At Orthoquest Pedorthics and Rehabilitation Inc. (“Orthoquest”), we value our relationship with you as a customer and/or patient. It is our responsibility in protecting and keeping private our customers, patients and partners Personal Information. We place a high priority on your personal privacy and remain committed to protect it. Our Privacy Agreement has been developed to comply with the British Columbia government’s privacy legislation, the Personal Information Protection Act (“PIPA”) and its regulations.

In this Privacy Agreement, ‘we’, ‘our’, and ‘us’ refer to Orthoquest, and ‘you’ and ‘your’ refer to each customer or prospective customer and patient or prospective patient, as applicable. The term ‘Personal Information’ refers to information in any form about an identifiable individual (e.g., contact information, medical information, account numbers, or details such as age, marital status, business, and financial information). Orthoquest is accountable for all Personal Information in our possession. To help us meet this commitment, we have designated a Privacy Officer to oversee our privacy program and practices.

By using the Orthoquest website, you signify your consent to all of the terms of this Privacy Agreement. We encourage you to read this Privacy Agreement so that you can understand how we collect, use, share and protect your Personal Information. This Privacy Agreement will continue to apply for as long as Orthoquest holds your Personal Information, including after the termination of your relationship with us. By providing us with Personal Information, you are consenting to the collection, use and sharing of your information as set out in this Privacy Agreement. This Agreement can also be found in our store and on our websites at www.orthoquest.ca.

We may amend this Agreement and our other privacy-related documents from time to time to take into consideration changes in legislation or other issues that may arise at our sole discretion. Any changes we make to this Agreement will be effective when we post the revised Agreement on our website. If we intend to use or disclose your Personal Information for purposes materially different from what is described in this Agreement, we will take reasonable steps to notify you. We encourage you to review the Privacy Agreement whenever you interact with us to stay informed about our information practices, as your continued use of our services or provision of Personal Information after changes have been made to this Agreement constitutes your acceptance of those changes. It is your responsibility to ensure that you read, understand, and accept the latest version of the policy. The date at the end of this policy indicates when it was last revised.

Principle 1 – Accountability
We are responsible for all Personal Information in our possession or control, whether supplied to us directly by you or by a third party. This does not include the name, title or business address or telephone number of an employee of an organization, or information made available in public records.

If at any time you have a concern about the handling of your Personal Information, then please reach out to our Privacy Officer.

Principle 2 – Identified Purposes
We will collect, use and disclose Personal Information as is reasonably required to:

• Identify you and ensure the accuracy of your Personal Information;
• Establish and maintain communications with you, including responding to your enquiries;
• Provide pedorthic, custom foot orthotics, shoe fitting, bracing, compression therapy and rehabilitation services (collectively the “Services”) to you;
• Understand your needs;
• Offer and provide our products and Services to you;
• Facilitate your payment of bills and invoices and to work with your insurance providers to direct bill your insurance providers, where applicable;
• Respond to your inquiries and contact you through telephone, email, and other appropriate communication channels;
• Meet regulatory and legal requirements; and
• Protect against fraud or other illegal activities.

If we use your information for any other purpose than listed above, we will explain the purpose and obtain your consent. We may use your Personal Information for other purposes with your consent or as permitted or required by law.

We also may collect, use or disclose your information to our affiliated companies, your agent and/or broker, operators of insurance industry databases, government agencies, insurers, and/or any other person, corporation, firm or enterprise as reasonably required for the purposes stated above.

Information may be collected by entities, or transferred, outside of Canada for processing, storage, analysis or disaster recovery and may be subject to disclosure to those authorized under applicable laws of the foreign jurisdiction.

Principle 3 – Consent
By purchasing product or utilizing the Services of Orthoquest, or by providing Orthoquest with Personal Information, you provide your consent for the ongoing collection, use and disclosure of your Personal Insurance as described in this Privacy Agreement.

We will obtain your consent for the collection, use or disclosure of your Personal Information except in situations where consent is not required by law. Your consent may be provided expressly (oral or written), implicitly or through an authorized representative. In most cases, your consent may be withdrawn with reasonable notice. If you choose to do so, we will explain the implications of withdrawing your consent.

Collecting Your Personal Information
Personal Information may be collected from you directly, from your interactions with us, and from other sources outside our organization, including from government agencies and registries, law enforcement authorities, public records, credit reporting agencies, other financial institutions, your health providers, other service providers, partners or third parties, agents and other organizations with whom you have arrangements or in accordance with their respective terms and conditions and/or privacy policies, or any other source, with your consent or as permitted or required by law. This information may be obtained by telephone, in writing or electronically. For legal entities such as businesses, partnerships, trusts, estates, or other organizations, we may collect information from each authorized person, partner, trustee, and executor, as appropriate.

You authorize the collection of Personal Information from these sources, and where applicable, you authorize these sources to provide us your Personal Information. When you apply for, or use any product or service and while you are our current, prospective, or former customer and/or patient, or act on behalf of one, we may collect and maintain Personal Information about you such as:

• information establishing your identity (such as your name, address, email address, mobile telephone number, occupation, date of birth and other identification documents or images of such, required by law);
• information to authenticate your identity such as knowledge-based information (i.e., username, password and account information), biometric information (i.e., signature, fingerprint and voiceprint), device information (i.e., device model, browser type and activity, IP address, security cookies and approximate physical location of device), and images recorded by video surveillance at one of our locations;
• information about your financial status including your employment information and history, references, annual income, assets, liabilities, and credit history;
• business name, business address, business telephone number, business email address, name(s) of owner(s), officer(s) and director(s); industry type and financial status (for business clients);
• information reflecting your business dealings with us;
• information we request, or that you provide, about spouses, common law partners or dependents under an insurance product, an authorized user of your account, or intermediaries, and other parties which is required by law. If you provide us with information about another individual, we will assume you have the authority to provide this information and have obtained their consent to its collection, use and sharing for the purposes set out in this Agreement;
• information regarding your medical records and history for the purposes of providing our Services to you;
• other information with your consent, or as permitted or required by law; and
• additional information may be requested to help us determine your eligibility for products and services that we offer.

We may share your Personal Information:

• with our employees, agents, service providers and any other entities that perform services on our behalf (collectively, ‘service providers’). You acknowledge that some of our service providers may be located outside of Canada and as such your Personal Information may be accessible to governmental, national security and regulatory authorities in accordance with the laws of these jurisdictions;
• with other organizations or agents with whom you have arrangements and to whom you have provided consent directly;
• with financial institutions to process payments;
• with payment card networks in order to operate or administer the payment card system that supports the products, services or accounts you may have with us;
• in respect of medical information, with your health care providers;
• in response to a judicial or administrative orders, subpoena, warrant or other demand or request we believe to be valid from governments, regulators, courts and law enforcement authorities in Canada or other jurisdictions or countries;
• to meet requests for information from regulators;
• to satisfy legal, audit, insurance, self-regulatory and regulatory requirements applicable to us;
• in any negotiations for the sale or assignment or proposed sale or assignment of all or part of our business or assets and to our successors and assigns who may use the information for similar purposes as those described in this Agreement;
• to other parties connected with your account, as applicable (e.g., powers of attorney or persons under a representation agreement for personal decision making);
• to help us collect a debt or enforce an obligation owed to us by you;
• with any person or organization, including an investigative body, to prevent, detect or suppress financial abuse, fraud, money laundering, cyber threats, criminal activity, protect our assets and interests, assist us with any internal or external investigation into potentially illegal or suspicious activity or manage, defend, or settle any actual or potential loss;
• with your consent or knowledge (e.g., with a power of attorney, persons under a representation agreement for personal decision making or an estate representative); and
• where permitted or required by law.

We do not sell the names or other Personal Information of our customers. We do not disclose the names or other Personal Information of our customers to other companies without consent, unless required or permitted by law.

Representatives

• Where someone is acting as a representative or we reasonably believe is acting with proper authorization, such as a legal guardian, person having power of attorney, or estate representative, we may share information with and take instructions from them including sharing information as instructed by either representative, where representatives are jointly appointed.
• Following death, we may also share your information with your beneficiaries or estate representatives where reasonably necessary to help in the administration of your insurance products or your estate’s financial affairs.

Anonymous Information

We may collect anonymous information. Anonymous information is information that cannot be associated with or traced back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically by web servers when you visit Orthoquest digital channels (i.e., our public websites and other secure portals). Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address. The anonymous/non-personal information collected may be used or shared for research and analytical purposes. To help us better understand our markets, we may also gather information for analytical purposes by conducting anonymous customer surveys, by extracting demographic information from existing files and from Statistics Canada.

How We Obtain Your Consent
It is important to understand the different ways that we may obtain your consent to collect, use and share your personal information. Depending on the situation, we may obtain your consent in different ways. Express consent may be obtained verbally, electronically or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain information, inquire about or apply for products, or services from us.

We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.

Additional Collection, Use and Sharing of Your Personal Information

Personal Health Information: From time to time, you may provide us with your personal health information (e.g., medical history) in connection with the Services, or any other products you may purchase from us. We may collect or share your personal health information with any health-care professional, medically related facility, insurance company, organization that manages public information data banks or insurance information bureaus. We will not share your personal health information within Orthoquest or use it in a manner other than that of the original intent disclosed to you.

Communications: We may collect information by monitoring and/or recording any communications between you and our representatives (e.g., telephone discussions, email conversations, online chats) for accuracy, service quality, training and security purposes, our mutual protection to prevent or detect fraud, and to enhance our customer service.

We may communicate with you through various channels including telephone, computer, mail, or mobile applications or by other electronic means, using the contact information you have provided.

Service Providers and Third Parties outside of Canada: Information may be stored and processed in any country where we have affiliates or service providers. By using our products or services, you consent to the transfer of information to countries outside of Canada, including the United States, which may be governed by different data protection rules. Orthoquest, and its service providers and other third parties, including affiliates, with whom we share information under this Agreement, may perform activities outside of Canada. As a result, your information may be securely used, stored, or accessed in other countries and be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts, and law enforcement officials in those countries.

We use cookies on our website to allow you to properly navigate the site, to collect aggregated statistics and to remember your settings. We do not use cookies to collect any personal information except where it is explicitly expressed.

Respecting Your Privacy Preference

Subject to legal, regulatory, and contractual requirements, you can refuse or withdraw your consent to our collection, use or disclosure of your Personal Information at any time by giving us reasonable notice. In certain circumstances, your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use and sharing are permitted or required by law, is required to ensure we have correct and up-to-date information about you, such as current address or is necessary to manage our business including the sharing of information when we assign our rights to others for business transactions.

We will act on your instructions as quickly as possible, but it may take some time for our records to reflect your choice as many records can only be changed during regular file updates.

Principle 4 – Limiting Collection
We will only collect, use or disclose your Personal Information that is required to do business with you or as required by law.

Principle 5 – Limiting Use, Disclosure, and Retention
We will not use or disclose your Personal Information for purposes other than those for which it was collected except with your implied or expressed consent or as required by law.

Disclosure within Orthoquest Pedorthics and Rehabilitation Inc.

Orthoquest and/or its affiliate companies may internally share your Personal Information for the purposes mentioned in our Privacy Agreement. Only companies or health care professionals with legitimate business or health care reasons will have access to your Personal Information.

Disclosure to Third Parties

We may share your Personal Information to third parties which may include your health care providers, government agencies, insurance providers, regulatory organizations, payment vendors, credit and consumer reporting agencies.
Our Third-Party partners are subject to PIPA and other privacy requirements. Only companies with legitimate business reasons will have access to your Personal Information.

Disclosure Outside of Canada

Orthoquest may use service providers located outside of Canada or related companies located outside of Canada to collect, use and store your Personal Information for the purposes mentioned in this Privacy Agreement.

Disclosure To You

We may share information or data with you in regular course of running our business. All information or data we share with you is solely for the purpose of helping you evaluate and potentially place your insurance policy with an insurance company and should not be used or shared with any third parties other than for this purpose.

Retention Periods

We will retain your Personal Information only as long as it is required for the reasons it was collected. This may include customer service, legal or regulatory needs that require us to keep your Personal Information beyond the end of your relationship with us.
When your Personal Information is no longer required, we will securely destroy it or convert it to an anonymous form.

Business Transactions
If we enter talks about a merger, acquisition or asset sale with a third party, we may share Personal Information that is deemed necessary in order to satisfy the business needs of such transactions, excluding your medical information. We will provide notice on our website if a business transaction is subject to a new privacy statement.

Principle 6 – Accuracy

You are responsible for advising Orthoquest of any inaccuracies or changes to your Personal Information (such as a change of address, telephone numbers, current address, marital status, health status, etc.). If any of your Personal Information changes or you discover inaccuracies in our data, you are required to advise us so we can update our records. Please be prepared to verify your identity when updating or changing your Personal Information.

Subject to contractual and legal restrictions as well as reasonable notice, you may request access to, correction or deletion of the Personal Information we hold about you at any time by submitting a written request to the Privacy Officer. Please be prepared to verify your identity upon making such a request. We will respond to your request within 30 days of receiving all necessary information or advise you if we require additional time.

Please note that we may not be able to provide you access to your Personal Information in certain situations (e.g., if disclosing the information would reveal confidential commercial information or information about a third party). If this is the case, we will inform you of the reasons that we were unable to provide you access.

Principle 7 – Safeguards

We have implemented administrative, technological, and physical safeguards to protect the security of your Personal Information under our control, regardless of the format in which it is held, against unauthorized access, disclosure, use or modification.

We train our staff on the importance of protecting the confidentiality of your information, and regularly confirm this expectation in writing. We authorize staff to have access to your personal information only on a need-to-know basis to perform their job functions.

To the extent that a service provider requires access to your personal information for an authorized purpose, we require the service provider to implement similar safeguards to protect the security of your Personal Information.

Principle 8 – Openness

At your request, we will make available information about our policies and procedures relating to the management of your Personal Information. You can contact our Privacy Officer with any requests to access to your Personal Information.

Principle 9 – Individual access

Upon your request, we will inform you of the existence, use and disclosure of your Personal Information which is in our possession and control. You have the right to request changes if required. We will respond to your request within 30 days of receiving your written request.

Refusal of Request for Disclosure

We will make every effort to disclose your Personal Information. If a request for disclose is denied, we will provide an explanation.
Examples of reasons for non-disclosure include:

• Cost Preventative
• Personal Information that contains information about other individuals that cannot be released.
• Commercial Proprietary Reasons
• Legal and Security Litigation Reasons

Principle 10 – Questions

To request access to, or correction of, your Personal Information, to ask questions about our privacy policies or to refuse or withdraw your consent to our use of your Personal Information for purposes outlined in this Agreement, you may send in a written request or contact us at (please note that requests for access must be in writing):

Privacy Officer
Orthoquest Pedorthics and Rehabilitation Inc.
1015 Richter St.
Kelowna, British Columbia V1Y 2K4
Tel: (250) 448-5908
Email: [email protected]

If you have any complaints or concerns about this Privacy Agreement or our privacy practices, please refer same to our Privacy Officer. If you choose to send us an email, do not include sensitive information. We are committed to providing you with understandable and easily available information about how we manage your Personal Information.

Orthoquest Privacy Agreement – April 2024