CardioRisk Calculator ™

PRIVACY POLICY

Last Updated: December 19, 2018

This online and mobile privacy policy ("Privacy Policy") explains how information is collected, used and disclosed by Cardiovascular Imaging Core Laboratory and its subsidiaries, if any (collectively, "CIRCL", "we", "us", or "our"), and applies to information we collect when you use or access: (i) any software, application, other front-end software, or API provided by CIRCL for online content storage, sharing and processing of files, materials, data, text, audio, video, images or other content (for greater certainty, excluding third party software that may interact with the Service, as defined below) (collectively, "Content"); (ii) the CIRCL website at http://www.circl.ubc.ca and such other locations as made available from time to time (the "Website"); (iii) any "app" or other front-end software provided by us (for greater certainty, excluding third party software that may interact with the Website or the Service, as defined below) that interacts or interfaces with the Website (the "Software"), and (iv) our software made available through the Website and/or the Software (collectively, the "Service").

Introduction. We respect the privacy rights of users and recognize the importance of protecting information collected about you. We have created this Privacy Policy to explain our practices for the collection, use and disclosure of your personal information. We have appointed a Privacy Officer who is responsible for our compliance with this Privacy Policy. You may contact our Privacy Officer at the contact information listed below.

Changes to This Privacy Policy. We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Last Updated" date at the top of this Privacy Policy and, in some cases, we may (but are not required to) provide you with additional notice (such as adding a statement to our Website or sending you an email notification). We encourage you to review our Privacy Policy whenever you access the Service to stay informed about our information practices and the ways you can help protect your privacy. Your use of any of the Service after the posting of such changes shall constitute your consent to such changes.

Information Collection. As indicated below, we collect two types of information through our Service: personal information and non-personal information. The types of information we collect about you will depend on the nature of your interaction with us or the Service.

Information You Provide To Us. We collect information you provide directly to us. For example, we collect information when you register with CIRCL for an account, create or modify your profile and online account, access and use the Service (including but not limited to when you upload, download, collaborate on or share files or other information), participate in any interactive features of the Service, request customer support, communicate with us via third-party social media sites or otherwise communicate with us.

The types of information we may collect directly from you may include your "personal information", which for the purposes of this Privacy Policy, means information about an identifiable individual, including, for example, an individual's contact information such as name, home address, telephone number, email address, mailing address, billing information, unique identifiers such as your user name, account information, password, user content generated by you, such as audio, video, text and images provided by you on the Website, which may contain personal information. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee's name, position or title, business telephone number, or business address.

On the other hand, "non-personal information" is any type of information other than personal information, and is excluded from this Policy. For example, non-personal information would include business information, or information that enables an individual to be contacted at a place of business, for example an employee's name, position or title, business telephone number, or business address. Non-personal information also includes information that is anonymous or not about an identifiable information, such as web browsing information (such as the domain used to access the Website, or the type and version of device, browser or operating system being used to access the Service), or aggregate information that anonymizes the underlying data (like the number of visitors, what pages users visit, average time spent on the Website or on various parts of the Service). We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws.

This Privacy Policy, however, only covers our collection, use and disclosure of personal information. We will only collect, use or disclose personal information in accordance with this Privacy Policy, or in accordance with laws applicable to the collection, use, and disclosure of your personal information by us ("Applicable Privacy Laws"). We may also store the files or other information that you upload or provide to the Service ("Content") in order to be able to provide you with the features and functionality of the Service.

Information We Collect Automatically When You Use the Service. When you access or use the Service, we may automatically collect information about you, including:

• Usage Information: We monitor user activity in connection with the Service and may collect information about the applications and features you use, the Content you access and any actions taken in connection with the access and use of your Content in the Service.
• Log Information: We log information about you when you access and use the Service including your Internet Protocol ("IP") address, access times, browser type and language, Internet Service Provider ("ISP"), the web pages or sections of the web pages that you visit, the Content you use or download from the Website and the URL of the web page you visited before navigating to the Service.
• Cookies: We use various technologies to collect information, which may include saving cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Service and your experience, customize your experience and preferences, allow you to access and use the Service without re-entering your user account ID and/or password, understand which areas and features of the Service are most popular and count visits. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images (also called "gifs") that may be used in the Service or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website. For more information about cookies and how to disable them, please see "Your Choices" below. The use of cookies by third parties you may sign-in from into the Service and/or third party applications, is not covered by our Privacy Policy. We do not have access or control over such cookies.

Information Obtained from Third Parties. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us and in accordance with this Policy and such policy under which that information was collected.

Use of Personal Information. We may use the personal information, in combination with the non-personal information, we collect about you for a variety of purposes, including to:

• Provide, operate, maintain and improve the Service;
• Enable you to access and use the Service, including uploading, downloading, collaborating on and sharing Content and sending emails on your behalf;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;
• Respond to your comments, questions, and requests and provide customer service and support;
• Communicate with you about services, features, surveys, newsletters and provide other news or information about CIRCL and our partners, if any;
• Monitor and analyze trends, usage, and activities in connection with the Service and for marketing or advertising purposes;
• Investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;
• Personalize and improve the Service, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Service;
• Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
• Enable you to communicate, collaborate, and share files with users you designate;
• Share an invite to use the services with third parties as requested by you; and
• For other purposes about which we notify you.

Your Consent to CIRCL. We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Laws. Accordingly, we may disclose any and all information we, in good faith, believe the Applicable Privacy Laws require or if disclosure is necessary to protect our legal rights. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Privacy Policy and as may be further identified at the time of collection.

Express Consent. Sometimes you will be asked to provide your express consent to our collection, use or disclosure of personal information - for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with Canada's anti-spam laws.

Implied Consent. Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you - for example, when you provide us with your personal information through a comment, you provide us with implied consent to use that personal information in order to feature the comment on the Website.

Withdrawing Your Consent. You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure of your personal information. We will accommodate your request subject to legal and contractual restrictions. The most common way of indicating this withdrawal of consent is (i) by changing your privacy preferences to the extent such functionality is made available through the Service, or (ii) stopping use of the Service. In other situations, you may be able to opt out of the use of your personal information. For example, if you have "opted in" or subscribed to one of our mailing lists, we will always provide you the opportunity to "opt out" or unsubscribe. You may also choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the Service, or information that you have requested. For example, we may require your email address in order to send you newsletters, articles, interviews, alerts, announcements, or online content.

Sharing and Disclosure of Information. We will not share personal information about you or any Content with any third parties except as described in this Privacy Policy or in connection with the Service. For example, we may share personal information about you including as follows:

• Vendors, Consultants and Other Service Providers: We may share your information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing, provide customer support, etc.
• Corporate Account: If you are an individual CIRCL registered user and the domain of the primary email address associated with your CIRCL account is owned by your employer and was assigned to you as an employee of that organization, and such organization wishes to establish a CIRCL corporate account, then certain information concerning past use of your individual account may become accessible to that organization's administrator including your email address.
• For Collaboration: We may share your information, including when you choose to use collaboration features in the Service that by their nature support sharing with third parties who you choose. Your name, email address, information from your profile and online account, and any Content you choose to share will be shared with such third parties, and such third parties may communicate with you (such as by posting comments or emailing you) in connection with your use of the collaboration features of the Service.
• Third Party Applications: CIRCL provides you with opportunities to connect with third-party applications or services. If you choose to use any such third-party applications or services, we may share information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary. This Privacy Policy does not apply to your use of such third-party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.
• Compliance with Laws: We may disclose your information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and Terms of Service, (c) to protect the security or integrity of the Service, (d) to protect CIRCL, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Aggregated or Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you.

Security. While no service is completely secure, CIRCL takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we encrypt your Content when it is stored in our data centers. In addition, sensitive information such as credit card number and password that we request from you on the Service is protected with encryption and anonymization during transmission over the Internet. CIRCL also takes efforts to remove personal information from electronic files through a third party. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the Internet. If you have any questions about security on our Website, you can contact us at circl.mail@ubc.ca. CIRCL expressly disclaims any liability for inadequate or incomplete de-identification completed by its third party contractor.

The servers on which personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

Your Choices

Requests for Access to and Correction of Personal Information.

Applicable Privacy Laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:

• identification of personal information under our custody or control;
• information about how personal information under our control may be or has been used by us; and
• the names of any individuals and organizations to which the individual's personal information has been disclosed.

We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to. In certain exceptional circumstances, we may not be able to provide access to certain personal information that we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

Removal of Your Information. We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.

Account Information & Retention. You may update, correct or delete information about you at any time by logging into your online account and modifying your information or by emailing us at circl.mail@ubc.ca. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. If you wish to deactivate your account, please email us at circl.mail@ubc.ca, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days. To request removal of your personal information from our blog or testimonials, contact us at the email address listed above. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements.

Promotional and Newsletter Communications. You may opt out of receiving promotional and newsletter emails from CIRCL by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing circl.mail@ubc.ca with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Service or those about your online account or our ongoing business relations.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the Service.

Testimonials. We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.

Links to Third Party Websites. We may place links on the Service. When you click on a link to a third party website from our website, your activity and use on the linked website is governed by that website's policies, not by those of CIRCL. We encourage you to visit their websites and review their privacy and user policies.

Our Policy Toward Children. The Service is not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us at circl.mail@ubc.ca. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.

Contacting Us. You can direct any questions or concerns regarding our compliance with this Privacy Policy to our Privacy Officer by writing or emailing at:

By phone: 604-875-5477
By email: circl.mail@ubc.ca
By regular mail: Rm 489 - 828 W 10th Ave, Vancouver BC, V5Z 1M9, Canada

If you are not satisfied with our Privacy Officer's response to their question or concern you may be able to make a complaint under Applicable Privacy Laws. Our Privacy Officer can provide you with the contact information to make such a complaint.

- End of Privacy Policy. -