Privacy Officer Statement

The Personal Information Protection and Electronic Documents Act (PIPEDA) is the federal privacy law for private-sector organizations. It sets out the ground rules for how businesses must handle personal information in the course of their commercial activity. The policies set forth below are for Ava Industries business activities. The Privacy and Security policies for Ava Electronic Medical Record is maintained under the protection of the Medical Custodian and corresponding Health Information Acts.

It is the policy of Ava Industries Inc. to maintain the confidentiality of all information concerning clients, staff and volunteers. Personal information is given to us in trust. It is mandatory that the information remains confidential. It is important that information not circulate outside of Ava Industries Inc. in an unauthorized manner, and it also should not pass between staff for reasons other than appropriate consultations. Ava Industries Inc. recognizes the dignity and self-worth of every person and their right to a safe, secure and trusting care environment. The client has the right to considerate and respectful care. The client also has the right to decision making affecting his/her health and welfare. Purpose The purpose of this protocol is to eliminate the incidence of inappropriate collection, use and disclosure of client, staff and volunteer information, both inside and outside of Ava Industries Inc. The purpose is not to prohibit the discussion of client and employee information by professional staff for legitimate reasons.

Policy

1. Privacy Policy Overview
   1. This Privacy Policy establishes rules to govern the collection, use and disclosure of personal information collected by Ava Industries in compliance with federal and provincial privacy laws including the Canada Personal Information Protection and Electronic Documents Act (PIPEDA), Ontario’s Personal Health Information Protection Act (PHIPA), Alberta’s Health Information Act (HIA), British Columbia’s Personal Information Protection Act respecting the protection of personal information in the private sector.
   2. This Privacy Policy applies to all individuals whose personal information Ava Industries collects, uses or discloses in the course of doing business. It is our policy to only disclose your personal information as required or authorized by law or as otherwise set out in this policy.
   3. We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: www.avaindustries.com. If the changes are significant, we will provide a more prominent notice.
2. Personal Information
   1. For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual. Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to be examples and not exhaustive or exclusive.
   2. This Privacy Policy applies to all personal information that is collected, used or disclosed by Ava Industries. Ava Industries has designated a Privacy Officer to be accountable for the operation of this Privacy Policy. Individuals may question or report any privacy concerns, breaches, violations or compliance issues to Ava Industries’ Privacy Officer at the address indicated below.
   3. If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact the Ava Industries Privacy Officer for guidance or clarification.
3. Personal Information We Collect
   1. Ava Industries collects and uses only the personal information that we need for offering services and operating our business. This pertains to our Website, not the licensed EMR software. Generally, Ava Industries collects the following personal information from individuals for the various purposes set out below:
      1. Name
      2. Address, jurisdiction of residence or both
      3. Email address
      4. Telephone number, including mobile telephone number
   2. Ava Industries collects, uses and discloses personal information for the following
      purposes:
      1. To confirm your identity and personal information
      2. To manage Ava Industries business and operations, including customer relationships and matters, and to meet legal and regulatory requirements
      3. Inform individuals about Ava Industries products and services that we believe may be of interest to them
      4. Better understand an individual’s interests in our products and services.
      5. Deliver, develop, enhance or improve products and services.
      6. Verify access rights to our website
      7. Meet regulatory requirements
      8. Conduct market research
      9. To enforce our legal relationship with you
   3. We normally collect information directly from you. We may collect your information from other persons with your consent or as authorized by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.
   4. We also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best.
   5. Finally, your Internet browser has a feature called “cookies,” which stores small amounts of data on your computer about your visit to our site. Cookies tell us nothing about who you are, however, unless you specifically give us personal information. You do not need to have cookies turned on to visit https://www.avaindustries.ca/ . You may also elect not to allow cookies to be collected by selecting certain options on your browser.
4. Consent
   1. Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.
   2. You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfill our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
5. Collection of Personal Information
   1. The purpose for collecting personal information is set out in this policy. Any necessary consent shall be obtained before personal information is collected, used or disclosed.
   2. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).
   3. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent electronically by clicking a button. We may rely on “opt-out” consent for certain types of information.
   4. Please note that we may use cloud-based services to store information. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.
6. Sharing of Personal Information
   1. Your information may be made available by Ava Industries to third-parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. Ava Industries will not sell, rent or trade your personal information to any third party. However, we may share your personal information when authorized by law or as follows:
      1. Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. Ava Industries will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and adequate security procedures.
      2. As permitted or required by law. From time to time, Ava Industries may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. In these circumstances, Ava Industries will protect the interests of its customers by making reasonable efforts to ensure that orders or demands comply with the laws under which they were issued, that it discloses only the personal information that is legally required and nothing more, and that it does not comply with casual requests for personal information from government or law enforcement authorities. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
      3. Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
7. Obtaining Access to Personal Information
   1. Upon request received by Ava Industries in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by Ava Industries should be directed to the Ava Industries Privacy Officer.
   2. Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only.
   3. Ava Industries responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.
   4. A fee for reasonable costs incurred may be charged when responding to more complex requests, if authorized by law. The individual will be informed of the applicable fee.
   5. Requested information will be provided in a form that is generally understandable.
   6. Ava Industries will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual.
   7. Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from Ava Industries, individuals wishing to view an original record will do so at Ava Industries head office and under the supervision of designated Ava Industries personnel.
8. Limitation to Access
   1. Ava Industries will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.
   2. In the event that Ava Industries refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Ava Industries will respond to your requests for access in accordance with applicable privacy legislation.
9. Maintenance of Personal Information
   1. Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.
   2. Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by Ava Industries and have it amended as appropriate.
   3. Individuals seeking a correction or amendment to their personal information should direct their requests in writing to the Ava Industries Privacy Officer.
   4. All formal requests to amend personal information must be accompanied by appropriate supporting documentation. The Ava Industries Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.
   5. If the individual is not satisfied with the results of the request, Ava Industries shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.
10. Security of Personal Information
    1. Personal information will be retained only as long as necessary and as required by applicable legislation and securities regulations and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.
    2. Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.
    3. We will notify the Office of the Information and Privacy Commissioner of Alberta, and any other Privacy Commissioners as required, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals or as required under applicable laws.
11. Challenging Compliance
    1. Inquiries or complaints concerning compliance with this Privacy Policy should be addressed, in writing, to the Ava Industries Privacy Officer.
    2. If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
12. Questions and Complaints
    1. If you have a question or concern about any collection, use or disclosure of personal information by Ava Industries, or would like to request access to your own personal information, please contact the Ava Industries Privacy Officer.