Privacy Policy
Please Read Carefully
Last Updated: August 1, 2021
This Privacy Policy explains how Thornhill Research Inc. and its respective subsidiaries and affiliates (collectively “Thornhill,” “we,” or “us”) collect and use personal information provided through our websites, however accessed (the “Site”). “Personal information” means information about an identifiable individual (sometimes called “your information”). By using our Site or otherwise providing your personal information to us, you agree to our handling of personal information as set out in this Policy.
- This Policy applies globally, but we have included additional information below for residents of the European Economic Area, the United Kingdom, Switzerland and California.
This Policy does not apply to deidentified, anonymous or business contact information.
Personal Information We Collect and Use
Information You Provide Us
We collect the personal information you provide us, such as when you create an account, fill out a form, request products or services, or contact us. This information usually includes contact information like your name, address, email and phone number. It may also include account and demographic information, information about your product selections, and any other information you choose to provide.
We Use This Information To:
- Deliver our products and services as requested.
- Operate our business and improve our products and services.
- Identify and authenticate you.
- Communicate with you about our products or services, and provide you with information about them that may be of interest to you.
- Analyze and improve the functionality of our Site.
- Protect the rights, property and safety of Thornhill, our employees, or other stakeholders.
- Prevent, detect, or investigate security concerns and illegal activity including fraud.
- Comply with applicable laws, regulations, or industry requirements.
When You Visit Our Site
We use a number of cookies and analytics tools that collect personal information when you visit the Site or consent to receiving our marketing emails. When you visit the Site, this includes information about how you use the Site, information about your device and browser, your IP address and the web pages you visited before and after visiting the Site.
We Use This Information To:
- Communicate with you about our products or services, and provide you with information about them that may be of interest to you.
- Present relevant advertisements and share promotional events.
- Analyze and improve the functionality of our Site and marketing efforts.
- Improve our products, services, and business.
- Protect the rights, property and safety of Thornhill, our employees, or other stakeholders.
For further information on these tools, how they collect your information and your control over them, see “Cookies and Web Analytics” below.
When You Apply for a Position at Thornhill
If you apply for a position with us, we collect the information you provide us as well as information from third parties, including websites and references. In some cases, we may also perform criminal record checks.
We do not knowingly collect personal data from children. If we become aware that we have personal data of children, whether through error, deception, or fraud, we will delete the data unless there is a legal and justifiable reason to retain such data.
When and Why We Share Personal Information
We may share your information to deliver our products or services or to enhance your customer experience. More specifically, we share your information with third parties in the following circumstances:
- With third party service providers who perform functions on our behalf, such as website hosting, marketing, product and service delivery, or analytics services.
- With business partners where it is relevant to a potential or actual business transaction, such as the sale of part or all of Thornhill, a merger, acquisition or corporate reorganization.
- To prevent, detect, or investigate security concerns or illegal activity including fraud.
- Protect the rights, property and safety of Thornhill, our employees, or other stakeholders.
- To comply with applicable laws, regulations, or industry requirements.
We do not sell your personal information to third parties.
Getting and Withdrawing Your Consent
We only collect information by lawful means. As part of using our products and services or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes identified or as otherwise permitted or required by law. In compliance with our privacy obligations, we may obtain your permission through this Policy or through other means (such as express verbal or written consent). However, in some situations, the law allows us to collect, use or disclose personal information without your consent.
You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so. You may withdraw your consent by contacting the Privacy Officer (see Contact Us below) and, subject to any legal constraints, we will comply with your request.
Cookies and Web Analytics
Cookies
We may use “cookies” and similar technologies such as web beacons, clear gifs and embedded scripts on this Site. Cookies are essentially small packages of data stored on your internet browser that tell us about your browsing behaviour on this Site and sometimes other sites. We use both session and persistent Cookies. We also use both first- and third-party Cookies. We use that information to monitor usage of our website and improve it, enable certain Site functions and perform analytics. We may also use this information to improve our marketing and deliver advertisements to you.
Many web browsers provide the capability to configure your cookie settings including disabling or deleting them. Please note that if you choose to block all cookies, you may not be able to access or use all or parts of our website and/or parts of our Site may not function properly.
For more information on cookies and how to manage them, check the support pages for your browser or AllAboutCookies.org. For more information on the development of user profiles and the use of targeting Cookies, please see DAA WebChoices in the United States and EDAA Online Choices if you are located in Europe.
Google Marketing Platform and Google Analytics
We use a variety of the tools available through the Google Marketing Platform, including Google Analytics and Google Tag Manager, to collect information about use of this Site across devices and pages. These tools provide us with information on user behaviour on the Site and allow us to advertise to users after they leave the Site.
Google Analytics uses the data collected through cookies to track and examine the use of the website, to prepare reports on its activities, and share them with other Google services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network (including ads that we may buy). For more information on how Google uses this data and how to control the information collected by websites. You can also opt out of Google Analytics by visiting Google Analytics Opt-out.
Third-Party Advertising Pixels
We use advertising pixels from third parties to obtain on user behaviour on the Site and to allow us to advertise to users after they leave the Site. These third parties include Facebook, Twitter, and LinkedIn. More information on our use of Facebook Pixel is included below.
We use Facebook Pixel cookies to better understand your use of our website. Facebook Pixel collects information on user behaviour on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. Facebook uses the data collected through cookies to track and examine the use of the website, to prepare reports on its activities, and share them with other Facebook services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Facebook may provide us with information associated with your Facebook account, such as your likes, location and age (Facebook may provide us with additional information if you use Facebook to create an account with us). Facebook may use the data collected on the websites to contextualize and personalize the ads of its own advertising network. For more, information on how to limit the data Facebook Pixel shares and uses about you. You can read more about how Facebook Pixel works from Facebook’s Data Policy (see “Information from partners”).
Do-Not-Track Requests
Because of the rapidly changing state of technology, we cannot make any guarantees that our systems will be able to honour Do-Not-Track requests sent by your browser.
Security
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. We utilize industry standard storage and protection procedures in order to safeguard personal information on servers which are not accessible to the public. No data storage or transmission plan is without risk. We cannot guarantee the security of your personal information transmitted to our Site.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
International Transfer and Storage
Some of our service providers and business partners may be based outside of Canada. This means your information may be accessible to law enforcement authorities outside of your jurisdiction, in accordance with the laws of that jurisdiction.
Retention
We only keep your information as long as it is operationally or legally necessary. After that, we will either destroy or anonymize your information.
Access and Control of Your Information
Accessing Your Information
To request to access, correct or delete your personal information, submit a written request to the address provided below under Contact Us. Ensure that the request identifies yourself, the information you want to review, and how we can contact you. We may not be able to fulfill your entire request, depending on the circumstances, and there may be a charge for copies of your personal information.
Correcting Your Information
We will make reasonable efforts to keep your information current and accurate. If a change or correction is required, let us know right away. We will make any appropriate updates needed. You can review your personal information by accessing your account, reviewing the correspondence we send to you, or by requesting access to your personal information, as described above.
Additional Information for European Residents
Basis for Lawful Processing
European data protection laws require us to be specific about our reasons or grounds for using your personal information. Thornhill processes the personal information of individuals located in the European Economic Area, Switzerland and the UK on these grounds:
- Consent. When you have provided your consent to our collection of your information;
- Service performance. When we need to perform the service you have requested or have agreed to through contract;
- Legitimate interests. When we have a legitimate business or commercial reason for using your information, and your interests and your fundamental rights do not override those interests; and/or
- Legal obligation. When we need to comply with a legal or regulatory obligation.
We may process your personal information on more than one ground depending on the reason or grounds for using your personal information. Please contact us if you need details about the specific grounds we are relying on to process your personal information.
Data Subject Rights
In addition to the abilities to access, correct and delete personal information as described above, European residents may also be entitled, depending on the circumstances, to one or both of the following rights:
- Restrict processing. The right to request that we limit or cease the processing of your information.
- Portability. The right to request that we transfer your information that we have collected to another organization or directly to you.
In order to exercise these rights, contact our Privacy Officer using the contact information outlined below.
Additional Information for California Residents
If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.
- You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
- You can ask us to delete your personal information.
- You can ask that we stop selling your personal information (although as noted we do not currently sell personal information to third parties.)
In order to exercise these rights, contact our Privacy Officer using the contact information outlined below.
In accordance with California law, we also confirm that in the preceding twelve months, Thornhill Medical has disclosed the following categories of personal information for a business purpose:
- Category A: certain Identifiers.
- Category B: certain California Customer Records personal information categories.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
In the preceding twelve (12) months, Thornhill has not sold personal information. We do not disclose your Personal Information to third parties for their direct marketing purposes.
Contact Us
Please contact us if you:
- Have any comments, questions or complaints about this Privacy Policy or our handling of personal information.
- Would like to request access to your personal information.
- Want to correct or delete to your personal information.
We can be contacted in writing at:
Attention: Data Privacy
Email: privacy@thornhillmedical.com
Address: Thornhill Medical
60 Wingold Ave
Toronto, ON, M6B 1P5, Canada
Thornhill will respond to your question, inquiry, request or complaint within a reasonable timeframe – typically within thirty days, except where required by law to respond sooner. Depending on the circumstances, there may be operational or legal limitations on the degree to which we can fulfill certain requests or respond to certain inquiries.
Changes to This Privacy Policy
We reserve the right to change or revise this Privacy Policy at any time to reflect changes in the law or our data collection and use practices. Privacy policy changes will apply to the information collected from the date we post our revised privacy policy, as well as to existing information we hold. The date the privacy policy was last revised is identified at the top of the page. Your continued use of this Site after we make changes is deemed to be acceptance of those changes.
