Safe Harbor Statement

Safe Harbor Standards

This Safe Harbor Privacy Statement (the “Statement”) sets forth the privacy principles followed by Medgate America Corp. (“Medgate”) in connection with the transfer and protection of “Personal Information” received from Switzerland.

To learn more about the US-Swiss Safe Harbor program, and to view our certification, please visit the official Safe Harbor website

About The Safe Harbor

We self-certify compliance with Safe Harbor Standards

The “Safe Harbor” program (the “U.S.-Swiss Safe Harbor Framework”) was jointly established in 2009 by the Department of Commerce and the Swiss Federal Data Protection and Information Commissioner, as a method of for transferring Personal Information from Switzerland to companies in the United States. The program is a voluntary self-certification processes for companies operating in the United States. Companies that certify to the programs represent that they are upholding privacy standards for Personal Information received from Switzerland that have been accepted by the Swiss Federal Data Protection and Information Commissioner and the US Department of Commerce. These standards exceed current US privacy standards. Medgate has certified its compliance with the Safe Harbor Framework.

“Personal Information” means information that can directly or indirectly lead to the identification of a living person, such as an individual’s name, address, e-mail, telephone number, license number, medical identification number, photograph, or other identifying characteristic. The identification can occur by reference to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural or social identity. Personal Information does not include information that has been anonymized, encoded or otherwise stripped of its identifiers, or information that is publicly available, unless combined with other non-public personal information.

Scope

This Statement governs Personal Information transferred from Switzerland to the United States on behalf of Medgate. It applies to Personal Information in electronic and off-line formats.

Safe Harbor Privacy Principles

The following privacy principles apply to the transfer, collection, use or disclosure of Personal Information from Switzerland by Medgate. Notice: Medgate informs individuals in Switzerland about the purposes for which it collects and uses their Personal Information, how to contact Medgate, the types of third parties with which Medgate shares their Personal Information, and the choice and means Medgate offers for limiting the use and disclosure of their Personal Information.

Consistent with the Safe Harbor requirements, Medgate may not be in a position to furnish notice in certain limited situations. Specifically, notice is not required where the processing of Swiss Personal Information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect Medgate’ legal interests and providing notice would interfere with those interests.

Choice: Medgate will not process Personal Information about Swiss individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents (“opt-in”) to the processing, or unless an exception applies. Medgate also provides Swiss individuals with the opportunity to withdraw consent at any time (“opt-out”), in which case their Personal Information will not be further processed.

Data Integrity: Medgate seeks to ensure that any Personal Information held about Swiss individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. Medgate collects Personal Information that is adequate, relevant and not excessive for the purposes for which it is to be processed. Swiss individuals have a responsibility to assist Medgate in maintaining accurate, complete and current Personal Information about them.

Transfers To Third Parties: Medgate will only transfer Personal Information about Swiss individuals to third-parties where the third-party (a) has provided satisfactory assurances to Medgate that it will protect the information consistently with this Statement; or (b) is located in Switzerland or a country considered “adequate” for privacy by the Swiss Commission, and therefore is required to comply with Swiss data protection laws or substantially equivalent privacy laws depending upon where the Personal Information originated; or (c) the third-party has also certified to the Safe Harbor, and is accordingly independently responsible for complying with the Safe Harbor requirements.

Where Medgate has knowledge that a third-party to whom it has provided Swiss Personal Information is processing that information in a manner contrary to this Statement or the Safe Harbor requirements, Medgate will take reasonable steps to prevent or stop the processing.

Access and Correction: Upon written request to Medgate, Medgate will provide Swiss individuals with reasonable access to their Personal Information. Medgate will also take reasonable steps to allow Swiss individuals to review their information for the purposes of correcting their information. There are certain limitations to the Access and Correction rights, as set forth in the US Department of Commerce’s Safe Harbor website. Security: Medgate takes reasonable precautions to protect Swiss Personal Information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Enforcement: Medgate has established internal mechanisms to verify its ongoing adherence to this Statement. Medgate also encourages individuals covered by this Statement to raise any concerns about our processing of their Personal Information by contacting the appropriate Medgate officer at the address below or by contacting their local privacy officer or Legal Department. Medgate will seek to resolve any concerns.

Limitation On Scope Of Principles: Adherence to these Privacy Principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

Contact Information:

Medgate America Corp.

c/o Medgate Inc.

250 Bloor Street East

9th Floor

Toronto, Ontario

Canada M4W 1E5

attn: Chief Security Officer

1 800 276 9120


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