PERSONAL INFORMATION THAT WE HAVE COLLECTED, USED OR DISCLOSED?
If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by law, within 30 days of receiving your written request.
HOW DO YOU KNOW THAT THE PERSONAL INFORMATION WE HAVE ON YOU IS ACCURATE?
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible, however, we will not perform routine checks, unless necessary. You can access and update certain information we have relating to your online account by signing into your account and going to the Account section of our Site. If you have questions about the personal information we have about you or need to update your information, you can Contact Us or call us at [email protected]
WHAT IF THE PERSONAL INFORMATION WE HAVE ON YOU IS INACCURATE?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If your Personal Information in our records is found to be inaccurate or incomplete, we will amend the Personal Information as required. As needed, we will transmit the amended information to third parties having access to your Personal Information.
HOW FAST WILL WE RESPOND TO YOUR WRITTEN REQUESTS?
We will attempt to respond to each of your written requests not later than 30 days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit.
ARE THERE ANY COSTS TO YOU FOR REQUESTING INFORMATION ABOUT YOUR PERSONAL INFORMATION OR OUR PRIVACY PRACTICES?
We will not charge any costs for you to access your Personal Information in our records or to access our privacy practices without first providing you with an estimate of the approximate costs if any.
WHAT SAFEGUARDS HAVE WE IMPLEMENTED TO PROTECT YOUR PERSONAL INFORMATION?
We use industry-standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means. The only ON MEN employees, who are granted access to your Personal Information, are those with a business ‘need-to-know’ or whose duties reasonably require such information.
HOW DO YOU CONTACT US REGARDING ACCESS TO YOUR PERSONAL INFORMAITON OR OUR PRIVACY PRACTICES?
All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Statement or our privacy practices, should be forwarded to our Privacy Officer at the following email address: [email protected]