privacy
 Cobalt Medical Solutions Ltd.

Website Privacy Policy


This Privacy Policy outlines Cobalt Medical Solutions Ltd. ("we", "our" or "the Company") practices with respect to information collected from Users who access our Site at https://cobaltmedicalsolutions.com ("Site"), or otherwise share personal information with us (collectively: "Users"). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are or may be subject too.

We always respect our Users privacy and safeguard their personal information and have strengthened our commitment to protecting personal information as a result of Alberta’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how Alberta businesses may collect, use and disclose personal information.

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

Scope of this Policy 

This Personal Information Protection Policy applies to Cobalt Medical Solutions Ltd.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Cobalt Medical Solutions Ltd..

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 


What information we collect on our Site

We collect two types of data and information from Users.

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
Survey Information: When you participate in a survey on our Site you may be required to submit information such as age, income, rankings, feedback and other requirements to provide the information required out of the survey.
Contest Information: When you participate in a contest, we may request additional information as part of the contest entry requirements. This could include age, income, rankings, feedback and other requirements.
Program Information: From time to time, we introduce temporary or permanent programs, such as a birthday club, where you may be required to provide additional information such as age so we can professionally deliver on the program promises.
Registration information: When you register to our Site you will be asked to provide certain details such as: full name; e-mail or physical address, and other information.  

How we receive information about you

We receive your Personal Information from various sources:

When you voluntarily provide us your personal details in order to register on our Site;
When you use or access our Site in connection with your use of our services;
From third party providers, services and public registers (for example, traffic analytics vendors).

What information do we collect?
Your privacy is important to us. We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a Site assigns to your device while you are viewing a Site. Cookies are helpful and can be used for various purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier.

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly, and your online experience may be limited.

We also use tools like “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often Users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected using Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics and other programs about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

Policy 1 – Collecting Personal Information

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

1.2 We will only collect Site Users information that is necessary to fulfill some or all of the following purposes: 

To verify identity;
To identify Site Users preferences;
To open and manage an account;
To deliver requested products and services
To guarantee a reservation;
To provide a donation receipt (if eligible and required);
To enrol Site Users in a program;
To send out membership information;
To contact our Site Users for fundraising; 
To ensure a high standard of service to our Site Users; 
To meet regulatory requirements; 
To collect and process payments for goods and services

1.3 In addition to the different uses listed above, we may transfer or disclose Personal Information to our subcontractors.

1.4 In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be in different jurisdictions across the world, for any of the following purposes: 

Hosting and operating our Site;
Providing you with our services, including providing a personalized display of our Site;
Storing and processing such information on our behalf; 
Providing you with marketing offers and promotional materials related to our Site services; 
Performing research, technical diagnostics, or analytics;

Policy 2 – Consent

2.1 We will obtain Site Users 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, through an authorized representative, in writing or orally or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the Site Users voluntarily provide personal information for that purpose. 

2.3 Consent may also be implied where a Site User is given notice and a reasonable opportunity to opt-out of their personal information being used for mail-outs, the marketing of new services or products, fundraising and the Site User 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), and Site Users can withhold or withdraw their consent for Cobalt Medical Solutions Ltd. to use their personal information in certain ways. A User's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service, product or offer. If so, we will explain the situation to assist Site Users in making the decision. 

2.5 We may collect, use or disclose personal information without the Site Users 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 personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as: 

Conducting Site Users surveys to enhance the provision of our services, provide entertainment, gather user generated content;
Contacting our Site Users directly about products and services that may be of interest;
Contacting our Site Users about a contest and winners;
Contacting our Site Users about unique offers and promotions

3.2 We will not use or disclose Site Users personal information for any additional purpose unless we obtain consent to do so. 

3.3 We will not sell Site Users lists or personal information to other parties unless we have consent from our Site Users to do so. 

Policy 4 – Retaining Personal Information

4.1 If we use Site Users personal information to make a decision that directly affects the Site Users, we will retain that 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 taking 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.

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

4.3. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications, and anything else as required by applicable laws and regulations.

4.4 We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that Site Users' personal information is accurate and complete where it may be used to make a decision about the Site Users or disclosed to another organization. 

5.2 Site Users 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. A request to correct personal information should be forwarded to the Privacy Officer or designated individual.

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 Site Users correction request in the file. 

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of Site Users' 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 personal information is appropriately protected: 

The use of Site Users ID’s, passwords, encryption, firewalls
Restricting access to only persons who need to know
In the case of printed material, the use of locked filing cabinets, securing rooms where the personal information is held.
Require any service providers to provide comparable security measures.

6.3 We will use appropriate security measures when destroying personal information such as:

Deleting electronically stored information
Properly destroying physical drives so they cannot be operated
Confidentially shredding printed documents

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

6.4 Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse of our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Policy 7 – Providing Site Users Access to Personal Information

7.1 Site Users have a right to access their personal information, subject to limited exceptions including;

the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
the disclosure would reveal personal information about another individual;
the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.
the information is protected by solicitor-client privilege;
the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;
the information was collected or disclosed without consent, as allowed under section 12 or 18, for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;
the information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act:

  • under a collective agreement, under an enactment, or by a court.
  • the information is in a document that is subject to a solicitor's lien.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer or designated individual. 

7.3 Upon request, we will also tell Site Users how we use their personal information and to whom it has been disclosed if applicable. You may request to:

  • Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
  • Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
  • Request rectification of your personal information that is in our control.
  • Request erasure of your personal information.
  • Object to the processing of personal information by us.
  • Request to restrict processing of your personal information by us.
  • Lodge a complaint with a supervisory authority.

7.4 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. 

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the Site User of the cost and request further direction from the Site User on whether or not we should proceed with the request. 

7.6 If a request is refused in full or in part, we will notify the Site User in writing, providing the reasons for refusal and the recourse available to the Site User. 

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or designated individual is responsible for ensuring Cobalt Medical Solutions Ltd. compliance with this policy and the Personal Information Protection Act. 

8.2 Site Users should direct any complaints, concerns or questions regarding Cobalt Medical Solutions Ltd. compliance in writing to the Privacy Officer or designated individual. If the Privacy Officer or designated individual is unable to resolve the concern, the Site User may also write to the Information and Privacy Commissioner of Alberta. 

Contact information for Cobalt Medical Solutions Ltd. Privacy Officer or designated individual:

Ron Kitsul
Cobalt Medical Solutions Ltd.
722 Oakhill Pl SW,
Calgary, AB, T2V 3X9

Ph: 403-386-2363
Email: info@cobaltmedicalsolutions.com 

Policy 9 – Processing of Site Users Information

9.1 The Data Controller or others designated by the Data Controller processes the data of Site Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

9.2 The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

9.3. In addition to the Data Controller, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the Site ands App administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the owner. The updated list of these parties may be requested from the Data Controller at any time.

Policy 10 – Third Party Platforms and Services

10.1 Access to third party services' accounts, location-based interactions, content commenting and interaction with external social networks and platforms can be included in our Site.

10.2. Users on our Site may interact with social media platforms including Facebook, Instagram, YouTube, Tumblr, TikTok, Twitter, Snapchat, LinkedIn and other social media platforms that are currently available or new social media platforms that may come online in the future. The services allow interaction with social networks or other external platforms directly from the pages of our Site. The interaction and information obtained by the Site are always subject to the Users privacy settings for each social network. If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.

10.4 We may use various links to display information within the Site. Site Users should refer to the displayed information Sites to understand their privacy policies which may differ from ours.

Policy 11 – Content Posting and Commenting

11.1 Content commenting services allow Site Users to make and publish their comments on the contents of this application. Depending on the settings chosen by the owner, Site Users may also leave anonymous comments.

11.2 If there is an email address among the personal data provided by the Site Users, it may be used to send notifications of comments on the same content, including content that may be offensive or contradicts our privacy and contesting policies.

11.3 Site Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Site Users do not use the content commenting service.

Policy 12 – Additional Information About Data Collection and Processing

12.1 The personal data may be used for legal purposes by the Data Controller or others designated by the Data Controller, in court or in the stages leading to possible legal action arising from improper use of this application or the related services.

12.2 The Site Users are aware of the fact that the Data Controller may be required to reveal personal data upon request of public authorities.

12.3 The Site does not support “Do Not Track” requests.

12.4 To determine whether any of the third-party services the Site uses honor the “Do Not Track” requests, please read their privacy policies.

12.5 The Data Controller or anyone designated by the Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a Site user objects to any of the changes to the policy, the Site user must cease using the Site and can request that the Data Controller or anyone designated by the data controller erase the personal data. Unless stated otherwise, the then-current privacy policy applies to all personal data the Data Controller has about Site Users.

Last updated November 22, 2021
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