Privacy Policy

Complete Concussion Management Website and Course Portal Privacy Policy

Complete Concussion Management Inc. (CCMI, our, us or we) operates the website, www.CompleteConcussions.com, (the “Website”) and related services and applications (collectively the “Services”). This Privacy Policy describes how we may collect, use and disclose personal information in relation to the Services, which you consent to by accessing the Services. “Personal Information” means information about an identified or identifiable individual.

This Privacy Policy may be supplemented or modified by consents you provide to us, and by agreements you enter into with us from time to time. To learn more about how we and third parties may process personal information in order to provide you with the Services, and to opt out of such uses, please read below.

Background

CCMI operates a website (CompleteConcussions.com) which is used to provide information and education on concussion management to both healthcare providers and the general public for the purposes of education as well as the marketing of CCMI’s clinical and educational services.  This website also links to a course website (Courses.CompleteConcussions.com) where CCMI hosts educational courses for healthcare professionals as well as the general public on concussion injuries.

This privacy policy covers the following elements of CCMI’s operation:

  • The CCMI website: CompleteConcussions.com
  • The CCMI online course portal: Courses.CompleteConcussions.com

For information about how we collect, use and disclose personal information in connection with the CCMI Concussion Management Program, please see our CCMI Concussion Management Program Privacy Notice https://network.completeconcussions.com/register/personal.

Our collection, use and disclosure of personal information

In most cases, we collect personal information (e.g., name, email address and phone number) directly from you when you purchase, register for or interact with us for our Services.  For this purpose “Services” indicates the submission and processing of a request for a concussion assessment or baseline test at one of our partnered clinic facilities, request to become a recognized CCMI clinic, registration to take part in our online training programs, or to sign up for one of our newsletters. In these cases, you will know what personal information we collect from you because you will have actively submitted it to us.

In some cases, it may be optional for you to create an account, or consent to the collection, use or disclosure of your personal information, in order to access our Services across various platforms. We will typically identify to you the purposes for which we may collect, use and disclose your personal information at the time that we collect such information. In general terms, such purposes include:

  • To deliver Services to you which you have requested or signed up for;
  • To establish and manage your subscriptions and accounts with us;
  • To respond to your requests, questions and inquiries;
  • To advise you of information, products and services which may be of interest to you;
  • To enforce and administer the terms of use of the Websites and Services; and
  • To meet our legal obligations and as permitted by law.

We may share information with related organizations and third-party service providers with whom we have entered into confidentiality agreements for the purpose of providing the Services and as described in this Privacy Policy (including the provision of products and services offered in conjunction with the Services). Where such parties are located outside of Canada, your personal information will be subject to the laws of that jurisdiction, including laws related to the disclosure of personal information to the authorities in that jurisdiction.

Below we describe in more detail how we collect, use and disclose information for certain Services.

Automatically Collected Information

Some information concerning your use of the Services will be collected automatically as you use them.  These are:

  • Computer IP address
  • Geographical location when you enable location tracking on your app; and
  • Information from cookies

We collect and use this information to generate aggregate/non-identifiable information in order to further develop, provide and manage the Services and for research purposes.

Subscriptions

When you sign up for a Subscription available through our Services (e.g., CCMI newsletters, courses, webinars, etc.), you are required to provide your name and email address. This information is used to deliver information to your email address, contact you and administer your Subscription, and enable you to log in to manage your subscription.

We may also ask for additional, optional, information, which is not required to participate in the Subscription service, for example, address and profession/occupation. We collect and use this information in order to gain a better understanding of our subscribers to improve our Services, and to generate aggregate/non-identifiable demographic information. To opt out of such use, please do not provide the optional information, or you may contact our Privacy Officer at any time as indicated below.

Website forms

When you submit an inquiry using our online forms, we request your name and email address, along with the comment or inquiry for the purpose of acting on the information and responding to you. This information may be shared with persons outside of Complete Concussion Management Inc. as required to respond.

How CCMI Responds to Do Not Track signals

CCMI does not track its customers over time and across third party websites and therefore does not respond to Do Not Track (DNT) signals.

Cookies

Cookies are small text files transferred to a website user’s hard drive by a web server. Complete Concussion Management Inc. uses cookies on the Websites: (a) to remember your searched locations for quick future reference when you re-visit the Websites; and (b) to save your login information for subscription. No additional information is collected in providing these features.

You have the option to set your browser to either accept cookies, to notify you before accepting cookies, or to refuse cookies altogether. If you refuse cookies please note that certain Website functionality, such as remembering your preferences, may not be available.  For more information, please see our Cookie Policy.

Retaining and safeguarding personal information

We will take steps to retain personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. For our continuing education courses, we will take steps to retain personal information for a period of 5 years (minimum) and as long as necessary afterwards to fulfill the purpose for which it was collected and as permitted or required by law.  We have implemented physical, organizational, contractual and technological measures designed to help protect your personal information from loss or theft, and unauthorized access, disclosure, copying, use or modification. However, complete confidentiality and security is not possible or guaranteed. For example, internet use and communication is subject to potential interception, loss and alteration. You acknowledge and agree that Complete Concussion Management Inc., its affiliates and related companies shall not be responsible for any damages you may suffer as a result of the transmission of confidential or sensitive information in relation to the Services.

Where we store your personal information

The data that we collect from you is stored in Canada. However, non-identifiable information that we share with third parties may be stored in a location outside of Canada. By submitting your personal data, allowing us to collect your personal data or using the Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

Links to other Websites and services

The Services may contain links to other websites and services, or be available only in connection with certain third parties and their websites, apps or services (e.g. social media providers). Complete Concussion Management Inc. is not responsible for the content or privacy practices of such third parties, or the information disclosed to them, and encourages you to review the privacy policies of such websites, apps and services.

Questions, complaints and requesting access to personal information

If you have any questions or complaints about privacy, or to request access or correction to your personal information, please submit a written request to us by mail or email at:

Attention: Privacy Officer
Complete Concussion Management Inc.
2655 Bristol Circle, Oakville, ON, Canada, L6H 7W1
Email: privacy@completeconcussions.com

Please note that if your request concerns your personal health information, we may refer you to your Primary Clinic.

Updates

Complete Concussion Management Inc. may amend this Privacy Policy at any time. Please check back often for any changes. By continuing to use the Services, you accept all updates to this Privacy Policy. This version was updated on August 19, 2018.

Supplemental GDPR Privacy Statement

European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR“) requires us to provide certain information about our data processing practices to data subjects in the European Economic Area (“EEA“). If you are accessing our online services from a member state of the EEA, this European Online Privacy Policy applies to you.

Complete Concussion Management Inc. (collectively “we”, “us”, “our”) is committed to protecting and respecting the privacy of our users and safeguarding personal data they provide to us in the course of accessing and using the services we provide.

If you are accessing our online services from a member state of the EEA, this European Online Privacy Policy applies to our collection and processing of personal data via any websites or mobile apps that we operate and which link to this Privacy Policy (our “Services”).

For the purposes of the EU GDPR, the Controller is Complete Concussion Management Inc. If you have any questions about this European Online Privacy Policy and/or the processing of your personal data, you can reach our privacy officer at:

Attn.  Data Protection Officer
Complete Concussion Management Inc.
2655 Bristol Circle
Oakville, Ontario
Canada, L6H 7W1
privacy@completeconcussions.com

Personal Data We May Collect & Why We Need It

We collect the following personal data for the following purposes:

What is Collected and When     Why We Need the Information
  1. Information you provide to us by filling out forms on CompleteConcussions.com. This includes:
  • Your name;
  • E-mail address;
  • A password you create;
  • Personal information you provide
  • Any information that you include in your form
In order to:

  • Create a login on the website and apps;
  • To request Services from one of our Recognized clinics such concussion baseline testing, assessment, and/or treatment;
  • To sign up for one of our newsletters; and
  • To register for a course, as a clinic, or to enter in to a contractual agreement as a partnered CCMI clinic or entity

We may use your personal data in the following ways:

  • To deliver our Services to you and allow you to participate in the interactive features of our Services, when you choose to do so;
  • To provide information to your healthcare provider so that they may contact you to set up an appointment;
  • To establish and manage your subscriptions/accounts with you;
  • To ensure that content from our Services is presented in the most effective manner for you and for your computer and/or mobile device;
  • To enforce our Services’ Terms of Use, to the extent that your personal data is required to determine whether the Terms of Use have been violated;
  • To administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • With your consent, to make suggestions and recommendations to you about goods or services that may interest you;
  • To meet our legal obligations.

You do not have to provide any personal data to us. Use of our Services is purely voluntary. You maintain control over the personal information you have provided to us. Users who have created an account with us can change their permissions at any time by contacting privacy@completeconcussions.com.

Automatically Collected Information

Each time you visit the website(s) or use the app, we automatically collect the following information:

(i) Technical information including: the Internet protocol (IP) address used to connect your computer and/or mobile device to the Internet; your username if you have created an account with us;

(ii) Information about your visit: services or pages you viewed; length of visits on certain pages; and methods used to browse away from the page

We do not use automated decision-making, including profiling, as referred to in Article 22(1) of the EU GDPR; that is, in a way that produces legal effects concerning you or significantly affects you.

Legal Basis of Processing

The legal basis for our processing of your personal data in connection with our Services is Article 6(1)(a) of the EU GDPR, which allows processing of personal data once you provide us with your consent. When you first sign up for an account on our website we request consent for the collection of your personal data in order to provide you with the Services and satisfy our obligations with respect to the other purposes listed in this Policy.  You also have the right to withdraw consent at any time for the collection or storage of your data provided that CCMI does not need to process your personal data for legitimate reasons, such as to perform a contract or to comply with its legal obligations.  These are dealt with on a case by case basis.

Disclosure of Your Personal Data

We may disclose your personal data in the following circumstances, as required or permitted by applicable law:

Who Is It Given To?   Why?
  1. To companies we may buy or who may buy us.
  2. To other parties to comply with our legal requirements
  • We may disclose your personal data to a prospective or actual buyer of us, or a prospective or actual seller of their company to us.
  • In order to comply with any legal obligation, and in order to enforce or apply our terms of use and other agreements;
  • To protect the rights, property, or safety of Complete Concussion Management Inc., our customers, or others

Our third-party business partners and service providers need to receive and process your information in order to help us provide you with our Services. Any transfers of your personal data to these entities is based on the European Commission’s decision in 2001 that Canada provides adequate protection of personal data or in compliance with the EU-U.S. Privacy Shield.

We also disclose aggregated de-identified data of our users to third parties:

Who Is It Given To?   Why?
  1. Google
  2. Facebook
  • For marketing analytics
  • For remarketing certain products and services through pixels

This data does not constitute personal data because it cannot reasonably be used to identify you.

Links and Other Websites

Our Services may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Some of our Services allow users to interface with other websites or services, including social media sites such as Facebook and Twitter.  You will remain logged in to such websites and services until you log off those websites and services and you agree to those other websites’ and services’ terms of use and privacy policies.

CCMI does not process or store payment information.  This is done through Stripe.  Please check with their policy prior to submitting any personal data.

Safeguarding Your Personal Data

We use a variety of technological, physical and organisational protections and procedures to help protect your personal data from unauthorised access, use, or disclosure, such as encryption, passwords, and physical security measures.  While we strive to protect your personal data, we cannot ensure or warrant that the personal data or private communications you transmit to us will always remain private.  The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to proactively prevent unauthorised access.

Your Rights to Your Personal Data

The EU GDPR provides you with a right to request access to the personal data we have collected from you, a right to request rectification of the data or that the data be erased, and a right to request that we restrict the processing of the personal data.

If you have created an account with us, consented to direct marketing emails or other data processing, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.  You have the right to lodge a complaint with a supervisory authority.

You also have the right to data portability. You have the right to receive your personal data which has been provided to CCMI and/or our partnered clinic facilities and have the ability to transmit those data to another controller.

You can exercise any of these rights by contacting us at privacy@completeconcussions.com.

Changes to This European Online Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.  This Privacy Policy was last reviewed on Aug 19, 2018.

Additional Privacy Documentation

CCMI HINP Privacy Policy
Cookie Policy

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