Last Updated: July 20, 2017

By using this site, you agree to be bound by the following Privacy Policy (the “Policy”).

OUR PRIVACY COMMITMENT TO YOU
Town Hall Medicine Inc. doing business as Town Hall Medicine (“THM”, “we”, “us” or “our”) 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, subscribe to use our Content, create an account, or submit information through this 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 and United States privacy legislation. We do this by adhering to the Canadian and United States principles that relate to the collection, use, retention and disclosure of your personal information. Although the Site and its Content are accessible worldwide, the Site and its Content are neither designed nor intended for use outside Canada and the United States. Those who choose to access the Site and its Content from locations outside Canada and the United States do so on their own initiative and at their own risk and are responsible for compliance with all local laws. We reserve the right, at any time and in our sole discretion, to limit the availability and/or use of the Site, its Content, and subscription accounts to any person, geographic area, or jurisdiction. You shall, at all times, comply with all applicable laws and regulations of Canada and the United States, as applicable, and all other applicable governmental entities governing, restricting or otherwise pertaining to the use, transmission, display, exporting or importing of data, products, services and/or technical 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 the Terms of Use and consent to both of their terms, as well as any other terms that are described to you when your personal information is collected. If you do not consent to all of the terms of our Terms of Use and Privacy Policy, you are not authorized to use the Site or the Content, and your sole remedy is to stop using the Site and the Content.

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, including, without limitation, name, username, password, other log-in information, billing information and other contact information. 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.

USE OF PERSONAL INFORMATION
THM will comply with all applicable laws related to the storage and use of personal information. THM will not share or distribute your personal information, except as provided in our Terms of Use , this Privacy Policy or as may be required by law. 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 compliance with our Terms & Conditions of Use, this Privacy Policy and applicable laws 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
THM will only use your personal information as set forth in our Terms of Use and this Privacy Policy, as may be required by law, or as otherwise specifically disclosed to you. We may use and disclose the personal information we collect from our customers, consumers, subscribers and other individuals to manage our relationship with such individuals, to administer accounts, to provide business services and to otherwise carry on our business operations.

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

By using this Site and its Content, you hereby agree to the terms of this Privacy Policy and expressly consent to all collection, use, and disclosure of personal information set forth in this Privacy Policy and the Terms & Conditions of Use.

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. While you can access this Site without telling us who you are and without revealing any of your personal information, there are times when we may need certain personal information from you, such as when you register for an Account or access or use the Content.

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 verify your identity;
• 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;
• Make it easier for you to log back into the use the Site or its 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 help us understand who is using the Site and its Content;
• To assess service levels, monitor traffic patterns and gauge popularity of different service options;
• To carry out our marketing activities, provided we have your consent as required under applicable law;
• To enforce this Policy or our Terms 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 identify and protect against fraudulent transactions;
• 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.

By registering for an Account, you herby agree to receive communications from us related to 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.

Disclosure
THM is not in the business of sharing or selling your personal information. We consider this information to be a vital part of our relationship with you. However, in addition to specific requests by you, set forth below are examples of when we may share some or all of your personal information with third parties without further notice to you (and you hereby expressly authorize THM to share your personal information under such limited circumstances, provided we do so in a manner consistent with this Privacy Policy and applicable laws):

Affiliated Companies and Partners
We may disclose personal information to our subsidiaries and other affiliated companies for research and marketing purposes, which may include targeted advertising. We may also share personal information with the University of Toronto on an aggregate, anonymized basis for research and analysis purposes.

• Agents, Consultants and Service Providers
  THM, like many businesses, engages third parties to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, transmitting information, hosting data and storing information. When we engage a third party to perform a function of this nature, we only provide them with the information that they need to perform their specific function and subject to terms of confidentiality.
• Authorized Persons
  We may disclose your personal information to individuals we reasonably believe are authorized by you to receive such information.
• Business Transfers
  From time to time, we may buy, sell or reorganize businesses or assets. In the event of an acquisition, sale, merger, reorganization, dissolution or similar event, personal information may be part of the transferred assets.
• Legal Requirements
  THM may disclose your personal information if required to do so by law or in circumstances to protect the personal safety of users of the Site and its Content or the public; or in order to (i) comply with a legal obligation; (ii) enforce, protect or defend the rights or property of THM; (iii) act in urgency against legal liability; or (iv) protect the good faith belief that such action is necessary.

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.

Personal Information of Minors
We do not knowingly provide our service to, and will not knowingly solicit or collect the personal information from a minor (i.e., anyone aged 18 or below). We also do not verify the age of any of our users. By using the Site or its Content, you represent and warrant to THM that you are at least 18. If we learn a child under the age of 13 has submitted information to us through the Site or its Content, we will delete such information promptly after we discover such submission. THM encourages parents to take an active role in their children’s use of the Internet, and to inform their children of the potential dangers of providing information about themselves while online.

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, internet browser information, and IP address. 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 uses “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 IN A FOREIGN JURISDICTION
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
The security of your personal information is important to us. We will strive to prevent unauthorized access to your personal information by taking commercially reasonable administrative, technical and physical measures to safeguard the information you provide to us, 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.

In the event that an unauthorized third party compromises our security measures or the security measures of a third party (such as your Internet service provider), we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disclose your information. Also, administrative agencies or courts of competent jurisdiction may order the disclosure of the information we collect. We cannot guarantee, and you should not expect, the information you provide to us will always remain private. Please keep this in mind when disclosing any personal information through the Site.

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 challenge the accuracy and completeness of the personal information handled by us and have such information amended. You may also request access to your personal information. For these purposes, please contact THM’s designated Privacy Officer at the contact information provided 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.

CAN-SPAM ACT COMPLIANCE
We are committed to being compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM Act”). All emails you receive from THM are intended to fully comply with the CAN-SPAM Act.

CHANGES TO OUR PRIVACY POLICY
We may amend this Privacy Policy at any time and in our sole discretion. You should review this Privacy Policy for amendments each time you use the Site and its Content. For your convenience, we include on this Privacy Policy the last date this Privacy Policy was updated. If our Privacy Policy is amended, the amended Privacy Policy will take effect immediately for all users of the Site and its Content. Your continued use of the Site following an amendment will evidence your acceptance of the amended Privacy Policy.

INQUIRIES, REQUESTS OR COMPLAINTS
Numerous individuals within our organization are responsible for the day-to-day collection and processing of personal information. However, 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]

SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS
Individuals who are residents of California and have provided their personally identifiable information to us may request information regarding our disclosures, if any, of their personally identifiable information to third parties for direct marketing purposes. Such requests must be submitted to our Privacy Officer in writing at the contact information provided above.

Such requests must include the reference Request for California Privacy Information in the subject line and in the body of the message and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.