Privacy Policy

WEBSITE PRIVACY POLICY

This Website Privacy Policy applies to: www.ethnomet.com

Last update: December 1, 2022

The respect of your private life is of the utmost importance for Ethnomet, who is responsible for this website.

This Privacy Policy aims to lay out:

  • the way your personal information is collected and processed. “Personal information” means any information that could identify you, such as your name, your mailing address, your email address, your location and your IP address. “Personal information” is a synonym for “personal data” within the meaning of the Regulation 2016/679 of the European Union (General Data Protection Regulation);
  • your rights regarding your personal information;
  • who is responsible for the processing of the collected information;
  • to whom the information is transmitted;
  • if applicable, the website’s policy regarding cookies.

This Privacy Policy complements the Terms and Conditions that you may find at the following address:

www.ethnomet.com/terms-of-use

  1. COLLECTION OF PERSONAL INFORMATION

We collect the following personal information:

  • Last Name
  • First name
  • Mailing address
  • Postal code
  • Email address
  • Date of birth/age
  • Education
  • Professional license registration information

The personal information we collect is collected through the collection methods described in the following section.

  1. FORMS AND METHODS OF COLLECTION

Your personal information is collected through a website registration form

We use the collected data for the purpose of evaluating and facilitating partnerships and healthcare service contracts.

  1. INTERACTIVITY

Your personal information is also collected through the interactivity between you and the website.

We use the personal information thus collected for the following purposes:

  • Contact
  • Regulatory requirements
  1. SHARING PERSONAL INFORMATION

We are committed not to selling to third parties or otherwise commercialize the personal information we collect. However, we may share this information with third parties for the following reasons:

  • Personal information collected via position forms may be shared with local project health organizations in Nigeria for project implementation and verification purposes.
  1. STORAGE PERIOD OF PERSONAL INFORMATION

The controller will keep in its computer systems, in reasonable security conditions, the entirety of the personal information collected for the following duration: the longer of 6 months or the duration of services.

  1. HOSTING OF PERSONAL INFORMATION

Our website is hosted by: Interactive Tracking Systems Inc., located at the following address:

301 Ontario Ave, Saskatoon, SK Canada S7K 1S3.

The host may be contacted at the following phone number: +1 306.665.5026.

Personal information we collect and process is transferred to the following countries: Nigeria, USA.

The transfer of personal information outside of the European Union is justified by the following reasons:

Information will be required by local health care partners in Nigeria to ensure they are licensed to practice.

  1. CONTROLLER

a) Controller

The “Controller” is: Interactive Tracking Systems Inc. The Controller may be contacted as follows:

The data contoller may be contacted by calling +1 306.665.5026 or emailing privacy@itracks.com.

The Controller is in charge of determining the purposes for which personal information is processed and the means of such processing.

b) Obligations of the Controller

The Controller is committed to protecting the personal information collected, not to transmit it to third parties without informing you, and to respect the purposes for which personal information was collected.

In the event that the integrity, confidentiality or security of your personal information is compromised, the Controller is committed to notifying you.

  1. RIGHT OF OBJECTION AND OF WITHDRAWAL

You have the right to object to the processing of your personal information by the Website (“right to object”). You also have the right to request that your personal information not appear, for example, on a mailing list (“right to withdraw”).

If you wish to exercise the right to object or the right to withdraw, you must follow the procedure described hereinafter:

Contact privacy@itracks.com.

  1. RIGHT OF ACCESS, OF RECTIFICATION AND OF REMOVAL

You have the right to consult, update, modify or request the removal of information about you by following the procedure described hereinafter:

Contact privacy@itracks.com

  1. GENERAL PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA UNDER EUROPEAN REGULATION 2016/679

In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of your personal data comply with the following principles:

  • Lawfulness, fairness and transparency: your personal data may only be collected and processed with your consent. Every time your personal data is collected, you will be informed that your personal data is collected and for which reasons your personal data is collected;
  • Limits purposes: the data is collected and processed for one or more purposes set out in this Privacy Policy;
  • Data minimization: only personal data necessary for the purpose to which it is necessary is collected;
  • Storage limited in time: personal data is stored for a limited time, of which you are notified;
  • Integrity and confidentiality of collected and processed personal data: the Controller is committed to guarantee the integrity and confidentiality of the collected personal data.

In order to be lawful and to comply with Article 6 or European Regulation 2016/679, collection and processing will only occur if one of the following applies:

  • You have given your express consent;
  • Processing is necessary for the performance of a contract;
  • Processing is necessary for compliance with a legal obligation;
  • Processing is necessary in order to protect your vital interests or those of another physical person;
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority;
  • Processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party.
  1. DATA PROTECTION OFFICER PURSUANT TO EUROPEAN REGULATION 2016/679

The following person has been appointed as the Data Protection Officer (also referred to as DPO): Michael Amanyi.

The purpose of the Data Protection Officer is to ensure the successful implementation of the applicable European legislative provisions relating to the collection and processing of personal data.

The Data Protection Officer may be reached as follows:

privacy@itracks.com

  1. ADDITIONAL RIGHTS PURSUANT TO EUROPEAN REGULATION 2016/679

In accordance with European regulation relating to the processing of personal data, you also have the rights listed below.

In order for the Controller to grant your request, you must provide your first and last name, your email address.

The Controller must answer your request within a period of thirty (30) days.


a) Right to portability of personal data

You have the right to request the portability of your personal data held by the Website to another site by following the procedure described below:

The user must send an email request to privacy@itracks.com outlining the request and containing information identifying the account.


b) Right of not being the object of a decision based only on automated processing

In accordance with the provisions of the European Regulation 2016/679, you have the right of not being the subject of decision based solely on automated processing if the decision produces legal affecting concerning you or significantly affects you.


c) Right to submit a complaint to the competent authority

In the event that the Controller does not answer your request, you wish to challenge his or her decision or you believe one of your rights has been infringed upon, you have the right to submit a complaint to the competent authority.

  1. SECURITY

Personal information we collect is stored in a secured environment. People working for us are obligated to respect the confidentiality of your personal information.

To ensure the security of your personal information, we use the following methods:

  • SSL (Security Sockets Layer) Protocol
  • Access management – person authorized
  • Access management – person concerned
  • Network surveillance software
  • Automatic backup
  • Digital certificate
  • Username/password
  • Firewalls

We are committed to maintaining a high degree of confidentiality by integrating the latest technological innovations that allow us to ensure the confidentiality of your transactions. Nevertheless, no mechanism can ensure complete security, and transmitting personal information on the Internet always contains an element of risk.

  1. PERSONAL DATA OF MINORS UNDER EUROPEAN REGULATION 2016/679

In accordance with the provisions of Article 8 of Regulation 2016/679, only minors over 15 years of age may consent to the processing of their personal data.

If you are a minor under the age of 15, the consent of a legal representative is required in order for your personal data to be collected and processed.

We reserve the right to verify by any means that you are over 15 years of age or that you have obtained the consent of a legal representative before using our Website.

  1. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may be viewed at all times at the following address:

www.ethnomet.com/privacypolicy

We reserve the right to modify our Privacy Policy in order to guarantee its compliance with the applicable law.

You are therefore invited to regularly consult our Privacy Policy to be informed of the latest changes.

  1. ACCEPTANCE OF OUR PRIVACY POLICY

By using our Website, you certify that you have read and understood this Privacy Policy and accept its conditions, more specifically conditions relating to the collection and processing of personal information.

  1. APPLICABLE LAW

We are committed to ensuring compliance with all applicable legislation, including, but not limited to:

  • the Criminal Code (R.S.C., 1985, c. C-46);
  • Canada’s anti-spam legislation (CASL);
  • the National Security Act, 2017 (S.C. 2019, c. 13);
  • the Communications Security Establishment Act (S.C. 2019, c. 13, s. 76);
  • the Security of Information Act (R.S.C., 1985, c. O-5);
  • the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) or Provincial counterparts in jurisdictions that have their own privacy laws ; and
  • General Data Protection Regulation, Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 for the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.