Privacy policy.
Last Updated: April 4, 2024
By visiting or using The Circumcision Clinic website at www.TheCircumcisionClinic.ca, www.TorontoCircumcision.com, www.TorontoBris.org, applications, or other online resources provided by The Circumcision Clinic (collectively, the “Website”), each web user (each a “User”) acknowledges that they may be providing Personal Information and/or Personal Health Information to The Circumcision Clinic.
The Circumcision Clinic is committed to protecting the privacy and personal information of each User. This Privacy Policy details how The Circumcision Clinic collects, uses and discloses personal information obtained by The Circumcision Clinic when Users visit and use the Website and services provided therein, provide information by email and electronic means.
Application of this Privacy Policy
This Privacy Policy applies to all Personal Information and Personal Health Information collected by The Circumcision Clinic through the operation of the Website. The obligations set out in this Privacy Policy apply to all Users of the Website. This Privacy Policy does not apply to third-party online resources, to which the Website may link, where The Circumcision Clinic does not control the privacy practices of such resources.
This Privacy Policy does not apply to information communicated between any patient and healthcare professional that is offline or otherwise not through the Website.
This Privacy Policy does not apply to information regarding any one or more individual where the identity of the individuals are not known and cannot be inferred from the information (“Aggregated Data”). The Circumcision Clinic retains the right to use Aggregated Data in any way that it determines appropriate.
What is Personal Information and Personal Health Information?
Personal Information is defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) as information about an identifiable individual, including, but not limited to, a User’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, internet protocol addresses, and network and server particulars.
Personal Health Information is defined in and protected under the Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”) as identifying information about an individual which relates to that individual’s health, the provision of health care to that individual, payments made for the provision of health care services or eligibility for health care coverage of that individual.
The Circumcision Clinic is committed to comply with the obligations set out in PIPEDA and PHIPA and the principles set out in the Model Code for the Protection of Personal Information.
Consent
By using the Website, the User hereby consents to the collection, use, and disclosure of the User’s Personal Information and Personal Health Information in accordance with this Privacy Policy. The User hereby acknowledges and agrees that the User’s access and continued use of the Website shall be deemed as consent by The Circumcision Clinic to collect, use and disclose the User’s Personal Information and Personal Health Information in accordance with this Privacy Policy.
Third Party Payers. The User hereby consents to The Circumcision Clinic: 1) communicating with the User via the email address provided to The Circumcision Clinic by the third-party payer; 2) disclosing the information that the User requested to the third-party payer to permit The Circumcision Clinic to process payment for the services; and 3) notifying the third-party payer of any changes or termination of the User’s access to the Website.
The User acknowledges and agrees that The Circumcision Clinic may be required to disclose Personal Information or Personal Health Information in the limited circumstances that are expressly required by law, for example, where there is an emergency, or a serious risk to the health and safety of the Users or other persons.
THIS WEBSITE IS INTENDED FOR USERS WHO ARE OVER 18 YEARS OF AGE. Persons who are under 18 years of age should not provide Personal Information or Personal Health Information without the express consent of their parents or guardians.
Withdrawal of Consent
The User acknowledges that the User may withdraw consent to The Circumcision Clinic’s collection, use, and disclosure of Personal Information and Personal Health Information at any time by providing notice to The Circumcision Clinic’s Privacy Officer (see contact information below).
If at any time the User does not consent to the collection, use and disclosure of the User’s Personal Information and Personal Health Information by the Circumcision Clinic in accordance with this Privacy Policy, the User must immediately cease using the Website. The User acknowledges and agrees that certain Personal Information will be collected automatically when the User visits the Website and continued use of the Website will be deemed by The Circumcision Clinic to be the User’s consent to collect any Personal Information that derives from Users’ use of the Website notwithstanding the fact that such User has previously communicated their withdrawal of consent for such collection.
The User acknowledges and agrees that a withdrawal of consent does not have retroactive effect and does not affect the collection, uses and disclosures of Personal Information and Personal Health Information collected by The Circumcision Clinic prior to the withdrawal of consent.
The User acknowledges that the User may choose to limit the collection of their Personal Information or Personal Health Information by not entering any such information into forms or data fields on the Website when prompted.
The User acknowledges and agrees that a withdrawal of consent or a limitation of consent will limit the ability of the Circumcision Clinic to provide services and the ability of the User to access certain aspects and functions of the Website.
Users who previously agreed to permit the use of Personal Information for marketing, advertising, or other promotional purposes may revoke their consent by following the opt-out instructions provided in each communication they receive, or by making a request in writing to The Circumcision Clinic’s Privacy Officer.
Collection Personal Information and Personal Health Information
The Circumcision Clinic collects Personal Information and/or Personal Health Information in one (or more) of three ways:
1. Volunteered Information. The Circumcision Clinic collects Personal Information and/or Personal Health Information that is voluntarily provided by a User through the Website (i.e. data or comments entered into forms or data fields on the Website).
2. Information from Public or Third-Party Sources. The Circumcision Clinic may collect Personal Information and/or Personal Health Information of Users who register or access the Website from public or third-party sources.
3. Information Collected from a User’s Computer or other Electronic Device. The Circumcision Clinic Website collects information from a User’s computer and other electronic devices (i.e. phones, tablets, etc.) when a User accesses the Website. The information collected includes, but is not limited to, a User’s Internet Protocol (IP) address, domain name, browser type, date and time of a User’s request and information provided by tracking technologies, such as cookies and single-pixel tags. The Circumcision Clinic may also anonymously use log information on operational systems and identify categories of Users by items such as domains and browser types to properly manage the Website.
Use of Personal Information and Personal Health Information
The Circumcision Clinic collects, uses, and discloses Personal Information and Personal Health Information to provide the User with the services, including the following reasons:
1. to register a User for, and facilitate a User’s participation in, certain areas of the Website (for example, by collecting a User’s name and email address in order to contact the User);
2. User entered / submitted data is used to connect and match potential patients/clients with health care providers, in which case, certain information such as a User’s name, email address, phone number, and responses to assessment questions may be used;
3. to provide information and reminders to Users regarding their appointments or consultations;
4. to properly advertise and promote health care providers and their degrees, specifications, and certifications;
5. to gather a User’s opinion and feedback;
6. internal record keeping;
7. to improve the Website;
8. to audit online resources for authorized access and security;
9. to customize the Website according to a User’s interests; and
10. such other uses as may be permitted or required by applicable law.
The User acknowledges and agrees that The Circumcision Clinic retains the right to use Aggregated Data in any way that it determines appropriate. Aggregated Data may be used for data analytics and may be reported to third parties assisting The Circumcision Clinic in the management and development of the Website. We may capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, this information is used for site optimization, fraud/security purposes, and advertising.
Disclosure of Personal Information and Personal Health Information
Except as otherwise provided in this Privacy Policy, Personal Information and Personal Health Information shall be kept in strict confidence and will not be disclosed without Users’ permission.
Notwithstanding the foregoing, the User acknowledges that The Circumcision Clinic may be required by law to disclose or provide access to Personal Information or Personal Health Information in response to a subpoena, search warrant, court order, law, or regulation. In such case, The Circumcision Clinic will take all appropriate measures to ensure that Users’ Personal Information and Personal Health Information is protected to the greatest extent possible while The Circumcision Clinic cooperates fully with the court and law enforcement authorities in this regard.
When a User agrees to be matched with a health care provider, The Circumcision Clinic will disclose a User’s Personal Information (to the extent consented to by such User) to the health care provider in order to facilitate appointments and communication.
The Circumcision Clinic may disclose Personal Information and Personal Health Information to a buyer in connection with the sale or transfer of its business. In this case, The Circumcision Clinic will require the buyer to agree to treat Personal Information and Personal Health Information in accordance with the terms of this Privacy Policy.
Users acknowledge and agree that The Circumcision Clinic may provide Personal Information or Personal Health Information to affiliates and other third parties that are retained to perform services on The Circumcision Clinic’s behalf. Such third parties will be contractually required to comply with the Privacy Policy. Notwithstanding the foregoing, the Circumcision Clinic cannot guarantee or warrant the security of the User Personal Information or Personal Health Information in the possession or control of third parties and each User hereby acknowledges and agrees that The Circumcision Clinic will have no responsibility or liability in relation to any Personal Information and Personal Health Information in possession or control of any third parties.
Protection of Personal Information and Personal Health Information
The Circumcision Clinic employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information. With respect to Personal Health Information collected, The Circumcision Clinic acts as custodian of the information collected to facilitate a booking. The healthcare provider who supplies the medical service in coordination with the clinic or facilities where they work is the custodian of the information they collect. The Circumcision Clinic thereof and takes all precautions required by PHIPA to prevent the unauthorized disclosure thereof.
The Circumcision Clinic will take all reasonable and legally required steps to protect Personal Information and Personal Health Information as it is transmitted from a User’s computer to the Website or other online resources and servers. The Circumcision Clinic will also protect Personal Information and Personal Health Information from unauthorized access, disclosure, alteration or destruction.
Notwithstanding the foregoing, security risks on the internet cannot be eliminated, and The Circumcision Clinic cannot and does not guarantee that a User’s personal information and personal health information will not be accessed in ways not otherwise described in the Privacy Policy.
It is a User’s personal responsibility to secure a User’s own copies of any logins, passwords and related access codes used on or for the Website.
Storage of Personal Information and Personal Health Information
The User acknowledges and agrees that The Circumcision Clinic uses third-party cloud-based data collection and storage methods and products, including Squarespace, Acuity Scheduling, Google, and Stripe. The Circumcision Clinic cannot guarantee or warrant the security of any information, including Personal Information and Personal Health Information, collected or stored by any third-party services providers. The User acknowledges and agrees that The Circumcision Clinic will have no responsibility or liability in relation to any information, including Personal Information and Personal Health Information, collected or stored by any third-party services providers. You may wish to review in connection with your consideration of The Circumcision Clinic.
Third-party service providers engaged by The Circumcision Clinic may host, transfer, and process data, including Personal Information and Personal Health Information, in the United States and in other countries, and subject to the laws of such jurisdictions and to the terms of their own respective privacy policies. By using the Website, the User hereby consents to the storage of the User’s Personal Information and Personal Health Information in servers located throughout Canada, the United States, and in other countries, including by third-party cloud-based data collection and storage methods and products used by The Circumcision Clinic.
Access and correction to personal information and personal health information
Users may access, update, and correct inaccuracies in Personal Information in The Circumcision Clinic’s possession, subject to certain exceptions prescribed by law.
Upon written request to The Circumcision Clinic’s Privacy Officer, The Circumcision Clinic will provide a User with any Personal Information and Personal Health Information in its possession to the extent required by law. If a User would like to access any of its Personal Information and Personal Health Information, or believes that any of the Personal Information and Personal Health Information collected by The Circumcision Clinic relating to a User is incorrect or incomplete, the User should contact The Circumcision Clinic’s Privacy Officer (see contact information below).
Retention and Deletion of Personal Information and Personal Health Information
Unless otherwise notified, The Circumcision Clinic will retain a User’s information until the access to services is terminated by the User or The Circumcision Clinic. Upon termination, the User will be provided with the opportunity to download their booking and payment history. Once downloaded, The Circumcision Clinic will not retain any other information except as required under applicable law. Other information relating to the services provided to the User by any health care provider maybe available from the health care provider directly. When information is deleted, it is removed from our active database. Any information that remains is securely stored and isolated from any further processing until deletion is possible.
Miscellaneous
Former Users. If a User ceases using the Website, or a User’s access to the Website has been terminated for any reason, The Circumcision Clinic may continue to use and disclose a User’s personal information and personal health information in accordance with the Privacy Policy.
Terms and Conditions of Use of Website. Any applicable terms & conditions of use governing a User’s use of the Website, including but not limited to the Terms of Service, contain important provisions, including provisions disclaiming, limiting, or excluding the liability of The Circumcision Clinic for a User’s use of the Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding a User’s use of the Website. Each of those provisions applies to any disputes that may arise in relation to the Privacy Policy, including any collection, use and disclosure of Personal Information and Personal Health Information and are incorporated in this Privacy Policy.
Third Party Links and Web Sites. The Website may contain links to third-party websites or internet resources, which are not affiliated with the Website, nor provided by The Circumcision Clinic, and are not subject to the Privacy Policy. The User assumes any risk associated with any third-party links or websites. The Circumcision Clinic assumes no responsibility or liability for, or control over any third-party websites or their collection, use and disclosure of a User’s Personal Information and Personal Health Information.
Privacy Policy Amendments. To accommodate amendments to the Website, changing technology, and legal developments, this Privacy Policy may be amended from time to time in The Circumcision Clinic’s absolute discretion and without any prior notice to the User or any other person. The Circumcision Clinic’s collection, use and disclosure of the Personal Information and Personal Health Information through the Website will be governed by the version of the Privacy Policy in effect at that time when the information is collected, used, or disclosed. New versions of the Privacy Policy will be posted on the Website and will be available upon request from The Circumcision Clinic. A User’s continued access, use and/or dealings with the Website after any amendments to the Privacy Policy, will be deemed a User’s consent or continued consent to the collection, use and disclosure of Personal Information and Personal Health Information in accordance with the Privacy Policy as amended from time to time.
Contact. For more information about the Privacy Policy, please contact the The Circumcision Clinic Privacy Officer, via electronic mail at:
Admin@TheCircumcisionClinic.ca.
Further Information. For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3
or your provincial office of the Information and Privacy Commissioner.