Last Updated: March 23, 2017

Our Commitment to Privacy: Ontario Association of Optometrists (“OAO”, “it”, “us” or “we”) is committed to protecting the privacy and confidentiality of personal information in its possession.
OAO is a voluntary, not-for-profit professional association that represents doctors of optometry in Ontario, Canada. The OAO is committed to keeping the personal information of our members, customers (general public and non-member doctors of optometry) and industry partners (exhibitors and sponsor) accurate, confidential and secure.
 
This privacy policy explains how personal information is collected, used and disclosed concerning OAO’s customers and other individuals.  OAO is committed to collecting, using and disclosing personal information responsibly and in accordance with this privacy policy.  
If you do not consent to the collection, use and disclosure of your personal information in accordance with this privacy policy, do not provide OAO with any personal information.  It is important to note that some of OAO’s products and services can only be provided if OAO receives appropriate and required personal information.  Consequently, should you choose not to provide OAO with the required personal information, OAO may be unable to offer these products and services to you.
Personal Information: For the purposes of this privacy policy, the term “personal information” means any information that is defined to be personal information under applicable privacy laws.  Usually, this refers to any information about an identifiable individual or any information that can be used to identify an individual.

Personal information may include, for example, your name and home address, your date of birth and gender, health information, your occupation, your personal financial records or credit information, or any personal identification numbers.
In most circumstances, personal information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not personal information under this privacy policy.

Purposes: OAO may collect, use or disclose personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:
To provide communications, and deliver programs and event information;
To establish, maintain and manage our relationships with users of the Website;
To provide products and/or services to users and/or access to OAO’s Website;
To comply with OAO’s legal obligations and regulatory requirements;
To provide information to anyone working with or for OAO as needed for the provision of OAO’s services;
To develop and manage OAO’s business and operations;
For billing, accounting and debt collection services relating to OAO’s products and services;
To distribute publications, invitations, advertising, and other communications that OAO believes may be of interest to OAO’s clients, customers and other individuals;
To provide for the safety, health, security and emergency preparedness of OAO’s staff, guests and visitors who are located on OAO’s premises;
To respond to questions and concerns of users;
To contact users for survey or client satisfaction purposes, or for the purpose of market or other types of research;
To detect and protect OAO and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with OAO’s insurers;
To otherwise communicate with OAO’s insurers;
To generate analytics;
To support hosting and backend infrastructures of OAO or of third parties that assist OAO;
To generate location-based interactions;
To manage contacts and to manage the sending of messages;
To undertake registration and authentication of users;
To generate and provide social features;
To ensure that OAO members qualify for membership within the association;
To provide members with membership services and exclusive benefits;
For the payment of annual dues, registration fees, and other fees, such as fees for programs or events;
To provide classified ad services;
For internal, external and regulatory audit purposes; and
For any other purpose for which OAO has your consent.

Consent: Privacy legislation requires OAO to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.

By providing your personal information to OAO, you agree that OAO may collect, use and disclose your personal information in accordance with this privacy policy and as otherwise permitted or required by law, and that OAO may access, process and store your personal information in Canada or another jurisdiction.

When OAO receives personal information from you for the purposes of providing you with OAO’s services or for other uses identified herein by OAO, you are providing OAO with consent as follows: 
1. to allow OAO to deal with that personal information in a reasonable manner; 
2. to allow OAO to provide your personal information to third parties it engages to provide or support OAO’s Website;
3. to allow OAO to use and store your personal information for the purpose of providing you with the products and services you purchase from OAO and to utilize this Website; and
4. to allow OAO to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by OAO. 

If you need to provide OAO with personal information about other individuals, you represent and warrant to OAO that, where required by law and prior to your disclosure to OAO, you will obtain the consent of each individual to the collection, use and disclosure by OAO for the specific purpose(s) that the disclosure is made by you.

Providing OAO with your personal information is always your choice. When you request products and/or services from OAO, utilize OAO’s services, or register with OAO’s Website, OAO asks that you provide information that enables OAO to respond to your request and/or provide you with OAO’s services. In doing so, you consent to OAO’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.

There are legal exceptions where OAO will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if OAO must comply with a court order or governmental order.

If OAO sells its business or merges with another party, your consent will be implied to transfer your information to OAO’s successor for the same purposes as set out in this privacy policy.

Collection of Personal Information: OAO collects your personal information in accordance with this privacy policy.

OAO may collect personal information about you from other sources, such as websites having links to or from this Website, government ministries, departments or agencies, government registries, investigators, health institutions or organizations, insurance companies or financial institutions.  By using OAO’s Website and/or service(s) you consent to OAO’s collection of your personal information from other sources. 

Use of Personal Information: OAO uses your personal information in accordance with this privacy policy. OAO’s staff may use your personal information for the purposes identified in this privacy policy.

Disclosure of Personal Information: OAO will only disclose your personal information for the purposes set out in this privacy policy.

OAO does not sell client lists or personal information to others. In providing OAO’s services or access to OAO’s Website, OAO may need to disclose the personal information OAO collects to other service providers or agents who perform various functions for OAO, provided such suppliers agree to keep all personal information private, confidential and secure and to use the personal information only to carry out work on OAO’s behalf.

In certain circumstances, OAO may be required to provide personal information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance OAO may have a legal duty or right to disclose personal information without the individual’s knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Ontario Ministry of Finance; Ontario Ministry of Labour, etc. and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.

Privacy and Our Websites: Each time a visitor comes to the Website, OAO’s web server may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on OAO’s Website and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. OAO may use this non-personal information to optimize OAO’s Website, products and/or services.

OAO may, from time to time, use “cookies” solely for security and authentication purposes. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services.  At your option, you may turn off OAO’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of OAO’s Websites, products and/or services.  To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.  

OAO may, from time to time, engage third parties to assist with this Website, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of OAO, push notifications to you, and use “cookies”, as discussed herein.  

By accessing and browsing OAO’s Website, products and/or service(s), you agree that OAO, or any third party it engages or that assists OAO,  may collect, use and disclose any information collected about you through OAO’s Website, products and/or services or that you provide to OAO through OAO’s Website, products and/or services as described in this privacy policy.

OAO’s Website, products  and/or service(s) may contain links to other sites and may provide forms on behalf of other organizations.  This privacy policy only applies to personal information that we collect, use and disclose.  OAO is not responsible or liable for the privacy practices of third parties, including any organizations on the behalf of which OAO provides forms, and OAO strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party.

Retention and Destruction of Personal Information: The amount of time OAO will retain personal information varies, depending on the services OAO has provided and the nature of the personal information that OAO holds.  OAO retains personal information for such period of time as is necessary for OAO to maintain sufficient information so OAO may respond to any issues that arise at a later date or as is required by law.

When personal information is no longer required by OAO or by law, OAO will either convert it into an aggregated non-identifying form or OAO will appropriately destroy or erase the personal information in a manner that is in accordance with OAO’s current policies and procedures.

If you are a member and at any point you decide that you no longer wish to participate as an OAO member, your practice information record required for the Website will be deleted and a copy of such record will be stored offline in a secure archive in accordance with related laws. Should you reinstate your membership information from this record may be accessed and utilized by OAO.

Safeguarding Personal Information:
OAO employs reasonable physical, electronic and procedural safeguards that are designed to protect OAO’s systems and personal information under OAO’s control against unauthorized access and use. In accordance with appropriate industry standards in Canada, all safety and security measures are appropriate to the sensitivity level of the information collected. 

OAO may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and OAO does not have any control over such external servers or services.

Online transactions and information on the Website may be processed using secure 128-bit encryption (Thawte® SSL123 Certificate has been purchased). 

Electronic Communications: Email is frequently OAO’s preferred method of communicating with you and others, and, unless you object, OAO may use unencrypted plain text or html-based emails or messages when communicating with you.  These emails or messages, and other electronic means by which OAO may communicate with you, may contain information that is confidential, unless you instruct OAO not to send such information electronically. OAO may communicate with you through other electronic means, in accordance with the contact information you provide to OAO.

While OAO makes every effort to secure all electronic communications within OAO’s control, there are inherent risks involved with exchanging information electronically.  For example, such information may be accidentally or deliberately intercepted by third parties.  OAO is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.

OAO will endeavour to be compliant with Canada’s Anti-Spam laws (“CASL”) in OAO’s commercial electronic communication with you. Should you fail to provide OAO with the requisite consent to send you commercial electronic messages, or withdraw such consent, OAO may be unable to provide, or continue to provide, this Website or some of OAO’s products and/or services that can only be provided if OAO receives appropriate and required personal information. CASL consent can be provided or withdrawn at: reply@hookeapp.com
Keeping Information Accurate / Access and Correction: It is important to OAO that your personal information held by OAO is accurate and complete. Having accurate information about you enables OAO to give you better service. You can help OAO keep personal information up-to-date by keeping OAO informed of any changes, such as a change of address, telephone number or any other circumstances.

With some exceptions, OAO has the right to access, verify and amend the information OAO has about you after OAO has received your written request and authenticated your identity.

OAO may charge a reasonable fee for providing information in response to an access request, and, upon request, OAO will provide an estimate of any such fee upon receiving a request to access information. OAO may require a deposit for all or part of the fee.
Where applicable or permitted, OAO will make the information available within 30 days or provide written notice when OAO requires additional time to respond to a request for access to information.

In some situations, OAO may not be able to provide access to certain personal information as the right to access personal information is not absolute.  If OAO does not provide you with the requested information, OAO will notify you in writing and explain OAO’s reason(s) for not fulfilling your request.

Despite OAO’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let OAO know and OAO will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from OAO. OAO will note errors, incomplete information or unresolved differences in information collected in any file it has relating to you.

Withdrawal of Consent: You may, at any time, withdraw your consent to OAO’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions.

Should you choose to withdraw your consent, OAO may be unable to provide, or continue to provide, this Website or some of OAO’s products and/or services that can only be provided if OAO receives appropriate and required personal information.  Consequently, should you choose not to provide OAO with the required personal information, OAO may be unable to offer this Website and such products and/or services to you.

You may, at any time, ask OAO not to send you further marketing materials about OAO’s products or services or if you do not wish to receive further invitations, you may unsubscribe or ask OAO not to contact you for these purposes.

Privacy Concerns: OAO will respond to questions and concerns relating to OAO’s personal information handling practices and this policy.  

Contact Information: Please contact OAO to obtain further information about OAO’s policies and procedures, to seek access to personal information OAO may have about you, or if you have any unresolved inquiries or concerns. OAO will respond to you promptly and do OAO’s utmost to resolve your concerns.  OAO may need to ask you for personal information to verify your identity. OAO can be contacted at: Beth Witney, Chief Executive Officer, Ontario Association of Optometrists, 20 Adelaide Street East, Suite 801, Toronto, ON, M5C 2T6; or bwithney@optom.on.ca

Changes to this Privacy Policy: This privacy policy is effective as of August 26, 2016.  OAO reserves the right to change this privacy policy, and any of OAO’s policies and procedures concerning OAO’s practices for handling personal information, at any time and without any prior notice.  If OAO has modified or amended our privacy policy, OAO will post the most current version on OAO’s Website.  Any changes that are made to this privacy policy will apply to both any personal information that OAO holds prior to the effective date of the amended privacy policy and any personal information that OAO collects on or after such effective date.

Successors and Assigns: OAO’s successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this privacy policy.

© Ontario Association of Optometrists, 2017.