Privacy Policy

The Essential Clinic Privacy Policy was updated on March 15, 2024.

1. Introduction and defined terms

This Privacy Policy (“Policy”) describes how Essential Health Systems Inc. doing business as EssentialClinic.ca (“Essential Clinic”, “we”, “us”, “our”) collects, uses, discloses, retains, disposes of, destroys and protects Personal Information as well as information that does not identify an individual in the course of providing our services.

There are a number of defined terms used in this Policy:

“Authorized Clinician” means a clinician who is registered to practice medicine in a Province or Territory of Canada, meets Essential Clinic’s other criteria, and is permitted to provide Healthcare Services and/or Informational Services through the Essential Clinic Platform.

“Health Care” means any observation, examination, assessment, care, service or procedure that is provided by a clinician to an individual to diagnose, treat, or maintain the individual’s physical or mental condition, to prevent disease or injury to the individual, or to promote the individual’s health.

“Healthcare Services” means the provision of Health Care by an Authorized Clinician through the Essential Clinic Platform.

“Informational Services” means the provision of general information about a disease or condition, rather than patient specific medical information, for educational purposes only and for clarity, not including a diagnosis, treatment or advice based on observation, examination or assessment of a particular patient.

“Essential Clinic Platform” means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Clinicians to provide Healthcare Services and Informational Services to Authorized Users.

“Personal Information” means information that we can reasonably use to directly or indirectly identify you, such as your name, date of birth, country of origin, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and includes PHI (defined below).

“Personnel” in relation to Essential Clinic, means its employees and agents including independent contractors and sub-contractors, for whom Essential Clinic is responsible at law.

“PHI” means Personal Information about an individual’s physical or mental health, or about their diagnosis, treatment and care.

“Subprocessors” means the third-party service providers engaged by Essential Clinic listed in the table under the heading (V).

“User(s)” means an individual or group who has requested Essential Clinic services and registered on the Essential Clinic Platform in accordance with our Terms of Service and is eligible to receive Healthcare Services and/or Informational Services through the Essential Clinic Platform.

“Website” means the Essential Clinic Platform.

2. Purpose of policy

Essential Clinic uses a number of safeguards to protect the privacy of Users (“you”, “your(s)”) of the Essential Clinic Platform and the confidentiality of their Personal Information including PHI.

This Policy is designed to provide transparency regarding Essential Clinic’s privacy policies with respect to your Personal Information we collect from you when you use the Essential Clinic Platform, in accordance with the rules and protections governing such information under applicable law.

We are committed to complying with this Policy and with all applicable Provincial and Federal privacy legislation and health information privacy legislation.

When discussing Healthcare Services, Personal Information refers to PHI, and when discussing Informational Services, Personal Information typically refers to Personal Information that is not specifically about you or your health, such as Personal Information in questions you would be comfortable asking of an expert during the call-in portion of a radio broadcast on health-related matters. PHI is not required for Informational Services, and we advise you to not to submit PHI in the course of accessing Informational Services.

(For an explanation of the services that Essential Clinic provides to Authorized Clinicians and to Users respectively, please refer to the agreement between Essential Clinic and clinicians providing services through the Essential Clinic Platform, (Essential Clinic Clinician Services Agreement) and the Terms of Service for the Essential Clinic Platform.)

This Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Personal Information by Authorized Clinicians or any other third party. Authorized Clinicians are subject to privacy legislation and professional requirements that govern their management of Personal Information, including Personal Information they collect, use and retain in the course of providing services through the Essential Clinic Platform. Please feel free to ask any Authorized Clinician to whom you are referred if you have questions about how he or she will treat your Personal Information.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. If you do not agree with our policies and practices, your choice is not to use the Essential Clinic Platform. By accessing or using the Essential Clinic Platform, you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy).

Your continued use of the Essential Clinic Platform after we make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates. We will notify you in advance of any material changes to this Policy and obtain your consent to any new ways that we collect, use, and disclose your Personal Information.

3. What kinds of information do we collect?

We collect Personal Information, including:

• PHI (defined above);
• Payment information, including credit card or other mode of payment data. Financial transactions relating to the Website, as and when they are offered, will be handled by our third party payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments and related transactions.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, Website pages viewed, sections of the Website used or viewed, and usage details.
• Location data through the use of GPS technology and your IP address where applicable to services you have requested, e.g., ensuring you are connected to an Authorized Clinician or pharmacy that is licensed or authorized to provide such services in the jurisdiction where you are located.
• Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to a newsletter, registering through authentication with the Website, posting material, and/or requesting further services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• A copy of your government-issued photo identification, and the Personal Information about you on such identification, for the following purposes:
  • To verify your identity: a copy is shared with our service provider, Vouched, who then extract the user’s name, date of birth, address, ID type, country, province, issue date and expiry date, as well as the last few numbers of the ID number. Vouched, in turn, has its own privacy policy that applies when it collects this Personal Information from us. We will retain this Personal Information ourselves after sharing it with Vouched, for the purpose of filling future orders from you.
  • To comply with law: Pharmacies in Canada are typically required by law to collect identifying Personal Information about patients before filling prescriptions. We must therefore provide this Personal Information to our pharmacy partners that supply our clients. As well, we must provide this Personal Information to our professional providers who may provide services to you, as they are required by law to collect such Personal Information by their own professional regulatory legislation. We retain this Personal Information ourselves after sharing it with the pharmacists or professional providers. Pharmacists and other health care professionals all have their own very strict health Personal Information privacy rules and protection methods.

We also collect information that is not Personal Information such as:

• Information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as generalized data, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

4. How do we collect your information?

We use a number of methods to collect Personal Information:

• Direct interactions with you when you provide it to us, for example, by filling in forms, registering for an account, or corresponding with us by phone, email, or otherwise.
• Third parties or publicly available sources, for example, our business partners.
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. We use “cookies” and other technologies such as pixel tags and web beacons. We use these technologies to better understand User behaviour, analyze trends, administer, personalize and improve the experience of using the Essential Clinic Platform. In particular, Essential Clinic uses the following types of cookies:
  • Our advertisement partners use cookies to track results of ad campaigns (marketing) and re-marketing our service within other websites the user may visit. User can opt out by visiting the advertisement platform’s website (e.g. AdWords’ opt-out instructions) and opting out from there.
  • Our login systems use cookies to remember if the device the user is using is already authenticated or not. Users can opt out by logging out immediately after logging in and performing the task they need to do. They can also disable cookies in their browser via extensions such as EFF Privacy Badger or unselect any visible “Remember Me” type checkboxes.
  • Our chat widget (Drift) uses cookies to retrieve user’s chat history and track the same user over multiple visits (see https://gethelp.drift.com/hc/en-us/articles/360019665133-What-is-the-Drift-Cookie-Security-and-Privacy-Policy-). Users can opt-out by disabling cookies on their browser or using a Chrome extension such as EFF Privacy Badger to selectively disable specific cookies.
  • Our proprietary intake forms and app within our website uses cookies to store the user’s answers to our intake forms so that the answers are remembered and can be restored for the user in case the user leaves the website (for up to 7 days). The cookie is deleted once the user completes the form and submits the Personal Information to our server. User can opt-out by disabling cookies on their browser or using a chrome extension such as EFF Privacy Badger to selectively disable specific cookies.

You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, the Essential Clinic Platform might not function correctly.

Essential Clinic also uses third parties to assist in tracking certain anonymized information of users and visitors to our website the Essential Clinic Platform. In particular, we keep track of device information and browser type, screen resolution, as well as session length, pages visited, interaction events such as clicks and mouse movements, and javascript errors. We use this information on an anonymized basis to gain a better understanding of our customer demographics and preferences in order to improve our products and services. For more information on those third parties, please see our Sub-processors Page.

Users can opt out of Google Analytics by following Google Analytic’s Opt-Out instructions.

5. Purposes of collection and use

The following are the purposes and methods by which we collect and use your Personal Information:

To Administer and Provide Access to the Essential Clinic Platform

We collect and use your Personal Information to present the Essential Clinic Platform and its contents to you, and to register you and personalize your experience while using the Essential Clinic Platform. We confirm your eligibility to use the Essential Clinic Platform for Healthcare Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.

You may choose to enter or upload and store your Personal Information in the Essential Clinic Platform such as your medical records.

We use Personal Information that you enter, or upload, or which is created as part of an interaction with an Authorized Clinician to make it available to you when you access your User Account.

To Process Payment

When you make a payment transaction through the Essential Clinic Platform, the billing and payment Personal Information you submit will be automatically transferred to our third-party payment processors, Spreedly and Stripe. They collect this Personal Information to process the payment and otherwise in accordance with their own privacy policies. We do not collect or store this payment Personal Information.

To Provide Services Generally

For registered Users, we collect and use Personal Information:

1. to provide you with information, products, or services that you request from us or that we may consider of interest to you;
2. to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it; and
3. to carry out our obligations and enforce our rights arising from any contracts with you, or to comply with legal requirements.

Essential Clinic collects and uses Personal Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Personal Information to what is needed for these purposes.

We use your Personal Information to text or email you to notify you about services that you request. For example, we notify you about the status of your consultations and other requests, such as prescription orders. We use Personal Information that you enter to provide you with services that you request us to perform on your behalf, e.g., securely sending your prescription to one of our third-party pharmacy partners (or if requested by you, your chosen pharmacy).

As mentioned, Authorized Clinicians are responsible for their own collection, use, disclosure, retention, destruction and protection of Personal Information. As a result, the following description is an overview only of the use generally made of Personal Information for the purpose of providing services through the Essential Clinic Platform. A particular Authorized Clinician may or may not choose to collect or use Personal Information as described in this Policy in connection with a particular interaction with a User.

To request Healthcare Services, you describe applicable symptoms relevant to your request. We facilitate your disclosure to the Authorized Clinician of that Personal Information, along with age and gender to determine whether your request is eligible. The Essential Clinic Platform presents to the Authorized Clinician the Personal Information you provided in your consultation request, including your name and medical history from your intake forms. Once the Authorized Clinician confirms that your request is eligible, we identify the Authorized Clinician to you.

To Provide Healthcare Services

Authorized Clinicians may collect Personal Information about you when you provide it as part of your intake forms, during a Healthcare Services consultation (e.g., verbally or in texts), by viewing the Personal Information that you have entered or uploaded to the Essential Clinic Platform and/or by creating or compiling Personal Information in the Essential Clinic Platform. Personal Information that is submitted through the Essential Clinic Platform and that will be available to Authorized Clinicians includes: the details that you provide in your consultation request; Personal Information you’ve entered or uploaded to profiles and medical records; Personal Information created during earlier interactions through the Essential Clinic Platform with other Authorized Clinicians; the name, email address, phone number, gender and date of birth, health card number, and province/territory that you provided when you registered, as well as medical history and symptoms (allergies, medications taken, past surgery history, and answers to specific medical questions) in order to get the appropriate treatment, desired prescription.

Authorized Clinicians use Personal Information to provide you with Healthcare Services and/or Informational Services and, as with any clinician, must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Clinicians may create Personal Information such as prescriptions, and other notes about your interaction with them through the Essential Clinic Platform. They may export or print copies of your Personal Information that they collect.

To Provide Informational Services

Authorized Clinicians collect and use Personal Information that you provide in the course of obtaining Informational Services, by viewing the Personal Information that you have entered or uploaded to the Essential Clinic Platform and by creating or compiling Personal Information in the Essential Clinic Platform. The Personal Information that they collect and use includes: the details that you provide in your request for Informational Services and Personal Information that you provided to register to use the Essential Clinic Platform (name, gender, date of birth and place of residence) to confirm your eligibility to receive Informational Services. Authorized Clinicians are bound to comply with privacy legislation applicable to providers of Informational Services.

To Communicate With You

We collect and use Personal Information in the course of communicating with you, including in the following circumstances:

• Medical emergencies associated with requests for Healthcare Services: Should you submit Personal Information about a medical issue which is deemed an emergency by an Authorized Clinician prior to their acceptance of your request for Healthcare Services, Essential Clinic reserves the right to contact you at any time using any of the contact Personal Information you have provided. This contact is strictly for the purpose of informing you that an Authorized Clinician has viewed your anonymized request and has declined the request based on their belief that your symptoms may represent a medical emergency.
• Customer support: If you email, fax, write to us or complete a ‘contact us’ form on the Essential Clinic Platform, we will collect the name and contact Personal Information that you provide to us and will use it to respond to you.

For Business Development and Marketing

We collect and use your Personal Information for the following business development and marketing purposes:

• to measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
• to help us create, develop, operate, deliver, support and improve the Essential Clinic Platform, its content and advertising provided to you through it (Essential Clinic’s and third parties’) unless you have decided not to receive such advertising.
• to improve our Website, products or services, marketing, or customer relationships and experiences. For this purpose, we may calculate active users, daily user engagements and duration of each, Website status and maintenance, version adoption, acquired users, user retention (weeks, percentage of users), audience metrics, country of access and other relevant data;
• to notify you by email or other means about changes to our Website or any products or services we offer or provide through it; and
• from time to time, to send you service announcements, including policy updates and updates to our Terms of Service and software and keep you posted on our latest products and any upcoming events that may be of interest to you or apply to you. You may opt-out of receiving non-essential communications through an unsubscribe link or similar in the communication you receive or by contacting us. For clarity, service announcements including updates to this Policy and Terms of Service and software are not considered non-essential communications.

Other Purposes

Without limiting the foregoing, we may also collect and use Personal Information:

• for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements;
• to allow you to participate in interactive features, social media, or similar features on our Website;
• to create de-identified data and aggregated data and statistics;
• in any other way we may describe when you provide the information; or
• for any other purpose with your consent.

6. Purposes of disclosure

Other than to Authorized Clinicians, emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy, we will not disclose, share, sell or rent your Personal Information with or to any third party (except to the extent we disclose), except for the purposes set out below, with your consent, or to the extent necessary, in our good faith judgment, to: (i) comply with applicable laws or regulations; (ii) respond to a subpoena, order, or similar obligation to produce Personal Information; (iii) establish or exercise Essential Clinic’s legal rights or defend against legal claims; or (iv) investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person.

By your use of the Essential Clinic Platform, you consent to us disclosing your Personal Information for the following purposes and to the following entities/persons:

• For the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others.
• To one or more of the Subprocessors (defined below) for the purposes set out in the table below. To support Essential Clinic in delivering the services and Essential Clinic Platform, Essential Clinic engages third-party service providers as sub-processors (the “Subprocessors”). The table below identifies our Subprocessors, describes where they are located, lists what services they provide to us and identifies the type of Personal Information processed.

For the purpose of engaging the Subprocessors to perform tasks on our behalf, we may need to share Personal Information with them to obtain certain services. Unless we tell you differently, such Subprocessors do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The Subprocessors we currently engage include third party companies and individuals employed by us to facilitate our services, including the provision of database management, payment processing and customer relationship management tools.

Our business needs may change from time to time and Essential Clinic will periodically update this page to provide notice of additions and removals to our list of sub-processors.

7. Links to third party sites

The Essential Clinic Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.

8. Your consent

By your use of the Essential Clinic Platform, you give your authorization to Essential Clinic to collect, use and disclose the Personal Information as described in this Policy, and confirm that you have been made aware of the reasons why the Personal Information is needed and the risks and benefits to you of consenting or refusing to consent.

Without limiting the foregoing, you specifically consent to us sharing your Personal Information with the Subprocessors, including Vouched or other similar third party identity verification provider, with the pharmacists from whom we obtain remedies for our clients, and with any professional providers that may provide you telemedicine services.

You may revoke your consent at any time by following the procedure outlined below.

9. How can you revoke your consent?

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at team@essentialclinic.ca. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

10. Retention

Unless we otherwise give you notice, we will retain your Personal Information on the Essential Clinic Platform on your behalf until such times as you or we terminate your User Account (unless a longer period is required by applicable laws or regulations). On termination, you will have an opportunity to print or make copies of your Personal Information subject to the following. To ensure that Authorized Clinicians may exercise any authority they have to withhold Personal Information they compile in connection with Healthcare Services from patients under the law, you will be required to request any access from Authorized Clinician about your consultation from the Authorized Clinician.

As mentioned above, Essential Clinic is not the custodian of Personal Information held on the Essential Clinic Platform; rather it holds Personal Information on behalf of Users or Authorized Clinicians. Within a reasonable time period following termination of your User Account, once you have been given the opportunity to print or make copies of your Personal Information, we will delete the Personal Information associated with your User Account, except Personal Information that an Authorized Clinician advises us he or she requires in connection with a consultation or Informational Services the Authorized Clinician provided. In such circumstances, Essential Clinic will destroy the Personal Information when the Authorized Clinician has obtained a copy or terminates his/her account with Essential Clinic.

11. Security measures

Essential Clinic takes the security of your Personal Information seriously. We store your Personal Information in electronic format using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Personal Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Essential Clinic Personnel are obligated to protect Personal Information by adhering to our policies, practices and applicable laws.

We only permit our Personnel to access Personal Information to the extent necessary to perform their designated functions. We require them to protect the Personal Information and maintain its confidentiality by complying with our policies, procedures and applicable law.

Essential Clinic processes and stores its data, including Personal Information, on servers located in Canada and the United States. Essential Clinic also transfers data to third-party service providers described on our Sub-Processors webpage. By submitting Personal Information or otherwise using the services, you agree to this transfer, storing or processing of your Personal Information in Canada and the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

We use encryption and other security measures to protect the confidentiality of all our email communications. However, notwithstanding our best efforts, as with any Internet transmission of data, emails can still be subject to hacking or unauthorized access by external actors. Accordingly, we ask Users to exercise caution in how much Personal Information and especially PHI they share with us by email.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Further, should you choose to print out or otherwise replicate Personal Information you have submitted to the Website, we will not be responsible for any consequent dissemination or loss of such replicated Personal Information. our data security measures cannot be extended to physical copies or other representations or replicas of Personal Information created or derived by you, from the Website.

12. Access and correction

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at team@essentialclinic.ca to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable Law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their Personal Information or confidential commercial information.
• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact us at team@essentialclinic.ca.

13. Contact us

If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance Officer. Please include your name and contact Personal Information if you’d like us to respond to you.

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable privacy laws. To discuss our compliance with this Privacy Policy please contact us using the contact information listed above.

14. Changes to this policy

We publish the current version of our Policy at https://www.essentialclinic.ca/privacy-policy. We reserve the right to amend our Policy at any time. Check back often to ensure you are aware of our current practices for collecting, using, disclosing, retaining, destroying and protecting Personal Information

We include the date the Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.