AlphaNet Canada
Privacy Policy
Last updated: April 8, 2019

AlphaNet Canada (“we” or “us”) understand that individuals affected by alpha1–antitrypsin deficiency are concerned about the privacy of information. Therefore, we have established policies and procedures concerning the collection, use and security of the personal information we collect, including the contact and medical information of those we serve. Our Privacy Policy is designed to help us preserve our firm commitment to the privacy of the personal information we collect while maintaining strict security standards.

By providing your information, you agree to your personal information being processed in accordance with this Privacy Policy, as amended from time to time. In doing so, you also agree to our use of cloud service providers (“CSPs”) to help us provide services to you. This may include your personal information being transferred to the United States, as described in more detail in the “transfers and disclosures” section below.

Information collected through our Website
We collect some information which is not attributable to an identifiable individual. For example, when you visit our website, our web server automatically recognizes only your computer’s domain name, but not your e-mail address or any other information that identifies you personally. This renders your visit virtually anonymous, unless you log in to one of the controlled-access areas of our site or otherwise volunteer other personal information. We may also collect anonymous aggregate information on what pages you access or visit.

The aggregate information we collect is used for many different purposes in order to serve you better. Among these purposes are to improve the content of our website, provide services such as technical support, to customize the content and/or layout of our website for each individual visitor, and to notify consumers about updates to our website.

Collecting Information
From time to time we may ask you to provide your personal information, including when you visit our website, register, or engage with us for promotional purposes. We only collect your personal information with your consent. For example, we may collect the following personal information about you: your name, address, telephone number, email address, doctor’s name and contact information, augmentation therapy dosage, necessary medical supplies, or augmentation therapy shipping records.

We use personal information for the purposes stated or implied at the time of collection, including to confirm identity, provide services, complete transactions that you initiate, servicing your augmentation therapy supply, maintaining quality assurance, respond to your inquiries, market our services to you (as well as those of our affiliates and third parties), to meet the legal and regulatory requirements applicable to us, and to improve our business. We may otherwise use your personal information where permissible by law, for example to respond to an emergency, or in the course of an investigation into illegal behavior.

Anti-spam
You have choices when it comes to learning about new services from AlphaNet Canada. Where applicable, we will seek your express consent to send you information, including by way of commercial electronic messages. This consent is sought by AlphaNet Canada at 10 Four Seasons Place, 10th Floor, Etobicoke, Ontario, Canada, M9B 6H7. You can unsubscribe at any time by following the instructions in the commercial electronic message, by contacting us at info@alphanetcanada.ca or by contacting your Coordinator directly.

Please be aware that, even if you have opted out of receiving marketing communications from us, we may still contact you for other purposes. For example, we may contact you to provide newsletters or other communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

Transfers and disclosures of personal information
AlphaNet Canada will not disclose personal information to any external organization without consent, unless we are required to do so by law. Your personal information may be disclosed with consent to Innomar Strategies, Inc. to the extent necessary to maintain your augmentation therapy supply and provide you with quality health management services. Augmentation therapy suppliers may receive only aggregated data from AlphaNet Canada, so that individual records remain confidential. AlphaNet Canada does not disclose demographic or medical information to Alpha-1 Canada. We may disclose your personal information in the event of a corporate amalgamation, reorganization, change of control or sale.

We sometimes use third party service providers that assist us to provide products and services and to administer your account, and to which we may transfer your personal information. Whenever AlphaNet Canada hires other organizations to provide support services, they will be required to conform to our privacy standards and Canadian privacy law principles. Our agreements with these providers allow us to audit them for compliance. We use CSPs, such as SalesForce.com, to store, secure, and process information, including your personal information, on our behalf.  CSPs may use equipment located in the United States and your information will be transferred to and stored on servers located outside of Canada.  For that reason, your information will also be subject to the laws of the United States, including possible access by law enforcement agencies in accordance with federal and state law.

Making the Security of Information a Priority
AlphaNet Canada takes all reasonable steps to protect the security and confidentiality of your personal information.  We protect the personal information within our custody or control with appropriate organizational, technological, and physical safeguards.

AlphaNet Canada Coordinators have access to information for patients only in their geographic service area. We restrict access to nonpublic personal information about our patients to only those who have a need to know that information in connection with the purposes for which it is collected and used. The patient database is located on a secured, standalone computer. Patient information does not reside on AlphaNet Canada’s network server. AlphaNet Canada’s Information Technology Manager maintains the information database. Within AlphaNet Canada, our employees have been trained to protect your personal information. To that end, we’ve established physical, electronic and procedural safeguards to protect your medical and personal information. Security measures in place are expected to protect against the loss, misuse and alteration of the information under our control.

Should your relationship with AlphaNet, Inc. end, your personal information will remain protected in accordance with our privacy practices outlined in this Policy.

Personal information is only retained for as long as is necessary for the purpose for which it was collected. When we no longer are required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold.

Making Sure Information is Accurate
Keeping accurate patient records is very important to us. We will promptly update or correct any erroneous information. If you ever find that your information is incomplete, inaccurate or not current, please call or write your AlphaNet Coordinator or contact our corporate office at:

AlphaNet Canada Privacy Officer
privacy@alphanetcanada.ca

Availability of Privacy Policy
This policy may change from time to time, but you can always review our current policy on our web site at: www.alphanetcanada.ca or contact us for a copy at: privacy@alphanetcanada.ca.