Hopitel

Hôpitel values its relationship with customers, suppliers, and employees. We are committed to maintaining the confidentiality and privacy of personal information gathered in these relationships. To further clarify this commitment, Hôpitel has adopted this Privacy Code to guide how we collect, use, and disclose personal information gathered in the course of operating our business. Our code is based upon the principles outlined in the Personal Information Protection and Electronic Documents Act of Canada (PIPEDA). It is designed to ensure that the purpose for gathering personal information is clearly defined, that consent is obtained to collect and use the information, and that safeguards are in place to protect the information. As business environments change, so do the requirements for the collection of personal information. Accordingly, this Code and the internal policies that support this Code will be subject to review to address new business conditions and respond to evolving law and policy.

Hôpitel provides hospitals, clinics, and nursing home patients, with self-rent 24/7 access to a wide variety of Infotainment services such as Broadcast & On-Demand Television, On-Demand Movies, Internet, Email, Social Media, On-Demand Music, Radio, On-Demand Audio Books, Interactive Games, On-Demand Relaxation Videos, Wi-Fi Hotspot, Video Calling and Health Education. (the “Meditel Services”). In the process of providing the Meditel Services Hôpitel may collect personal information about individual hospital patients who are using the Meditel Services. Hôpitel provides hospitals, clinics, and nursing home patients, as well as patients residing at home or elsewhere, with access to audio-visual healthcare educational programs, questionnaires, surveys as well as motion pictures, television, and other audio-visual entertainment. (the “PatientLogix Services”). In the process of providing the PatientLogix Services, Hôpitel may collect personal information about individual hospital patients who are using the PatientLogix Services.

Hôpitel provides hospitals, clinics, and nursing home patients, as well as patients residing at home or elsewhere, with access to an audio-visual video calling application. (the “Hôpiface Services”). In the process of providing the Hôpiface Services, Hôpitel may collect personal information about individual hospital patients who are using the Hôpiface Services. Hôpitel take its users’ right to privacy seriously and use and disclose your information only as set forth in this policy.

WHAT IS PERSONAL INFORMATION?
Personal Information is any information about an "identifiable individual" including information regarding ethnic background, religion, marital status, medical, employment, email addresses and education. Information published publicly such as listed telephone number, address and name is not considered to be personal information.

ACCOUNTABILITY
Hôpitel is responsible for the personal information under its control. Hôpitel has established internal procedures, and where appropriate, contractual arrangements with external parties, to protect personal information. The Hôpitel Administration monitors adherence with this Code to the best of its abilities, to guide staff in understanding and implementing privacy procedures, and to respond to requests from customers and employees for information on privacy issues. IDENTIFYING PURPOSES
The purpose for collecting personal information will be communicated at the time the information is gathered. If personal information is to be used for a purpose other than originally communicated, consent will be obtained before using the information for the new purpose.

In general, Hôpitel collects personal information for the following purposes:
• To provide entertainment content, health education content and communication services to patients and residents of healthcare facilities
• To allow Hôpitel or hospital facilities to collect debts for services rendered, rectify billing errors or issue refunds in relation to these services
• To undertake health education media follow-up questionnaires to glean patient comprehension on health education media content
• To undertake customer satisfaction surveys for the purpose of improving existing products and services delivered, and determining other products and services in demand
• To provide Point of Sale terminals and related network connectivity to merchants, as well as necessary leasing arrangements
• To provide transaction processing through a self-rental application
• To comply with any other legal or regulatory requirement

CONSENT
Hôpitel will obtain consent to collect, use or disclose any personal information except where Hôpitel is authorized or required by PIPEDA or any other law to do so without consent. Depending upon the circumstances, consent may be express or implied. The purpose for obtaining personal information will be communicated in understandable terms so that the individual can base consent upon meaningful information. Consent may be withdrawn at any time, subject to legal or contractual restrictions, providing adequate notice is provided. Upon withdrawal of consent, Hôpitel will notify the individual of the consequences of withdrawal, which may include the inability of Hôpitel to provide further services to the individual.

LIMITING COLLECTION
Hôpitel will limit its collection of personal information to that which is reasonably necessary to provide a product or service, and which is reasonably necessary for the purposes consented to.

LIMITING USE, DISCLOSURE AND RETENTION
Personal information is not used, disclosed or retained for any purposes other than those for which it was collected. Personal information will be kept only as long as necessary to fulfill those purposes and as per government regulations. In most cases, personal information will be retained to allow for challenges to, or correction of, transactions related to the information. Where personal information is no longer required to fulfill the identified purposes and or is not required by governmental regulations to be retained for accounting purposes, it will be destroyed, erased, or made anonymous. In certain circumstances, personal information may be disclosed to third parties without consent of the individual. Hôpitel may disclose personal information for the following purposes: • In respect of an emergency that threatens the life, health, or security of the individual
• Pursuant to lawful requests to comply with a warrant, order or subpoena made by a court or other body with appropriate jurisdiction
• When Hôpitel has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial, or foreign law, and the information is used for that investigation
• Any other situation as permitted under PIPEDA

ACCURACY
Hôpitel will endeavor to keep personal information as accurate, complete, and up to date as possible for the purposes for which it was collected. Individuals are encouraged to advise Hôpitel of any changes to personal information that may be relevant to the services provided by Hôpitel.

SAFEGUARDS
Hôpitel will protect all personal information in its custody by making reasonable arrangements to prevent unauthorized access, collection, copying, use, disclosure, or modification of that information. Hôpitel's methods of protection will include physical measures (such as locked storage facilities and restricted areas), organizational measures (such as restricting access to computer systems) and technological measures (such as passwords and firewalls) Our employees are educated on the importance of client confidentiality, and are instructed to ensure client information is accessed and used only for the business purposes we have identified, and disclosed only to parties who are bound, contractually or through other reasonable means, to a comparable level of personal information protection.

OPENNESS
Hôpitel will be open about its procedures used to manage personal information as per this Privacy Policy. The most up to date version of this policy will be available on our websites or you can request a copy of the Privacy Policy by writing to the Hôpitel Administration Privacy Policies Department at the address noted below.

INDIVIDUAL ACCESS
Individuals who wish to review or verify personal information held by Hôpitel may do so by making a request, in writing, to the address noted below. Upon verification of the individual's identity, Hôpitel will respond within 30 days with a description of the ways in which that information is used and a description of any entities to which such information may have been disclosed. Hôpitel may request certain information of the individual in order to authenticate identity and may charge a reasonable fee for providing the information. An estimate of such fee will be provided to the individual if requested. If an individual finds the information inaccurate or incomplete, upon providing evidence to verify the correct information, Hôpitel will promptly update the individual's records. In certain instances, Hôpitel may not be able to provide access to certain personal information. This may include situations in which: • The information contains references to other personal information
• The information cannot be disclosed for legal, security or commercial proprietary reasons, or
• The information is subject to solicitor-client privilege

CHALLENGING COMPLIANCE
Hôpitel encourages our customers and clients to tell us of any concerns they may have regarding our compliance with the principles of PIPEDA. If an individual has an inquiry or concern about Hôpitel's personal information handling practices, it may be directed, in writing, to the Hôpitel Administration Privacy Policies Department at the address noted below. Should any complaints be determined to be justified, Hôpitel will take appropriate measures including, if necessary, amending its policies and practices.

WHAT PERSONAL INFORMATION DOES HÔPITEL COLLECT?
Hôpitel collects personal information necessary to set up and maintain you’re Meditel, PatientLogix and Hôpiface Services. For Meditel Services when a patient is not paying by cash or debit, credit card information is required. For PatientLogix Services and Hôpiface Services, information typically is limited to an email address to access Health Education programs and a video calling application. Note that your email address may contain part or your entire name. We may also collect from time-to-time personal information generated from Patient Health Educational Questionnaires and Patient Surveys on behalf of hospitals (“Survey Information”) Survey Information which is typically transferred to the related hospital for its internal use.

YOUR ON-LINE PRIVACY ON HÔPITEL IN-PATIENT ROOM TERMINALS, WEBSITES AND DOWNLOADABLE APPLICATION
Hôpitel collects some information about the ways you use its websites to make its site more interesting and useful to you. You are welcome to browse our websites anonymously at any time, without revealing any personal information.

There are a few activities where the collection of personally identifiable information may be necessary such as rental orders processed through the Hôpitel in-patient room terminal or the Hôpitel Internet website for Television, Internet, On-Demand Movie and Music streaming, Video Calling, Telephone services, Health Education and our Internet Information Request website application. Whenever personally identifiable information is collected, you will know because you will have chosen to provide your information. Hôpitel provides the consumer the ability to rent products and or services directly through its in-patient room terminals, its website or its downloadable application. Hôpitel only collects the Personal Identifiable Information required for the purposes of processing your order. The services of a certified third-party payment provider is utilized to process on-line payments. Your credit card information is provided directly by you to this provider and can be shared or made available to Hôpitel. Hôpitel retains only the credit card holder’s name, first four digits and the last four digits of the credit card and an email address for the purposes of a possible refund request. Personal information provided to facilitate the payment of your order is transmitted using Secure Sockets Layer (SSL) protocol, an internet technology used to protect your Personal Information from being intercepted or used for unauthorized means. However, data transmission over the Internet cannot be guaranteed to be 100% secure. As a result, while the Hôpitel in-patient room terminals and the Hôpitel website strives to protect your Personal identifiable Information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

IP ADDRESS (HÔPITEL WEBSITE)
When you visit Hôpitel websites, your IP address may be collected from time to time so that we know where to send the information you are requesting. This IP address does not personally identify you.

ANONYMOUS INFORMATION (HÔPITEL WEBSITES)
This is information that cannot be associated with a specific individual. The Hôpitel web servers collect some anonymous information automatically when you visit its site. This information may include the pages you visited, what content you downloaded, the type of web browser you were using, and the level of encryption your browser supports. This information is collected on an aggregated basis. No personal information is associated with these statistics. We use this information to determine what type of information is most useful to you so that we can improve our websites to make it easier for you to access information.

COOKIES (HÔPITEL WEBSITES)
Hôpitel’s website collects aggregated site-visitation statistics using cookies, small text files containing a unique identification number that identifies your browser to its computers. This small file of information allows the website to remember important information that will make your use of the site more enjoyable. Cookies tell us which pages are visited, by how many people, the average time spent, and other useful statistics relating to the use of the site. This helps us to enhance the online experience of visitors to our sites. Hôpitel uses the statistics to understand how customers use its sites, to make it easier for you and other visitors to use, to monitor the site’s performance and to improve the Hôpitel websites. To assist you, cookies help us remember who you are through your browser settings, while saving your passwords and preferences so you don’t have to enter them each time; essentially, cookies save you time. We never combine information gathered by a cookie with personally identifiable information. The use of cookies is an industry standard, and you will find that most major websites use cookies and most major browsers are set up to accept them. If you wish, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. You do not need to accept cookies to visit our sites. However, should you choose not to accept these cookies, your experience at our sites (and other websites) may be diminished and some features may not work properly.

HOW WE SAFEGUARD YOUR INFORMATION
The information you provide to Hôpitel on its in-patient room terminals and websites are securely maintained and kept confidential. Information is retained in secure facilities, and protected from unauthorized access. We provide technical, administrative, and physical security measures to protect your information against loss, misuse, and unauthorized access or disclosure.

LINKS TO OTHER WEB SITES
The Hôpitel in-patient room terminals and website may contain links to other sites that are not governed by this Privacy Statement. Please be aware that Hôpitel is not responsible for the privacy practices of other such sites. This policy applies solely to information collected by this website. Please note that when you click on one of these links, you are moving to another web site. It is important for you to read the Privacy Statement and terms of use for each site you visit to ensure you are comfortable with how they might use your personal information. Hôpitel provides links to you only as a convenience, and the inclusion of any link does not imply endorsement, investigation, verification, or approval of such websites, products, services, or publications by Hôpitel.

Your use of the Meditel, PatientLogix or HôpiFace Services or the Hôpitel website, or downloadable application in connection with any of these services constitutes your agreement with this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Meditel, PatientLogix or HôpiFace Services, the Hôpitel website or downloadable application. We reserve the right to change this Privacy Policy at any time by posting changes on this page. Your continued use of our Services and/or website following the posting of any changes will signify your acceptance of those changes.

ALL CORRESPONDENCES REGARDING THIS PRIVACY POLICY MAY BE DIRECTED TO: