Privacy Policy

AURUM GROUP'S PRIVACY POLICY & PRIVACY CODE

1. AURUM GROUP
Aurum Ceramic Dental laboratories Co., Aurum Ceramic Dental Laboratories Ltd., Aurum Ceramic Dental Laboratories Alberta Ltd., Aurum Ceramic Dental Laboratories (Sask.) Ltd., Cerum Ortho Organizers (A Division of Cerum Ortho Distributors Inc.), Cerum Ortho Distributors Inc., Space Maintainers Laboratories Canada Ltd., Aurum Crest Dental Laboratories Ltd., Cerum Dental Supplies Ltd., Classic Dental Laboratories Ltd., Classic Dental Laboratories (Toronto) Ltd., Space Maintainers Laboratories (Ottawa) Canada Ltd., Aurum Ceramic Services Ltd., Aurum Ceramic Services (B.C.) Ltd., Aurum Ceramic Dental Laboratories (B.C.) Inc., Space Maintainers Laboratories (Vancouver) Canada Ltd., Core 3D Centres Limited, and any other subsidiary and/ or affiliate (collectively, "Aurum Group") is committed to protecting your right to privacy. The following describes how the personal information, which we collect from you in connection with our business relationship, will be handled and your rights to limit use of that information.

2. PIPEDA AND WHAT IT MEANS TO US AND YOU
In brief, PIPEDA is the acronym for the Personal Information Protection and Electronic Documents Act, which sets out basic policies for the management of personal information collected, used, and distributed in the private business sector. It is federal legislation applicable to all provinces in Canada, except where the Province may have adopted similar legislation. Quebec is the only province that currently has legislation considered "substantially similar". Thus, organizations, like Aurum Group, must, under the Act, obtain an individual's consent when collecting, using, or disclosing that information. The individual has the right to access the information held by Aurum Group, and to contest the correctness if warranted. The information can only be used for the purpose for which it was originally collected. If Aurum Group needs to or would like to use it for another objective, consent must then be acquired again. Your privacy is of utmost concern to us, and this Privacy Policy manual will explain both your rights and ours. Each employee or representative of Aurum Group is responsible for maintaining and protecting all personal information under their control. Each employee or representative has been informed of these responsibilities through this Privacy Policy and our Privacy Code. Aurum Group has also designated a Chief Privacy Officer to oversee our compliance with PIPEDA and this Privacy Policy.

3. PERSONAL INFORMATION

3.1 Collection
Aurum Group collects personal information by reasonable, lawfully permitted means as prescribed by PIPEDA and thus we limit the collection, use and disclosure of personal information to that which is reasonably necessary to administer our dental laboratory business. Thus, this may include collection in order to understand your specific needs, in order to meet legal, regulatory and contractual requirements, to facilitate the delivery of products and services to you, to maintain your contact information, and to provide information to you. We will identify the reasons for which we collect your personal information, either before or at the time of collection. We will only collect, use and disclose your personal information with your knowledge and consent, except where otherwise permitted or required by law. Our collection of your personal information will be restricted to what is reasonable and necessary for the reasons identified to you, and shall only be collected by reasonable and lawful means. Your personal information will only be used, disclosed or retained for the purposes for which it was originally collected, unless you have permitted otherwise, or when required or permitted by law. We will only retain your personal information for the period of time necessary to fulfill the purposes for which it was collected. Lastly, information about our policies and practices at Aurum Group will be made readily available to you upon request.

3.2 Personal Information defined
"Personal Information" includes all the information provided to us by our customers, employees, suppliers, contractors, and consultants, and may also include, but is not limited to, customer account information, dentist's patient health information, information customers provide to us during the normal course of communication between dentists and Aurum Group staff.

More specifically personal information includes, but is not limited to the following examples:

  • age
  • name
  • blood type
  • identifications
  • income
  • employee evaluations
  • credit records
  • loan records
  • medical records
  • disputes with customers
  • ethnic origins

Personal information does not include the name, title or business address, telephone number, or email address of an employee of Aurum Group.

3.3 Forms of Collection
We may collect your personal information through various forms not limited to, Aurum Group prescription pads, email, the Brightsquid Dental platform, employment forms, insurance forms, our website, etc.

3.3 (a) Email and Email Campaigns:
We will confirm with you that we have your permission to market to you through email. Any and all email campaigns will be compliant with PIPEDA guidelines , and specifically will include the following:

  • a double opt-in message where permission to send the email is received both at the time of sign-up, and upon receipt of the first message;
  • identification of the message source, and if to US recipients', a postal address for the message origin;
  • an "unsubscribe" function which is mandatory under PIPEDA;
  • a link to Aurum Group's Privacy Policy in each email we send out; and
  • a contact email address for our Chief Privacy Officer

3.3(b) Aurum Group Website:
Prior to collecting any of your personal information through our website, we will explain to you what we intend to do with that information.

3.4 Employees, Suppliers, Consultants, & Contractors
If you are, or are potentially, an employee or contractor/consultant, we collect your name, address, telephone number, and other relevant personal information including emergency contacts, family and health benefit information, past employment, educational experience and evaluative information.
We use your personal information for lawfully authorized purposes relevant to our employment/contracting relationship including:

  • Administration of benefits and payroll
  • Entitlement for benefits, raises, bonuses and/or promotions
  • Business development and marketing

3.5 Customers
If you are a customer, we may collect personal information that we require in order to complete your project satisfactorily. We may collect information about you, and, if applicable, your employees, and/or others associated with your organization (such as contractors or consultants). These requests may include name, telephone, fax, email address, job title, organizational chart, credit information and special physical or environmental needs or other information that may be required as your project progresses. This information is used for:

  • Confirming your business identity
  • Entering into a contract with us
  • Development of plans and documents necessary to the satisfactory completion of your project

Providing ongoing service In doing a project for you, we may require your patient information, including:

  • the name of your patient
  • your patient's health information provided for the purpose of completing the project

4. CONSENT
Consent is defined as the "voluntary agreement with what is being done or proposed". Consent can be explicit or implied, or by not opting out. Express consent is given explicitly, either orally or in writing. Express consent is undisputable and does not necessitate any presumption on the part of Aurum Group when seeking the consent. Implied consent occurs where consent may logically be understood from the action or inaction of the individual.

Consistent with privacy principles under PIPEDA and other applicable legislation, and where reasonably possible, Aurum Group only collects, uses or discloses personal information with the consent from the individual. Aurum Group is careful to select a fair and reasonable form for the consent required in the circumstances.

If you are an employee or contractor/consultant, you are hereby notified that your personal information will be collected, used and disclosed to establish and generally to manage our employee or contractor/consultant relationship and facilitate the completion of projects with third parties. In certain limited circumstances consistent with law and regulation (e.g., legal, medical, or security reasons) personal information can be collected, used or disclosed without your knowledge or consent.

If you are a customer, you consent to supply certain pertinent personal information. You consent to the use of that personal information to administer, implement and perform our services as they relate to your project. You also represent that you have obtained the consent required by applicable laws and policies to the disclosure of personal information of your employees, officers, directors and consultants, and specifically, your PATIENTS. In certain limited circumstances consistent with law and regulation (e.g., legal, medical, or security reasons) the personal information can be collected, used, or disclosed without your knowledge or consent.

5. USE & DISCLOSURE OF PERSONAL INFORMATION
Aurum Group will not use or disclose Personal Information for purposes other than those for which it was collected, except with your consent or as required by law. Your Personal Information shall be disclosed only to those who have a "need to know" and the specific information shall be restricted to only that information relevant to the recipients' need to know. Those who need to know may include employees, contractors, consultants, and dental and other health benefit providers. Also, the Personal Information disclosed is limited to only that Personal Information required for the purpose. You may specify any restrictions on whom we want to disclose your Personal Information to or restrict the content.

WE WILL NOT SELL YOUR PERSONAL INFORMATION. We will not use or disclose it to third parties without your knowledge or permission, except in special circumstances, where consent is not required under Section 7 of PIPEDA.

5.1 When we may use your information without your consent
Aurum Group may use your Personal Information without your consent or knowledge only where:

  • Aurum Group has reasonable grounds to believe that the Personal Information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
  • for an emergency that threatens an individual's life, health, or security;
  • for statistical or scholarly study or research (in such case Aurum Group must notify the Privacy Commissioner of Canada before using the information);
  • if it is publicly available as specified in the regulations;
  • if the use is clearly in the individual's interest and consent is not available in a timely way; or
  • if knowledge and consent would comprise the availability or accuracy of the information and collection was required to investigate a breach of an agreement or contravention of federal or provincial law.

5.2 When we may disclose your information without your consent
Aurum Group may disclose your Personal Information without your consent or knowledge only:

  • to a lawyer representing Aurum Group;
  • to collect a debt you may owe to Aurum Group;
  • to comply with a subpoena, a warrant or an order made by the court or other body with appropriate jurisdiction;
  • to the Financial Transaction and Reports Analysis Centre of Canada (FINTRAC) as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act;
  • to a government institution that has requested the information, identified its lawful authority to obtain the information, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law, or suspects that the information relates to national security, the defence of Canada or the conduct of international affairs; or is for the purpose of administering any federal or provincial law;
  • to an investigative body named in the Regulations of the Act or government institution on Aurum Group's initiative where Aurum Group has reasonable grounds to believe that the Personal Information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or suspects the information relates to national security, the defence of Canada or the conduct of international affairs;
  • if made by an investigative body for the purposes related to the investigation of a breach of an agreement or a contravention of a federal or provincial law;
  • in an emergency threatening an individual's life, health, or security (the organization must inform the individual of the disclosure);
  • for statistical scholarly study or research (Aurum Group must notify the Privacy Commissioner before disclosing the Personal Information);
  • to an archival institution;
  • 20 years after the individual's death or 100 years after the record was created;
  • if it is publicly available as specified in the Regulations; or
  • if required by law.

We may disclose your personal information as follows:

  • To someone authorized to collect it on your behalf
  • To others within Aurum Group for management and administration of our business relationship
  • For benefits, raises and payroll purposes

For business development and marketing we may disclose the information we collect to certain third parties including:

  • Third parties such as contractors, suppliers and consultants, as required to satisfactorily complete their contractual obligations with you
  • Other business units of Aurum Group to help serve you better

Any information shared will be done so with the condition that they will only use and retain such Personal Information for the specific purpose for which they are engaged by Aurum Group. Any third party to which Aurum Group discloses your Personal Information is required to protect the confidentiality of your Personal Information in a manner consistent with our own internal process, or as required by law.

6. THIRD PARTY TRANSFERS
As specified in Section 5 above, from time to time Aurum Group may retain third parties to help us promote, implement and administer our services. As such, Aurum Group may need to transfer to these third parties the personal information they need to perform their obligations. "Transfer" is a "use" by an organization and is not to be confused with disclosure. In such cases, Aurum Group must take all reasonable steps to protect the personal information from unauthorized uses and disclosures while in the hands of the third party. Aurum Group will thus take all reasonable contractual steps to ensure that a comparable level of personal information protection is provided by these third parties, including restricting their using the information for any other purpose.

When Aurum Group discloses or provides your personal information to a third party as permitted by these principles, Aurum Group will require them, by agreement, instruction or otherwise, to comply with the requirements that are embodied in these principles. Aurum Group will also ensure that it is satisfied that the third party has similar policies and processes in place, including training of the staff and other effective security measures to ensure that the information in its care is properly safeguarded at all times. Aurum Group will also retain the right to audit and inspect how the third party handles and stores the information transferred to them, and we will, if needed, exercise our right to audit and inspect the information.

7. ACCURACY
Aurum Group will make every reasonable effort to ensure that the personal information we obtain from you will be maintained as accurately and completely as necessary for its purpose. Your personal information will be verified in our records and updated if necessary each time you notify us of a change, and as practical during the course of our business relationship with you. It is your responsibility to notify us immediately of any change in personal information which you have previously supplied to us. For more information on accuracy of your information, please see Section 9 below.

8. RETENTION AND SECURITY OF YOUR INFORMATION:
We will only retain your personal information for the period of time required to fulfill the purposes for which it was collected, or as required by law. We will protect the personal information we collect with security safeguards appropriate to the sensitivity of the information. Aurum Group maintains complete records of the storage locations of personal information, both paper and electronic.

Aurum Group will take appropriate security measures to protect your personal information against loss, theft, unauthorized access or disclosure, improper use, alteration or destruction. We currently employ physical safeguards such as security systems, locked storage on and off-site, locked storage access limited to restricted personnel only, offsite backup, etc.

We also have technological safeguards in place such as, network security, firewalls, antivirus, and encryption, etc. The administrative safeguards we have in place include employee training in privacy issues, circulation and mandatory compliance with Privacy Policies and Privacy Code.

If you are a customer, upon your written and reasonable request, your personal information will be erased from our records, though removal of your personal information from our records may affect our ability to provide you with our services or products. If you are an employee or contractor/consultant, personal information that is no longer necessary or relevant for the identified purposes or required to be retained by law will be destroyed, erased or made anonymous or unidentifiable. We may retain your personal information for up to seven (7) years.

If you are a customer, personal information that is no longer necessary or relevant for the identified purposes or required to be retained by law will be destroyed, erased or made anonymous or unidentifiable. When seven (7) years have elapsed after the substantial completion of your last contract, all personal information pertaining to you and your employees will be permanently destroyed and erased from our records.

9. ACCESS
You have the right to ask whether we hold any personal information about you, what kind of information we are holding, and what we use and disclose your information for. You can request access to your personal information maintained by Aurum Group at any time. We will respond to your request within 45 days. There may be a small charge for each request. If charges apply, we will notify you in writing and seek your approval of the charges prior to processing your request. If you believe any of the information we have collected from you is incorrect or incomplete, you have the right to request us to change it. Where we have obtained medical information about you from a dentist, we will only release this information to you and /or back to the dentist.

You may submit your request in writing to Aurum Group's Privacy Officer:

Aurum Group
115-17th Avenue S.W.
Calgary, AB T2S 0A1
Attn: Rita Schlegel
Chief Privacy Officer

Please specify as much as possible which personal information you are requesting. We will respond as quickly as possible, and we will inform you if for some reason we are unable to respond within the 45 day time frame. In certain specific circumstances, we have the legal right to refuse your request for access.

10. COMPLAINTS:
You may contact us at any time with suggestions, questions, and complaints about our Privacy policy and Privacy Code. If you feel Aurum Group has not complied with appropriate privacy principles or practices, you may register a privacy-related complaint with our Chief Privacy Officer. You may at such time request that we correct or remedy such non-compliance and we will respond to your complaint promptly once we have had an opportunity to complete an investigation. If a complaint is justified, we will take all reasonable steps to correct the non-compliance, which may include updating our policies and practices at Aurum Group. Please address any complaints to:

Aurum Group
115-17th Avenue S.W.
Calgary, AB T2S 0A1
Attn: Rita Schlegel
Chief Privacy Officer

We reserve the right to revise this policy from time to time, as privacy laws and practices evolve and will publish revisions at our earliest reasonable convenience.

Aurum Ceramic Dental Laboratories Co. (2011). Reproduction of this work in whole or in part by any means whatsoever is strictly prohibited without the express written consent of Aurum Ceramic Dental laboratories Co. All rights reserved.

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