I. ELITE WEBSITE
The Elite Website (“Website”) refers to the website at www.theelitepractice.com its subdomains, and related domains or sales pages. This Website is owned and operated by Carlo Biasucci Consulting Inc. (“Elite”), located in the Province of Ontario. Elite offers the Elite Practice Transformation professional coaching program to healthcare professionals.
2. OBJECTIVE AND SCOPE OF POLICY
At Elite, we are committed to providing our clients, customers and members with exceptional service. Consistent with our obligations as professionals, Elite is dedicated to maintaining high levels of confidentiality and adheres to certain privacy principles to ensure the confidentiality of the Personal Information entrusted to us.
At Elite, we will inform you of why and how we collect, use and disclose your Personal Information, obtain your consent where required, and only handle your Personal Information in a manner that a reasonable person would consider appropriate in the circumstances.
“Personal Information” – means information about an identifiable individual. Personal Information does not include “Contact Information” defined below.
4. COLLECTING PERSONAL INFORMATION
Unless the purposes for collecting Personal Information are obvious and you voluntarily provides your Personal Information for those purposes, Elite shall communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection. Elite shall only collect client, customer and member Personal Information that is necessary to fulfill the following purposes:
(a) To Verify Identity
To verify identity, Elite may collect your name, home address, home telephone number and birth date. Elite will also collect this information to validate that you are of legal age for on-line purchases of Elite Products and Services (“Purchases”).
(b) To Open and Manage an Account: Use of Website and Purchase of Elite Products/Services
You will need to register and create a “User Account” to complete certain functions on the Website and to complete Purchases. You will be asked to provide certain Personal Information to facilitate same, including your name, shipping address, billing address, telephone numbers, email address, and payment information such as your credit card number. You are also responsible for maintaining and updating the registration information in your User Account with current and complete information.
(c) To Facilitate E-mail Newsletter Subscriptions
To subscribe to Elite’s newsletters, if any, you will need to provide your e-mail address. You may also be asked for other information when you subscribe.
(d) To Ensure a High Standard of Customer Service
Elite may offer support and/or technical assistance with the purchase of some Elite Products and Services. If applicable, you may contact Elite’s customer service centres via telephone, online chat or email. To facilitate the necessary customer service assistance, you acknowledge and agree that the operator may view and/or make changes to information in your User Account and/or request personally identifiable information from you to verify your identity. Further, Elite may access and/or view your Personal Information to:
§ process your orders and returns via our online services;
§ send text message notifications of delivery status;
§ contact you in the event of any problems with the delivery of your items; and
§ answer your queries and to inform you of new or changed services
(e) To Identify Client, Customer and Member Preferences
As part of the registration process for certain Website functions and to complete on-line purchases of Elite Products and Services, you may be asked to provide information that does not personally identify you. Rather, you may be asked to provide information concerning your personal preferences, purchasing habits, etc. in your “User Account” profile or other sections of the Website. Elite requests this optional information to better understand you and to bring to your attention new services, programs or special offers that may be of interest.
(f) To Participate in Forums and Creating “Public Profiles”
You are solely responsible for managing your participation in Forums and your Public Profile. Elite bears no responsibility for any action or policies of any third parties who collect information that you may disclose in User Forums or as a result of Public Profiles.
(g) To Publish Comments, Photographs or Content
If you submit to the Website a comment, photograph or other content online or offline, Elite may publish your name or other personally identifiable information in connection with same. In this instance, you are hereby deemed to have given Elite permission to do same.
(h) To Facilitate Special Promotions and Purchases
If you choose to participate in Elite’s “Special Promotions”, including but not limited to contests and surveys, or to make Purchases, you will be asked to provide personally identifiable information, such as your name, mailing address, e-mail address, phone number, and date of birth. This Personal Information will be collected by Elite and/or a third party, such as a co-sponsor or a vendor involved in, or providing services in connection with, a Special Promotion, or an e-commerce partner in the case of a Purchase.
By participating in the Special Promotion or making a Purchase, you are deemed to have provided consent to Elite to provide your information to third parties who provide certain services such as processing of credit card transactions, customer service, promotion or administration, order fulfillment and/or prize delivery, as applicable. Further, by participating in Special Promotions, you are deemed to have agreed to the official rules that govern the applicable Special Promotion, which may include allowing Elite and/or the relevant sponsor(s) of the Special Promotion to use your name, voice or likeness in advertising or marketing associated with the Special Promotion, to the extent permitted by law.
Elite may also participate in a Special Promotion on a third party’s website or some other means. If you choose to participate in such a Special Promotion, Elite shall collect your Personal Information from the third-party if you opt-in to receive additional communications from Elite, or if Elite is required to fulfill some function in relation to your activity (e.g. to send your order or deliver a prize).
(i) To Research Website Use and Enhance Website Functionality – Cookies and Related
A web beacon is a small graphic image that allows the party who established the web beacon to monitor and collect information about the viewer of the web page or email message. Elite may use web beacons to count visitors to the Website, to learn how individuals use the Website and in email messages, to determine how many messages were actually opened, forwarded and acted upon.
Elite may also collect personally identifiable information through other means, directly or indirectly. This includes:
(a) Via Wireless Carrier or other Third Party
(b) Information About Other People
The Website may ask you to submit Personal Information about other individuals. In the event that you provide Elite with Personal Information about a friend or another individual provides Elite with your Personal Information, Elite shall only forward the requested information. Elite shall not use the email address provided to send any other email communication unless so requested by the individual.
Elite shall obtain your consent to collect, use or disclose Personal Information, except as where noted below, Elite is authorized to do so without consent. Consent may be provided in writing or electronically, or it can be implied where the purpose for collecting, using or disclosing the Personal Information would be considered obvious and you voluntarily provided your Personal Information for that purpose. Consent may also be implied where you are given notice and a reasonable opportunity to opt-out of your Personal Information being used for mail-outs, the marketing of new services or products, fundraising, emails, promotions and the like, and you do not opt-out.
Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product; and the withdrawal of consent would frustrate the performance of a legal obligation, etc.), you can withhold or withdraw your consent for Elite to use your Personal Information in certain ways. Your decision to withhold or withdraw your consent to certain uses of Personal Information may restrict Elite’s ability to provide a particular service or product. If so, Elite shall explain the situation to assist you in making the decision.
Elite may also collect, use or disclose Personal Information without the client’s, customer’s and/or member’s knowledge or consent in the following limited circumstances:
· When the collection, use or disclosure of Personal Information is permitted or required by
· When disclosure is necessary to identify, contact, or bring legal action against someone who may cause or be causing harm to, or interference with, the Elite’s rights and/or property;
· In an emergency that threatens an individual's life, health, or personal security;
· When the personal information is available from a public source;
· When Elite requires legal advice;
· For the purposes of collecting a debt;
· To protect ourselves from fraud;
· To investigate an anticipated breach of an agreement or a contravention of law; and
· To respond to an inquiry, request or complaint that you have made.
6. USE AND DISCLOSURE OF PERSONAL INFORMATION
· To conduct client, customer, member surveys to enhance the provision of services/products; and
· To contact clients, customers and members directly about products and services that may be of interest.
7. RETAINING PERSONAL INFORMATION
Elite shall retain your Personal Information only for as long as necessary to fulfill the identified purposes or a legal or business purpose. Elite shall not remove your Personal Information when there is a legal storage requirement, such as book-keeping requirements or some other grounds to keep the data, such as unsettled debts.
You can withdraw your consent for Elite to use your Personal Information for marketing purposes at any time by sending a letter to Carlo Biasucci Consulting Corporation, 101-432 Great Northern Road, Sault Ste. Marie, ON, P6B 4Z9, or by sending an email to [email protected]. You can also access, edit or remove your Public Profile and/or User Account, if applicable, by signing in to your User Account and following the directions, or by sending an email to [email protected]. You can further unsubscribe from receiving commercial email from the Website by clicking the link contained in the email sent to you.
Notwithstanding the options as set out herein, even if you choose to modify/delete your User Account or unsubscribe, Elite reserves the right to contact you regarding your account, use of this Website, technical support, product information, changes to account terms and any other matter that may affect Elite’s Products and Services purchased and/or registered from Elite.
8. ACCURACY OF PERSONAL INFORMATION
You may request a correction to your Personal Information to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought.
9. SECURING PERSONAL INFORMATION
Elite is committed to ensuring the security of your Personal Information to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. To this end, Elite has implemented technical, physical and administrative safeguards to protect your data from loss, manipulation and unauthorized access and when destroying the Personal Information. Elite has and will continue to adapt these security measures in line with technological developments.
Using a credit card for Purchases is as secure as possible, and all information is sent in encrypted form. The Personal Information is passed through a secure connection and your personal data cannot be read by external parties. Elite works with an authorized payment agent who liaises directly with your bank to ensure the card is valid for purchases. The payment agent processes your card details according to the international security standard PCI DSS, which was developed by the major credit card companies (ie. VISA, MasterCard, American Express, etc.). This means that your credit card details are processed with a very high level of security. Elite reserves the right to carry out an identity check.
Notwithstanding the above, Elite cannot guarantee that unauthorized access, hacking, data loss, or other breaches will not occur. As such, please be aware that your use of the Website and Elite Products and Services is at your own risk. Elite urges you to take steps to protect your information.
10. ACCESS TO PERSONAL INFORMATION
You have a right to access your Personal Information subject to limited exceptions, including but not limited to solicitor-client privilege and that the disclosure would reveal Personal Information about another individual. A request for access to Personal Information shall be made in writing and provide sufficient detail to identify the Personal Information being sought. If a request is refused, in full or in part, Elite shall notify you in writing and provide the reasons for same.
A minimal fee may be charged for providing access to Personal Information. Where a fee may apply, Elite shall advise you of the cost and further request direction from you as to whether or not you desire us to proceed with the request.
11. SUCCESSORS AND ASSIGNS
12. THIRD PARTIES
Elite does not have any control or responsibility for matters related to a third party, and therefore you will have to contact the third party regarding same. Elite further does not endorse or sponsor any other website, is not responsible for the privacy practice of such websites and is not responsible and/or liable for any damages or losses of any nature or kind that may result, directly or indirectly, from your use of or access to such third party websites.
14. QUESTIONS AND COMPLAINTS
Name: Carlo Biasucci
Email: [email protected]
Effective March 18, 2017