2. Information collected by the Merogenomics Inc.
2.1. Nonpersonal Information
Nonpersonal information is information that is anonymous and that cannot be traced back to you and used to identify you as an individual. Anonymous information is compiled as aggregate statistics and is used to track the behaviour of visitors who access Merogenomics Inc. services including website access.
Anonymous information includes the source of incoming traffic (such as the Internet Protocol "IP" address, the Internet service provider, the browser and platform type, and the referring source, including the domain name) and trends associated with service use (timing, quantity, type, order of usage, and duration of services used). For example, this can include website page views, content explored during a website visit and the length of time the website was viewed, items downloaded, search terms entered on the website (or a referral site), what the exiting site is when leaving the website, and if Cookies and other electronic tags were used to track anonymous behaviour (see below for a definition of Cookies). Access to and use of the Merogenomics Inc. website without Client commitment to additional services allows for nonpersonal information collection only.
Information about Healthcare Providers may be collected without an association to personal information. Merogenomics Inc. may collect information from Service Providers regarding analytical equipment and methodologies used to deliver services.
Cookies are small text files that are stored on the hard drive of your computer when a specific website is visited. Such a text file acts as a unique identifier associated with the IP address of your computer; that is, the site recognizes your computer when the website is revisited in the future. The ability to identify a returning source can be used to monitor and save preferences associated with the visiting source (that is, preferences can be saved for a specific IP address). Tracking of preferences can enhance the services provided by Merogenomics Inc. and tailor them to Client needs.
A Cookie in no way provides access to a personal computer, and Cookies are not used to collect personal information that could identify a specific user.
Cookies are provided at the request of a website being visited and can be used only if the request is accepted. Most browsers are automatically set to accept Cookies. You have the option to reject, disable and remove Cookie information at any time by adjusting browser preferences on your computer. Rejection of Cookies use will not prevent access to the Merogenomics Inc. website, however, it might limit access to certain website components (for example, previously saved information linked to a specific IP address). To learn more about Cookies, including how to manage them, click here.
Nonpersonal information is collected in an automated fashion, and is used to analyze which services clients do or do not find useful. Such information enables Merogenomics Inc. to tailor its services to Client needs and to improve Merogenomics Inc.’s marketing scope. Please refer to section 3 for complete details on information use and disclosure.
2.2. Personal Information
Personal Information is information that can be used to identify you as an individual. Merogenomics Inc. collects Personal Information about the Client at the point of commercial transaction, during registration (for example for an account or a newsletter), during survey participation, in public access forums (such as chat rooms, community forums, or blog comments sections), and when you communicate with Merogenomics Inc. Such information may include, but is not limited to, your name, your contact information (email address, postal address, telephone number), payment information, purchase history, and additional areas of interest such as demographic information (when it is voluntarily submitted) such as age, education level, gender, etc., and email preferences.
Access and use of certain restricted functionalities of the Merogenomics Inc. website may require the Client to register for an account (hereafter referred to as “Client Account”) and provide a user ID and password. For example, such process may be required to download and electronically receive data from a genome sequencing procedure. User ID, password, and account preferences will be kept in association with collected Client Personal Information.
You are the sole custodian of your Client Account and are responsible for safekeeping of such information.
Besides the use of Personal Information to perform a sales transaction, such information helps Merogenomics Inc. better understand who are the interested clientele of its services, how to tailor the services for the benefit of Clients, and how to improve the marketing of services to the general public. Please refer to section 3 for complete details on information use and disclosure.
2.3. Health Information
Health Information is health related data that can be linked to a specific individual. This can include medical history, medical records information, laboratory test results (such as genome sequence information), or insurance information.
Merogenomics Inc. aims to have minimal or no access to the Health Information of its Clients. However, Merogenomics Inc. can gain access to Health Information during delivery of its services. Such Health Information is sometimes necessary. For example, Merogenomics Inc. would need to know the cancer type in association with a Client name when seeking an appropriate test to fulfill the Client’s needs. Currently, Merogenomics Inc. does not require the Client to provide Health Information in its registration forms; such information is provided voluntarily by the Client in communication with Merogenomics Inc.
With explicit consent of the Client, Merogenomics Inc. may share Client Health Information with Service Providers or other third parties (affiliated and unaffiliated) to enhance Client services. Such information can also be used to perform Merogenomics Inc.’s business operations or shared as required by law. Please refer to section 3 for complete details on information use and disclosure.
Health Information is used by Merogenomics Inc. and its Service Providers in accordance with regulations in Alberta’s Health Information Act and applicable Canadian laws governing patient privacy.
3. Information use and disclosure
3.1. Use of your information
Access to personal data is restricted to Merogenomics Inc. employees who perform the following business functions:
1) Contact you to respond to your inquiries or provide you with requested information;
2) Process commercial transactions and deliver services you have ordered from Merogenomics Inc.;
3) Administer your Client Account with Merogenomics Inc.;
4) Provide you with promotional information (novel products, services, events or special offers) which Merogenomics Inc. believes might be of interest to you;
5) Assist you with technical support;
6) Contact you for market research purposes;
7) Enforce our Terms of Agreement and other policies governing the use of Merogenomics Inc. services;
8) Protect rights and property of Merogenomics Inc.;
9) Recover debt owed to Merogenomics Inc.;
10) Prevent fraud.
Use of your Personal Information for any other purpose will require your explicit consent.
Merogenomics Inc. may combine and match your Personal Information with your Health Information and your nonpersonal information as submitted or collected from various available sources (including third parties) at various times. Such combined information may be compiled into aggregate data without personal identifiers by Merogenomics Inc. to:
1) Maintain internal record keeping;
2) Measure interest in and use of Merogenomics Inc. services;
3) Improve Merogenomics Inc. services;
4) Develop and test new products and features;
5) Develop and test new marketing material;
6) Diagnose or fix problems.
3.2. Disclosure of information
Merogenomics Inc. does not disclose Personal Information or Health Information to unaffiliated third parties without the Client's prior consent except as may be required by exigent circumstances listed below. The term “unaffiliated third parties” does not include third party associates who assist Merogenomics Inc. in operating the Merogenomics Inc. website, in conducting our business, or in providing services to the Client (i.e., contracted external contractors collectively referred to hereafter as “Service Providers”). Your Personal Information and Health Information is shared with Service Providers only when it is necessary for Merogenomics Inc. to respond to your inquiries or to provide commercial transaction services.
Merogenomics Inc. may disclose Personal Information or Health Information to obtain information of benefit to the Client, including information from unaffiliated third parties, in a quest to enhance a particular service for the Client. For example, use of a Client’s name and medical condition (such as cancer type) when contacting experts for opinion and/or advice. When use of a Client’s Personal Information in such correspondence is warranted, the Client will be asked for permission.
Disclosure of nonpersonal information is at the sole discretion of Merogenomics Inc. Such anonymous information is disclosed on an aggregate basis, in a format that does not include the Client’s name or contact information.
Your information may be disclosed to individuals who might require such information to provide treatment or directives toward treatment to you, such as your physician or other healthcare providers and professionals, or designated individuals involved in your care.
Your information may be disclosed to obtain payment for services provided by Merogenomics Inc. This may include our affiliated Service Providers, your health insurance company, or designated individuals involved in the payment for your care.
(C) Personal representatives or family members
Your information may be disclosed to an authorized personal representative, such as a lawyer, executor, or other designated individual, or who is desired by you to have access to such information (for example, a family member or a close friend).
(D) Minors' health information
Personal Information about an individual who is under the age of 18 (hereafter referred to as "Minor") may be disclosed to a parent or legal guardian.
(E) Products and services marketing
Your information may be used by Merogenomics Inc. to contact you to provide you with promotional information which Merogenomics Inc. believes may be of interest to you. This can include information about novel products, services, events, or special offers that may be related to your treatment, care, or case management.
Merogenomics Inc. will not disclose sensitive Client information such as Personal Information or Health Information to third parties for marketing purposes without prior written authorization. If such authorization is obtained from the Client, the authorizing document will disclose the financial compensation received by Merogenomics Inc., if any. The authorization can be revoked at a future time.
(F) Sale of information
Merogenomics Inc. will not sell your Personal Information or Health Information unless provided with prior written authorization. If such authorization is obtained from the Client, the authorizing document will disclose the financial compensation received by Merogenomics Inc., and if applicable, the financial compensation received by the Client. The authorization can be revoked at a future time.
(G) Disclosures to business associates
Your information may be disclosed to affiliated third parties (companies or individuals) who provide services to Merogenomics Inc. or to the Client, if required for the fulfillment of the services. For example, this can include a company to perform administrative services for Merogenomics Inc. or Service Providers.
The third party associates used by Merogenomics Inc. (and their subcontractors) are contractually required to protect the privacy and security of your Personal Information and Health Information and to notify Merogenomics Inc. and the Client if improper disclosure of information or breach of security has occurred.
Your information may be disclosed for research purposes with your consent. Prior to the consent, the Client will be provided with an informed consent form delineating the purpose and planned details of the research project, the risks of participation, the participant’s rights, and the support network available for participants. Research projects will be under review by a supervisory committee, independent of Merogenomics Inc., that is responsible for ensuring the protection of research project participants’ rights, and the safety and confidentiality of their information. The supervisory committee will ensure that authorization was obtained in an appropriate manner.
(I) Change of ownership
(J) De-identified information
Your information may be disclosed once it has been de-identified as permitted under applicable laws. De-identified information does not identify a specific individual, and is compiled into aggregate data for statistical analyzes for the general administration and operation of Merogenomics Inc. services. For example, such information can include cancer types observed among clientele.
Once the Client de-identified information becomes part of aggregate data, it can no longer be associated with a specific identity and hence can no longer be isolated and deleted upon request.
(K) As required by law
Your information may be disclosed as required to comply with applicable federal or local law. Merogenomics Inc. will take reasonable steps to protect Client anonymity and will inform the court of existing factors that justify confidentiality and protection of your Personal Information or Health Information. In the event that Merogenomics Inc. is legally compelled to disclose your information, such proceedings will occur only in compliance with properly issued court order, warrant, subpoena, governmental request, regulatory compliance, or other legal process. Merogenomics Inc. will promptly notify you of the information request prior to disclosure, unless doing so would be in violation of the law or court order. In such instance, the affected Client will have an opportunity to object and challenge such information disclosure in court.
(L) Property protection
Your information may be disclosed to protect the property or rights of Merogenomics Inc. This can include disclosure to credit bureaus to process late or missed payments, disclosure to enforce Merogenomics Inc. policies governing delivery of services, or disclosure for other dispute resolution or unlawful activity that exposes Merogenomics Inc. to legal liability or cost. Merogenomics Inc. will inform the affected Client of such circumstances prior to Personal Information disclosure, and attempt to amicably resolve the dispute. Merogenomics Inc. will disclose Personal Information only when we believe that such disclosure is necessary to protect our rights or property, and disclosure will proceed in accordance with federal and local laws.
(M) All other uses and disclosures of Health Information
4. Storage, processing, and security of your information
4.1. Storage and processing
The Client information collected by Merogenomics Inc. will be stored and processed in Canada (headquarters of Merogenomics Inc.), or in a country in which the Service Providers maintain facilities. Please note that because the third-party Service Providers may be located in the United States and possibly other countries, those Service Providers may store your confidential Client information on foreign servers. Some of these third-party Service Providers may be participants in a program of the U.S. National Security Agency. If this is the case, then this would mean that your confidential information provided to those Service Providers located in the U.S. would be available to U.S. federal law enforcement agencies and may be accessed, stored indefinitely, and used by those agencies without notice to you.
Duration of storage is permanent for nonpersonal information and de-identified health information. All Personal Information and Health Information collected from the Client will be erased from databases within two weeks (14 days) of completion or termination of ordered services. Exceptions will be made if the Client chooses to use additional Merogenomics Inc. services, or to remain on the contact list for future company updates.
4.2. Security of your information
Merogenomics Inc. is committed to keeping Client information secure, and uses the following recommended industry standards to ensure this goal is achieved.
1) The servers used to process and store collected data are controlled with restricted access;
2) Information collected through the Merogenomics Inc. website is encrypted with industry standard Secure Sockets Layer (SSL) technology. Transmission of Personal Information or Health Information to servers used by Merogenomics Inc. or affiliated third parties is also SSL encrypted. An important exclusion to such encryption is information transmitted by email;
3) The servers used by Merogenomics Inc. for data storage are protected by firewalls;
4) Information collected by Merogenomics Inc. is regularly backed up for protection against loss, as are the systems used for data protection;
5) Access to sensitive Client data requires both a personal user ID and a password, as determined by the Client;
6) The number of individuals who access Personal Information or Health Information is limited, and closely monitored. For example, employees, third party contractors, unaffiliated third parties, as required for operational needs or by Client request are all closely monitored;
7) Computers used to store information are encrypted, password protected, and kept in locked facilities.
While Merogenomics Inc. aims to protect the security and confidentiality of Personal Information and Health Information via the commercially reasonable efforts listed above, due to the global scale of Internet use for data transmission, storage, and exchange, it cannot be completely guaranteed that selected security measures will prevent unauthorized third parties (such as "hackers”) from illegally accessing such information during or after transmission.
Such unauthorized third parties may resort to unethical methods such as the use of viruses, worms, or Trojan horses to either obtain or damage information processed by Merogenomics Inc. or affiliated third parties.
Therefore, Merogenomics Inc. does not warrant or represent that any information it collects, stores, transmits, or is otherwise maintained in its care, including your Personal Information and Health Information, will be protected against accidental disclosure, loss, misuse, or alteration by unauthorized third parties. Merogenomics Inc. does not and cannot assume any responsibility or liability for information collected through unauthorized third party intrusions, and submission of information is always at the Client’s own risk.
In the event Merogenomics Inc. becomes aware of a potential compromise of your Personal Information or Health Information, depending on the nature of the event, and subject to our sole discretion, Merogenomics Inc. will endeavour to promptly notify you of such developments using your email address. The nature of the event refers to the assessment of the probability that security of information has been compromised, as determined by affiliated third party providers contracted by Merogenomics Inc. to maintain data storage.
If you desire other means of notification under such circumstances, please email your preferences to email@example.com.
Merogenomics Inc. can recommend an alternate form of electronic communication with enhanced security to protect Client data.
4.3. Voluntary disclosure of information on Public Forums
Disclosure of Personal Information or Health Information by the Client on publicly accessible Internet interactive areas such as blogs, message boards, community forums, profile pages, or chat areas (hereafter collectively referred to as Public Forums), exposes such information to be viewed, collected, and used by third parties who access the same Public Forums. How such information might be used by third parties is beyond the control of Merogenomics Inc. For example, it may result in unsolicited contact with the Client. Merogenomics Inc. bears no liability or responsibility for the information content that is voluntarily submitted by the Client (or any third party) to Public Forums, and makes no warranties about third party access and use of submitted information. Merogenomics Inc. cannot review the information content prior to it being posted on a Merogenomics Inc. website by the users, and Merogenomics Inc. cannot guarantee that a prompt action can be taken to remove objectionable content. The Client is advised to carefully consider the type of information that is disclosed in Public Forums. Voluntary disclosure of Personal Information or Health Information on Public Forums is done at the Client's own risk.
Merogenomics Inc. reserves the right to edit or remove any material posted to Public Forums offered by Merogenomics Inc.
5. Information access, updates, and choice
This section informs the Client of his or her rights with regard to the information collected by Merogenomics Inc. The Client can exercise these rights by contacting Merogenomics Inc. using the “Contact” form available on the website or by sending email at firstname.lastname@example.org.
5.1. Client information: access and modification rights
The Client (or an authorized representative of the Client) may access his or her Personal Information or Health Information that is stored by Merogenomics Inc. The Client will be required to verify his or her identity by requesting details of Client information previously provided to Merogenomics Inc. before access will be granted to personal data.
A fee may be charged to cover the production cost of a summary report containing information requested by the Client.
If you believe that the Personal Information or Health Information that is stored by Merogenomics Inc. is inaccurate or requires alteration to reflect novel status (such as new contact information or name change), you are requested to inform Merogenomics Inc. promptly in writing describing the information that should be corrected or updated, and stating the reasons for the desired information modification.
Merogenomics Inc. reserves the right to reject any requests for data modification; in such case the Client will be informed of our decision and reasons behind it. However, the Client will have the right to request that a record of the request be added to the Client’s stored information.
5.2. Client information choices
5.2.1. Restrictions on uses and disclosures
Merogenomics Inc. reserves the right to reject any request, and the Client will be informed of our decision and the reason(s) behind it in the event that Merogenomics Inc. rejects a request. In such circumstance, a written statement of disagreement with our decision, submitted by the Client, will be taken into further consideration by Merogenomics Inc.
The Client has various opportunities to elect to receive newsletters or other promotional communication from Merogenomics Inc.; such opportunities are available during Client Account registration, email correspondence, or through the website. The Client can opt out of receiving promotional material by clicking on the “unsubscribe” link within received email, or by sending email us at email@example.com.
5.2.2 Data removal
The Client can request that Personal Information or Health Information be no longer collected, and/or ask Merogenomics Inc. to delete existing data. While Merogenomics Inc. will strive to achieve complete data elimination, residual Personal Information and/or Health Information might remain within databases or other records used by Merogenomics Inc. Complete data destruction might not be feasible. Merogenomics Inc. bears no responsibility for the removal of information that has been posted by the Client on Public Forums, and Merogenomics Inc. cannot guarantee that all posted messages can be deleted. In addition, Merogenomics Inc. may retain portions of collected information, including Personal Information, for a period of time as necessitated by business operations (such as completion of a commercial transaction or dispute resolution), or as required for legal reasons. Merogenomics Inc. reserves the right to retain the Client’s email address and to contact former Clients or users of the Merogenomics Inc. website via retained email addresses.
Merogenomics Inc. reserves the right to reject requests to delete information in certain circumstances. In such circumstances the Client will be informed of our decision and the reason(s) behind it. In the event that Merogenomics Inc. rejects a request to delete information, the Client can submit a written statement of disagreement with our decision, which will be taken into further consideration by Merogenomics Inc.
5.2.3 Confidential communications
The Client can request an alternate form of communication that is offered by Merogenomics Inc. for enhanced security of information provided by the Client. The alternate form of communication is limited to the choices provided by Merogenomics Inc.
5.2.4 Accounting of disclosures
The Client can request to obtain a history of past disclosure(s) of Personal Information and/or Health Information. A historical account of disclosures lists the dates of the disclosures, to whom the data were disclosed, and the purpose behind the disclosures.
Disclosure of nonpersonal information or de-identified information is not tracked by Merogenomics Inc. in association with specific individuals, and therefore accounting of such disclosures cannot be provided to the Client.
6. Third party information
If the Client needs to provide third party Personal Information or Health Information to Merogenomics Inc. (that is, information regarding an individual other than the Client or Client’s dependant), the Client must provide notice to, and obtain consent from, such third party to deliver such information.
Merogenomics Inc. bears no liability or responsibility for information about a third party that is provided to Merogenomics Inc. by the Client.
7. Linked third party websites
8. Use by Minors
The Merogenomics Inc. website and services are directed toward adults, and are not intended for nonadult use without the authorization of a guardian adult (parent or legal custodian).
If you are under the age of 18, you must obtain the permission of a guardian adult to use the Merogenomics Inc. website. Merogenomics Inc. will not knowingly collect, use, or disclose any Personal Information or Health Information from an individual under the age of 18 without the authorization of a guardian adult. If Merogenomics Inc. becomes aware that Personal Information was collected from a minor without consent of a guardian adult, such information will be promptly removed from Merogenomics Inc. databases.
9. Financial information
10. Governing laws
11. Contact information
The Client should be aware that transmission of information in any form that excludes SSL encryption, such as email, is especially at risk of being intercepted or viewed by unauthorized third parties while in transit. The Client is advised to carefully consider the type of information that is disclosed by email or other unsecure channels of communication. To keep information provided to Merogenomics Inc. strictly private, do not send your information to Merogenomics Inc. by e-mail or other unsecure channels.
Merogenomics Inc. can also be contacted by post mail at the address listed below, or by alternate forms of electronic communication with enhanced security to protect the provided Client data.
10060 Jasper Avenue
Tower 1, Suite 2020
In the event that Merogenomics Inc. cannot satisfactorily resolve your inquiry, you have an option to contact the Office of the Information and Privacy Commissioner of Alberta which governs privacy policies in the private sector.
Effective Date: December 10, 2016