Last Updated:  July 20, 2017

This Site is provided by Town Hall Medicine Inc, operating as Town Hall Medicine (“THM”, “we”, “us” or “our”), which is majority owned and controlled by Genuine Health Inc. (“Genuine Health”), and is provided in conjunction with the University of Toronto (“U of T”).  By using this site, you agree to be bound by the following Privacy Policy (the “Policy”).

OUR PRIVACY COMMITMENT TO YOU
THM is committed to protecting the privacy of personal information of identifiable individuals who visit the website located at www.townhallmedicine.com (the “Site”) or use the videos, features, information and articles (collectively or individually, the “Content”) offered on the Site. We have made a commitment to ensuring that personal information in our custody remains secure and is not used in a manner that is inconsistent with this Policy and with Canadian privacy legislation. We do this by adhering to the principles that relate to the collection, use, retention and disclosure of your personal information.

Amendments to this Policy will be posted to the Site and will be effective when posted. Your continued use of the Site or the Content following the posting of any amendment to this Policy shall constitute your acceptance of such amendment.

By providing us with your personal information and using the Site and/or the Content, you accept this Policy and consent to its terms, as well as any other terms that are described to you when your personal information is collected.  If you do not consent, please do not use the Site or Content or otherwise provide your personal information to us.

WHAT IS PERSONAL INFORMATION?
The use of the term “personal information” means information about an identifiable individual; it is information by which the identity of an individual can be deduced. However, personal information does not include the name, position or title, business address or business telephone number of an employee of an organization. It also excludes publicly-available information, such as information listed in a public telephone directory.

ACCOUNTABILITY
THM is accountable for all personal information in its control. This includes information under the direct control of THM, as well as personal information that THM may transfer to its affiliates or to third party service providers for processing, storage or other purposes that facilitate THM’s business operations or that have been consented to by the individuals to whom the information relates. We will use contractual or other measures to require third parties that process information on our behalf to maintain a level of privacy protection comparable to our own practices. To ensure accountability for all personal information collected, used and disclosed by THM, we have developed appropriate policies and practices and have trained those individuals within our organization that deal with personal information.

OUR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
Our collection, use and disclosure of personal information will be with your consent and in accordance with this Policy and applicable law.  Individuals may withdraw consent at any time by contacting our Privacy Officer at the contact information listed below.

We will use the personal information we collect from users or subscribers to the Site to manage our relationship with such individuals, to administer accounts, to provide business services and to otherwise carry on our business operations.  This may require us to disclose your personal information to third party service providers that administer the Site, provided their use of such personal information is consistent with the purpose for which we obtained your consent.

If we choose to use personal information already in our custody for a purpose that was not identified at the time we initially collected the information, unless the new purpose is required or authorized by law, we will seek the consent of the affected individuals before using this information for these new purposes.

We will not refuse to provide a service to an individual if they choose not to provide us with their personal information, unless their failure to provide the information makes us unable to provide the service.

SUBSCRIBERS
In order to access certain Content on the Site, you must create a subscription user account (“Account”) on the Site.  In order to create an Account, we ask for personal information that will be used to activate your Account, provide the subscription Content to you, communicate with you about the status of your Account, and for other purposes set out in this Policy. We may use your personal information or Account information for the following purposes:

• to provide the Content to you and to improve the quality of the Site;
• to provide information to you so that you may use the Site more effectively;
• to create, manage and control your Account information, and to verify access rights to Content;
• to bill your Account;
• to communicate with you for the purpose of informing you of changes or additions to the Site, or of the availability of any service we provide;
• to assess service levels, monitor traffic patterns and gauge popularity of different service options;
• to carry out targeted advertising and other marketing activities, provided we have your consent as required under applicable law;
• to enforce this Policy or our Terms & Conditions of Use
• to respond to claims of any violation of our rights or those of any third parties;
• to respond to your requests for customer service;
• to protect the rights, property or personal safety of you, us, our users and the public;
• and as required or authorized by law.

As set out above, we may share your personal information with third party service providers in order to administer the Site and your Account.  We may also share your personal information with Genuine Health for research and marketing purposes, which may include targeted advertising, and with U of T on an aggregate, anonymized basis for research and analysis purposes.

Provided we have your consent under applicable law for such communications, THM and/or Genuine Health may occasionally communicate with you regarding our products, services, news and events. You have the option to not receive this information. We provide an opt-out function within all email communications of this nature, or will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you.

Our use of your personal information will be limited to the purposes for which it was collected, and disposed of in a secure manner when it is no longer needed. The specific details will be disclosed to you at the time of the collection and your consent to use the information collected will be obtained at that time.

Other than described above, we do not share the individual information we gather on our Site with third parties, except as may be permitted and required by law.

FINANCIAL INFORMATION
If you choose to subscribe to our service, you may be asked to provide your payment information, such as a credit card number and/or other related information that may be required from you to complete your purchase (“Financial Information”). We do not collect, store, process or maintain your Financial Information, but merely provide a gateway to our third party payment processor.  All Financial Information is provided by you directly to our third party payment processor who confirms your payment information, which then allows us to complete the transaction.  Your Financial Information will be governed by the privacy policy of our third party payment process.  Please refer to that privacy policy for further information.

TECHNICAL DATA
As with most Internet websites, the Site collects a variety of technical data, including your IP address (a unique number that identifies your access account on the Internet), domain, and World Wide Web browser information. We do not log the specific identity of visitors. Technical data is used only to create broad demographic summaries of Site usage and activity (such as average time spent and pages viewed) to assist us in providing useful content that is tailored to be of most value to our users. For example, we use the information to: give the developers of the Site information that is useful in determining appropriate new features, content, and services; and to provide advertisers, partners and clients with aggregate – not individual – information about our user base.

Our Site may use “cookies”. This technology allows users to move more quickly through our Site. Cookies are small text files that a website can use to recognize repeat users and facilitate the user’s ongoing access to and use of the website. For example, a cookie may store your password, or note your particular areas of interest. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site. We do not record or store any information about your movements on the Internet outside of the Site. You can choose to decline our cookies (e.g., by setting your browser to reject cookies), but if you do, some parts of the Site may not operate properly.

PROCESSING AND STORAGE OF PERSONAL INFORMATION
Your personal information may be transferred to, processed and/or stored in a foreign jurisdiction outside of the jurisdiction in which it was originally collected.  As a result, your personal information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction.

LINKS TO OTHER WEBSITES
The Site may contain links to other websites.  We are not responsible for the privacy practices or the content of such websites. This Policy does not extend to the collection of personal information by third party sites and we do not assume any responsibility for the privacy practices, policies or actions of such third parties. In visiting any third party sites, whether linked to the Site or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party site or any content in such site.  We encourage you to read the privacy policy of linked sites before using those sites or disclosing any personal information to third parties, as their privacy policies and practices may differ from our policies and practices.

SECURITY
We will strive to prevent unauthorized access to your personal information, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. We will continue to enhance security procedures as new technologies and procedures become available.

We strongly recommend that you do not disclose your password to anyone. If you forget your password, we will ask you for your user ID and send you an email containing a link that will allow you to reset your password.

Please remember that you control what personal information you provide while using the Site. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of the Site. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through the Site. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the Site, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the Site. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party. You release us from any and all liability in connection with the use of such personal information or other information of others.

ACCESS AND CORRECTION OF PERSONAL INFORMATION
We keep personal information as accurate, complete, current and relevant as necessary for the identified purposes.  However, we rely on you to update this information as THM does not routinely update personal information unless it is necessary to fulfill the purposes for which the information is collected.  You may review and correct your personal information by contacting our designated Privacy Officer at the contact information below.  In certain circumstances, access may be denied. If we deny an access request, we will advise you in writing of the reason for the refusal. You may then challenge our decision.

INQUIRIES, REQUESTS OR COMPLAINTS
THM has a designated Privacy Officer who is ultimately accountable for the handling of all personal information under our control and for ensuring that the principles set out in this Policy are being complied with. Any inquiries, requests or complaints with regard to the way that THM handles or manages personal information should be directed to our Privacy Officer who can be reached as follows:

Town Hall Medicine Privacy Officer
317 Adelaide Street West, Suite 501
Toronto, Ontario M5V 1P9
Tel:  647-255-3422
Fax:  416-977-4184
Email:  [email protected]