Privacy Policy

We collect Personal Information to provide our services and improve your experience, and we limit the collection to what is necessary for these specific, identified purposes, as detailed below: 

• Contact information (ex. name, company, job title, phone, fax, email, address), if you provide it to us.
  
  • Purpose: to communicate with you, respond to your inquiries, manage our relationship and to provide you with tailored marketing communications, promotional offers, and updates about products or services that may interest you.
• Account Information (ex. username; a secure hash of your password is created and managed through our e-commerce platform provider and is not accessible to us.)
  
  • Purpose: to allow you to create and manage an account in our store and to provide secure access to your order history and preferences.
• Biographical/Demographic Information, and Health Information with your explicit consent.
  
  • Purpose: to provide you with personalized services and to fulfill specific requests that require this information.
• Financial information (ex. partial payment card details and transaction information. We use a third-party payment processor to process your payments. We do not collect or store full payment card numbers or CVV codes; this information is collected directly by our payment processor.)
  
  • Purpose: to process your payments for products or services and to prevent fraudulent transactions.
• Purchase and Customer Service History
  
  • Purpose: to provide customer support, facilitate product refills or renewals and improve our services
• Location Data (ex. IP, country, zip/postal code, and mobile device location)
  
  • Purpose: To provide you with geographically relevant services, deliver localized communications, and analyze website usage trends.
• Data from interactions with social media posts on platforms like LinkedIn.
  
  • Purpose:  to engage with you, understand user sentiment, and respond to inquiries.
• Marketing & Communications Preferences
  
  • Purpose: to send you newsletters, promotional materials, refill/renewal reminders, and localized updates. You may opt-out of these communications at any time via the subscribe link.
• Online Activity Data (ex. device information, browsing history) gathered via cookies, web beacons, and similar technologies.
  
  • Purpose: to analyze website traffic, remember your preferences, and improve our services.
• Any Personal Information you submit to us through the “Contact Us” section of this Notice.
  
  • Purpose: To respond to your inquiries and address your requests.

We will not use your Personal Information for new purposes without your consent.

By using our website or services, you consent to our collection, use, and disclosure of your Personal Information as set out in this Privacy Notice. For certain purposes, or where required by law, we will obtain your explicit, opt-in consent. 

We collect information in three main ways: 

• You provide it to us: for example, when you fill out registration forms, subscribe to a newsletter, order products, or contact us.
• Automatically: such as your IP address, browser type, pages viewed, and approximate location based on IP. We use cookies and similar technologies to improve website performance and your experience.
• From trusted third parties: such as service providers, only when lawful and with required consent. 

We do not knowingly collect information from individuals under the age of 14, and we do not knowingly use our services to profile them. For minors under 14, we will seek the explicit, separate, and informed consent of the parent or legal guardian. Minors aged 14 or older may provide their own consent.  

We may share your information with:

• Service Providers – such as organizations that assist us in operating our website, processing payments, and delivering services
• Legal or regulatory bodies – if necessary to comply with laws – for example, in response to a subpoena or government request.
• Affiliates – such as other companies within our corporate group:
  
  • Operational: where necessary to respond to your inquiry, provide requested services, or for internal administrative purposes.
  • Marketing: to send you email communications about products or services that may interest you. We will only share your information for this purpose with express opt-in consent.   
• In a business transfer – such as a merger or acquisition. We will notify you of such a change in ownership or transfer of assets, to the extent we are able to do so, by posting a notice on our website.
• Butterfly Network - When you purchase a Butterfly medical device product through our website, we share your contact information (such as your name and email address) with Butterfly Network to enable account creation on the Butterfly platform. We share this information securely and only for this specific purpose. By purchasing the product, you consent to this data sharing. You may review Butterfly’s privacy practices on their website. 

We are accountable for all Personal Information under our control, including information transferred to a third party for processing. We do not sell your Personal Information.

Your Personal Information may be stored on servers located in Canada and the United States, where our primary cloud service providers are based. Some of our third-party service provides (for example, our payment processor) may process personal information in other countries outside of Canada. In those cases, your information is subject to the laws of those jurisdictions, and we rely on those providers’ privacy and security safeguards. 

For residents of Quebec, before any international data transfer, we conduct a Privacy Impact Assessment to ensure that the destination jurisdiction provides an adequate level of protection for your Personal Information. In jurisdictions where the protection is not equivalent to that of Quebec, your explicit consent is required. Consent is obtained through clear, separate opt-in mechanisms on this website, such as cookie banners or consent forms.

You may withdraw your consent at any time by adjusting your cookie preferences or contacting us directly. Withdrawing consent may limit your ability to access certain features or services.

We use cookies and similar technologies, in accordance with our Cookie Policy to:

• Make our website work properly
• Remember your preferences
• Analyze website traffic
• Deliver relevant content and ads

For example, we use Google Analytics, a web analytics tool that helps us understand how visitors engage with the Services. We obtain your specific, opt-in consent before collecting or using any data that can identify, locate, or profile you via these technologies.  To learn more about how Google uses information from sites or apps that use its services, please visit https://policies.google.com/technologies/partner-sites.

You can manage cookies in your browser settings and our cookie banner. 

Microsoft Clarity

We use Microsoft Clarity to better understand how users interact with our website and to help us improve user experience. Clarity is a web analytics and session replay tool that collects data through cookies and similar technologies to capture information about website usage, such as pages visited, scroll activity, mouse movements, clicks, and engagement patterns. Clarity may also collect information about your device (e.g., browser type, operating system), approximate geographic location based on IP address, and technical identifiers. 

The data collected may be used to generate heatmaps and session recordings, which help us analyze how users navigate and interact with the website. Microsoft Clarity does not collect sensitive personal data such as keystrokes in form fields, and fields designed to collect personal or sensitive data are automatically masked. The data may be stored and processed by Microsoft on our behalf in accordance with their Privacy Statement.

The legal basis for this processing, where required by applicable law, is your explicit consent. Microsoft Clarity is only activated after you have provided clear and affirmative consent through our cookie consent banner or tool. You can withdraw your consent at any time by adjusting your cookie preferences via the consent management tool or by changing your browser settings to disable cookies.

Data collected through Microsoft Clarity is retained for up to 13 months, after which it is automatically deleted. We do not use this data to identify you directly, and it is used solely for website optimization, diagnostics, and aggregated analytics purposes.

Online Purchases 

When you make purchases on our website, your payment details are sent directly to third-party service providers solely for order fulfillment and payment processing. Providers may only use the data on our behalf.

External Websites

Our website may contain links to other websites. You should review the privacy notice of the other websites that you may link to via our website as their privacy notice may differ from ours. We are not responsible for the privacy practices of other websites.

Limiting Use, Disclosure and Retention 

Except as necessary to fulfill our business obligations, or in response to your express instructions, we do not sell, transfer, or disclose Personal Information without your express consent, except as authorized by law. 

We retain Personal Information only as long as necessary to fulfill the purposes for which it was collected or to meet legal, regulatory, or legitimate business requirements. Some categories of information may be retained longer when needed for legitimate business purposes, but only with clear disclosure and, where required by law, your consent.

When Personal Information is no longer required, we securely delete it or anonymize it to prevent identification.

Safeguards and Security 

We implement reasonable technical, organizational, and administrative safeguards designed to protect the Personal Information we collect; however, no method of transmission over the internet is entirely secure and we therefore cannot guarantee the absolute security of your Personal Information. You are responsible for the security of your devices and passwords.

Depending on your region, you have rights under applicable privacy laws which may include:

1. Access to, and correction, of your Personal Information
   
   1. Deletion, destruction, or erasure of your Personal Information, or the right to have a hyperlink de-indexed, where applicable
   2. Changing your consent options and withdrawing consent at any time (subject to legal or contractual limits)
   3. Data portability, in a structured, commonly used technological format, if applicable
   4. Objection to processing, including automated decisions with legal or similarly significant effects, and the right to request human review. 

To exercise these rights, contact our Privacy Officer using the details provided in the “Contact Us” section of this Notice. We will respond within the required legal timelines and notify you if more time is needed. If a request is denied, we will explain why and inform you of your available complaint options, including how to contact the relevant oversight authority.

Certain rights or processes may be subject to legal exceptions, such as protecting minors or preventing harm. For residents of Quebec, additional rights and protections apply under Law 25, including specific consent requirements for minors under the age of 14. In such cases, consent must be clear, informed, and requested separately in simple language from the parent or legal guardian. Minors aged 14 or older may provide consent themselves or through their guardian. Individuals must also be given the means to withdraw consent at any time.

For residents of Quebec, we may disclose personal information about a deceased individual to your spouse or close relative if such information is likely to assist that person in their grieving process. You have the right to refuse this posthumous disclosure. If you wish to record a refusal to grant this right of access to your successors, please do so by contacting us using the contact details provided under the “How to Contact Us” section of this privacy policy. 

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) or the Commission d'accès à l'information du Québec (CAI).

For any privacy questions or concerns, please contact our Privacy Officer in writing at:

Trudell Healthcare Solutions Inc. 
758 Baransway Drive
London, Ontario N5V 5J7
Attention: Privacy Officer

Email: yourprivacy@trudellhs.com