Privacy & Security

Personal Information Protection Policy

In we are committed to providing our clients, customer and vendors with excellent and personal service.  By providing this service, it involves the collection, use and disclosure of some personal information about our clients, customers and vendors. Our main goal is protecting their personal information is one of our highest priorities.

We respect and protect our clients, customers and vendors privacy and safeguarded their personal or business information.

We will inform our clients, customers and vendors of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with HIPAA, outlines the principles and practices we will follow in protecting clients, customers and vendors personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients, customers and vendors personal and business information and allowing our clients, customers and vendors to request access to, and correction of, their personal information.

Scope of this Policy 

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of our company.


Personal Information –means information about an identifiable individual. For example, name, address, phone number, credit card information for payments, information for credit checks.

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy.


Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the client, customer or vendor voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client, customer and vendor information that is necessary to fulfill the following purposes:

  • To identify customer to obtain order information
  • To open and manage an account;
  • To deliver requested products and services
  • To contact our clients, customers or vendors;
  • To ensure a high standard of service to our clients, customers or vendors
  • To process an order with credit card information
  • To process a payment to a vendor

 Policy 2 – Consent

2.1 We will obtain client, customer, vendor consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided electronically, or orally or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer or vendor voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a client, customer or vendor is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, marketing information that he wants information about, and the client, customer or vendor does not opt-out.

2.4  Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, customers, vendors can withhold or withdraw their consent for our company use their personal information in certain ways.  A client, customer, vendor’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the client, customer, vendor in making the decision.

2.5  We may collect, use or disclose personal information without the clients, customers or vendors knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law
  • In an emergency that threatens an individual's life, health, or personal security;
  • When the personal information is available from a public source (e.g., a telephone directory);
  • When we require legal advice from a lawyer;
  • For the purposes of collecting a debt;
  • To protect ourselves from fraud;
  • To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose client, customer or vendor personal or business information where necessary to fulfill the purposes identified at the time of collection or for a purpose related to:

  • To conduct client, customer, vendor surveys in order to enhance the provision of our services
  • To contact our clients, customers or vendors directly about products and services that may be of interest
  • Vendor information will never be disclosed

3.2 We will not use or disclose client, customer or vendor personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client, customer or vendor lists or personal information to other parties unless we have the consent to do so.

Policy 4 – Retaining Personal Information

4.1 If we use client, customer or vendor personal or business information to make a decision that directly affects the client, customer or vendor, we will retain that personal information for at least one year so that the client, customer or vendor has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client, customer or vendor personal or business information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client, customer, or vendor personal information is accurate and complete where it may be used to make a decision about the client, customer, vendor or disclosed to another organization. We will never disclose vendor information.

5.2 Clients, Customers, Vendors may request correction to their 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.

5.3 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 the clients’, customers’, correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client, customer, member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client, customer, member personal information is appropriately protected:

We use locked filing cabinets; we physically securing offices where personal information is held; we apply 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.

6.3 We will use appropriate security measures when destroying client’s, customer’s, member’s personal information such as:  shredding documents and deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

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