PRIVACY POLICY
OUR COMMITMENT TO PRIVACY
Last Updated: November 10th, 2023.
Medical Facilities Corporation ("MFC" or "we" or "us" or "our") is committed to protecting your Personal Information (as defined below) through ensuring that your information is treated with care and is not used or disclosed in ways to which you have not consented. This privacy policy ("Policy") explains the ways in which we collect, use and disclose your Personal Information. It applies to any Personal Information that is collected by us, whether it is collected over the telephone, in writing, or electronically.
MFC will never disclose, sell or lease to any third party any Personal Information that you provide to us, including through this website (the "Site"), without your permission, other than as described in this Policy, or unless we are required to do so by law. Notwithstanding this, this Site is hosted and administered by third parties. Accordingly, the Personal Information provided through this Site will be available to those third parties for the limited purposes of hosting and administering this Site.
By providing us with your Personal Information and using our Site you accept this Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected. If you do not consent, please do not use the Site or otherwise provide your Personal Information to us.
It is MFC's policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual's right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable.
This Policy may be amended or updated at our discretion from time to time. We include the date the Policy was last revised at the top of the page. Please check the Site from time to time for such amendments. Any modifications to this Policy will be effective upon our posting of the new Policy. In all cases, by continuing to access and use the Site, you accept and consent to the terms of the then current Policy, as amended.
WHAT IS PERSONAL INFORMATION?
"Personal Information" is any information about an identifiable individual. This includes information that we can reasonably use on its own, or with other information we have, to directly or indirectly identify an individual. Personal Information includes but is not limited to your name, address, telephone number, fax number, e-mail address, and questions or comments submitted by you on the Site.
Publicly available information, such as business contact information or a public directory listing of your name, address, telephone number or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not considered Personal Information.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We may collect the following types of Personal Information about you:
- Your contact information (such as your name, the organization you are affiliated with, your address, telephone number, fax number and email address);
- What type of investor you are; and
- Your comments and questions.
Personal Information is collected by us when you provide it to us, such as when you provide us with your contact information or send us a question or comment through the Site, when you meet with us in person, or when you phone us with an inquiry.
COLLECTION OF TECHNICAL INFORMATION
When you visit our Site, we collect certain technical information which is recorded by the standard operation of our internet servers on an anonymous basis, such as information about your device and internet connection, the operating system you are using, certain details regarding your access to and use of our Site, including the sections of the Site you visit, and the Site pages you read and the Site images you view.
This non-identifiable information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Site and system administration purposes; (ii) to improve the Site; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors' use of our Site; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary. If we can or do use your technical information to identify you, we treat such technical information as Personal Information in accordance with this Policy.
Cookies
When you view the Site, we may place a "cookie" on the hard drive of your computer which allows the Site to remember who you are. Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. Cookies provide additional functionality to websites to better match users' interests and preferences. With most Internet browsers, you can erase cookies from your computer hard drive, block the creation of cookies, or receive a warning before a cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.
Web Beacons
Our Site may use small electronic files known as web beacons. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, web beacons will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
For What Purposes Do We Collect Personal Information?
We collect and use Personal Information primarily for the purposes of:
- Responding to your communications and inquiries;
- Meeting legal, regulatory, audit, security, and financial requirements under federal and provincial laws;
- Sending individuals press releases, financial reports, marketing materials or information about scheduled events for which we have your consent to receive;
- Providing investors with information that they have requested about MFC;
- For Site and system administration purposes;
- To improve the Site;
- To conduct internal reviews of the number of visitors to the Site; and
- To protect the security or integrity of our Site when necessary.
We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information.
We will notify the individual from whom the information is collected of the purposes for which we are collecting the information. This notice will be provided at or before the time that we collect the Personal Information. Depending on the way in which Personal Information is collected, this may be done orally or in writing.
When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law.
Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.
Disclosure of your Personal Information
We may disclose Personal Information that we collect as described in this Policy with your consent for any other purpose we disclose when you provide the information or as permitted or required by applicable law. We may disclose aggregated and anonymized information, which no longer allows an individual to be directly or indirectly identified, for any serious and legitimate purpose without further notice to you or your consent, as permitted by applicable law.
We may share or disclosure your Personal Information in the following circumstances:
- Subsidiaries and Affiliates. To our subsidiaries and affiliates to provide you with the services that you consented to.
- Service Providers. To contractors, service providers, technology providers and other affiliated or third parties we use to support our business, such as Google Analytics. We contractually require these parties to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to adhere to security safeguards consistent with those described in this Policy.
- Sale or Business Transaction. In accordance with applicable law, to a buyer or other successor in the event of a proposed and completed merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer or business transaction involving all or part of our company or our assets, including for the purposes of determining whether to proceed with such transaction.
- Law Enforcement. To comply with any court order, law, or legal process, including to respond to any government or regulatory request (for example, in response to a court order, subpoena, search warrant or other lawful request for information we receive), according to applicable law.
- Enforce our Rights. To enforce our rights arising from any agreements between you and us, including our Terms of Use.
- Protect our Rights. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us or others.
Retention and Disposal of Personal Information
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.
Processing of Personal Information
Your Personal Information may be transferred, processed and/or stored outside of the jurisdiction in which it was originally collected, including outside of Canada. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. You can obtain more information about our policies and practice with respect to the use of non-Canadian service providers by contacting us as described below under the "Contact Us" heading.
Links to other Websites
Our Site may contain links that take you to other third-party websites, including websites maintained by our U.S.-based indirect subsidiaries. These third-party websites are not governed by this Policy but by other privacy policies that may differ somewhat from our Policy. This Policy does not extend to the collection of Personal Information by these third parties and MFC does not assume any responsibility for the privacy practices, policies or actions of third parties. We encourage you to review the privacy policies of each website visited before using these websites or disclosing any Personal Information to third parties.
Your Privacy Rights
Depending on the jurisdiction in which you reside, you may certain rights (including those described below) with respect to your Personal Information that we collect and process. To exercise any of your privacy rights, please contact us as set out below.
- Updating your Personal Information. We want to make sure that the information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information unless it is necessary for us to do so to fulfill the purposes for which we collected the information. Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed by contacting us in the manner set out below.
- Access to and Correction of Personal Information. If you have any questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information. You may write to or email our Privacy Officer at the address below to request access to Personal Information that we have about you. We will respond to requests within 30 days.
- Withdrawal of Consent. Where you have provided your consent to the collection, use, and disclosure of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent we may not be able to provide you with a particular service. We will explain the impact to you at the time to help you make your decision.
- Unsubscribe from Marketing & Promotional Communications. If you are receiving our marketing and promotional electronic communications, you may unsubscribe at any time by clicking on the "unsubscribe" option in any electronic marketing communication (e.g. email) you receive or by contacting us as set out below.
Questions and Further Information
We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer who is ultimately accountable for the handling of all Personal Information in our custody and/or control, and for ensuring that the principles described in this Policy are being complied with.
We make information about our privacy policies and practices readily available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, please contact our Privacy Officer at:
Privacy Officer
Medical Facilities Corporation
4576 Yonge Street, Suite 701
Toronto, Ontario M2N 6N4 Canada
Email: privacyofficer@medicalfc.com
If you have any questions about your privacy rights or complaints, you may also contact the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3 Canada
Fax: 819-994-5444
Inquiries: 1-800-282-1376