Introduction
NRGene Canada Inc. and its affiliates (referred to interchangeably herein as “NRGene”, “we”, “our” or “us”) may collect certain information based upon and as a result of your use of the NRGene the website www.nrgenecanada.com, its subdomains and its related features and in connection with our products and/or services (“Website”, and collectively with our products and/or services – the “Services”).
NRGene is dedicated to protecting your privacy rights and making our practices regarding your personal information more transparent and fair. This Privacy Policy (“Policy”) is in compliance with the applicable data protection laws, including the British Columbia’s Personal Information Protection Act (“PIPA“), and was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit our Website, use or interact with our Services, or otherwise access or use any of our Services.
We encourage you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services.
You are not legally required to provide us with any Personal Information (as defined below), but without it we will not be able to provide you with the full range or with the best experience of using our Services.
This Policy is integrated into and forms part of the NRGene Terms of Service.
- Definitions:
In this Policy:
- “Personal Information” means information about an identifiable individual, and does not include Contact Information.
- “Contract Information” means information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual.
This section sets out how and when we collect your Personal Information. Please note that we will only collect the minimal amount of Personal Information as necessary to achieve the purpose of the collection.
- Usage Information. When you use our Services, we collect technical information about your interaction with our Services. Such information may include IP address, unique identifiers (e.g. MAC address) as well as other information which relates to your activity in the Services.
- Communication Information. When you send us an email or contact us via the Website, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.
- Tracking Technologies. When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies“). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Service’s performance, and perform analytics. We use Tracking Technologies on certain pages of our site to help analyse our website flow, measure promotional effectiveness and promote trust and safety. You may set your browser to refuse cookies, but certain parts of our website may not function properly as a result.
The Personal Information described above may be collected for the following purposes:
- Provision of the Service – we will use the Personal Information you provide us for the provision and improvement of our Website, providing customer support and to respond to your queries.
- Improving our services – we collect and analyze information about you and your usage of our Website to improve its usability and effectiveness.
- Marketing – according to your communication preferences, we may use your Personal Information in order to send you commercial communication, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions and events, about us and our partners. See more under “Marketing” section.
- Protecting our interests – we may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Website and Services and protect the rights and property of the Company, its users and/or partners.
- Enforcing of policies – we may use your Personal Information in order to enforce our policies, including but not limited to our Terms of Use.
- Compliance with legal and regulatory requirements – we may use your Personal Information to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
- Process for other purposes for which we obtain your consent.
We will obtain your consent to collect, use or disclose your Personal Information, except where we are legally authorized or required by law to do so without consent. For example, we may collect, use or disclose your Personal Information without your knowledge or consent where:
- The information is publicly available, as defined by statute or regulation;
- We are obtaining legal advice;
- We reasonably expect that obtaining consent would compromise an investigation or proceeding; and
- We are permitted to by law.
Your consent may be provided orally, in writing, electronically or through inaction. Your consent is implied when it is obvious that we are collecting, using or disclosing personal information and when you voluntarily provide Personal Information for that obvious purpose. Your provision of Personal Information to us means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this policy.
Your consent may be implied, express or provided by an authorized individual depending on the nature and sensitivity of the personal information.
You may withdraw their consent at any time by giving us reasonable notice, subject to legal, contractual and other obligations. If we receive notice of withdrawal of consent, we will inform you of the likely consequences of withdrawing consent, which may include our inability to provide certain goods or services for which that information is necessary.
We may share your Personal Information as described below:
- Affiliated companies: we may share Personal Information internally within our family of companies, for the purposes described in this Policy.
- Service providers: we work with service providers that work on our behalf that may need access to certain Personal Information in order to provide their services to us. These companies include those we have hired to provide various services, such as cloud storage vendors.
- Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. We will only disclose the minimum amount of Personal Information that is required for compliance with such legal requirements.
- Auditors and advisers: we may share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for the purpose of ensuring our compliance with regulatory requirements and industry standards.
- Mergers and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
We are committed to ensuring the security of your Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
The following security measures will be followed to ensure that your Personal Information is appropriately protected:
Physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures).
We will use appropriate security measures when destroying your Personal Information such as shredding documents and deleting electronically stored information.
We will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.
We will retain your Personal Information for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
Please note that if we use your Personal Information to make a decision that directly affects you, we will retain that Personal Information for at least one year after making such decision, as required under PIPA, so that you can have a reasonable opportunity to request access to it. After that period has passed, we will securely destroy or anonymize such Personal Information once it is no longer necessary to fulfil the purpose for which it was originally collected.
- Accuracy
We will make reasonable efforts to ensure that your Personal Information is accurate and complete where it may be used to make a decision about you, or disclosed to another organization.
You may request a correction to your Personal Information in order 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. A request to correct personal information should be sent to the contact details detailed below.
If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note your correction request in the file.
You have a right to access your Personal Information, subject to limited exceptions, which include documentation subject to solicitor-client privilege, or where disclosure would reveal Personal Information about another individual. A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. Please send the request to the contact details detailed below. Upon request, we will also provide you information about the ways in which your Personal Information is or has been used, and to whom it has been disclosed if applicable.
We will make the requested information available within 30 business days or provide written notice of an extension where additional time is required to fulfill the request. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform you of the cost and request further direction from you, on whether or not we should proceed with the request. If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and further steps as may be available to you.
We may use your Personal Information, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Services. All marketing communication is sent by us in accordance with the applicable data protection laws, including Canada’s Anti-Spam legislation (“CASL”). In cases where CASL required that sending marketing electronic messages will be carried only subject to your consent, we will seek for such consent before sending any commercial electronic messages.
At any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to the details listed below.
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Since we operate globally, it may be necessary to transfer data, including Personal Information, to our related entities, agents and third party service providers located outside of Canada, for the purposes defined in this Policy, including for the purposes of assisting us with the management and storage of its information files and for the provision of services to the Company, or for other purposes where appropriate consent has been obtained or as otherwise permitted by law. While the information resides outside of the territory of Canada, it may be accessible to the local courts, law enforcement and national security authorities in the foreign jurisdiction.
- Linked Websites
This Policy does not apply to any third party websites linked from the Website or that may provide links to the Website. Any use of such third party websites shall be governed by the privacy policies and other policies of such other websites, and NRGene accepts no responsibility for the privacy and/or security of any information you may submit to any third party websites.
We reserve the right to change this Policy at any time. The most current version will always be posted on our Website. You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
If you have questions about this Policy or concerns about how we manage your personal information, you can email us at [email protected] or write to us at:
Privacy Officer
Local Address: 101-110 Research Drive Saskatoon, SK S7N 3R3
If you have questions about privacy in British Columbia or are not satisfied with how we are handling your personal information, you may contact the Office of the Information and Privacy Commissioner for British Columbia at the following address:
Office of the Information and Privacy Commissioner for British Columbia
PO Box 9038 Stn. Prov. Govt.,
Victoria, BC, V8W 9A4