1. Important introductory information

1.1 This Privacy Policy describes how Woodford Surgical Sales the appointed Distributor of EIDO products in Canada (“EIDO”) will process your personal Information. 

1.2 EIDO respects your privacy and is committed to protecting your personal information. 

1.3 All personal information that we process relating to you, will be handled in line with all applicable data protection laws. 

1.4 Our products, services, publications and websites are not intended for children, and we do not knowingly process personal information relating to children.

1.5 It is important that you read this privacy notice together with any other privacy notice we may provide to you from time to time so that you are fully aware of how and why we will use your personal information.

1.6 If you have any questions or concerns about the information set out in this privacy notice or how EIDO processes your personal information please contact our Data Protection Officer using the contact details set out in paragraph 1.7 below. 

1.7 The table below provides various information about EIDO, including details of how you can contact us, and our Data Protection Officer (DPO) 

Company name	EIDO Canada
Registration number	88206 5303
Address	114 Woodman Road Wolfville Nova Scotia  B4P 2M5
Data Protection Officer contact details	[email protected]

2. What personal information will we process about you?

2.1 We may collect, use, store and transfer different kinds of personal information about you depending on how we interact with you and the purposes we hold your personal information for. The types of personal information we might hold about you can be grouped together as follows:

2.1.1 Identity Data including first name, last name, job title or similar identifiers such as the organisation you work for or the area of your specialism.

2.1.2 Contact Data including postal address, email address and telephone numbers.

2.1.3 Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.

2.1.4 Usage Data including information about how you use our website, publications, products and services.

2.1.5 Marketing and Communications Data including your preferences in receiving marketing from us, your communication preferences, and information regarding your use of, and responses to, our marketing.

2.1.6 Transaction Data including details of our relationship with you, about your enquiry, request or complaint or any other information relating to the purpose you have contacted us for. 

3. How do we collect your personal information?

3.1 We may collect your personal information in several ways including:

Direct interactions

3.2 You may give us your Identity Data, Contact Data, Transaction Data, and/or Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

3.2.1 submit an enquiry about our products/services. 

3.2.2 subscribe to our newsletter or publications.

3.2.3 request a copy of our Annual Consent Review or another publication. 

3.2.4 request marketing materials to be sent to you.

3.2.5 take part in a competition, survey or promotion.

3.2.6 give us your personal information at any event, meeting, exhibition we attend.

3.2.7 give us feedback or contact us regarding our products/services or request support when using our website products or services.

3.2.8 communicate with us whether by phone, email, social media or otherwise.

Third parties and publicly available sources

3.3 We may receive personal data about you from various third parties as set out below:

3.3.1 Technical Data from analytics providers, such as Google. 

3.3.2 Identity Data and Contact Data from data brokers or aggregators.

3.3.3 Identity Data and Contact Data from publicly available sources, such as Linkedin.

4. How we use your personal information?

4.1 We will only use your personal information for purposes and in ways that are fair and lawful and generally only when you consent whether expressly or impliedly. 

4.2 We have set out below, in a table format, a description of all the ways we will use your personal information. 

Purpose/Activity	Type of personal data
To process your request for a copy of our Annual Consent Review or other publications	Identity Data Contact Data
To process and respond to your general enquiry or to provide support to you	Identity Data Contact Data
To send you marketing material in relation to our products/services which may be of interest to you	Identity Data Contact Data Usage Data Marketing and Communications Data
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy notice or reminding you when your service is due to expire. Asking you to send us feedback or take a survey. Taking payments from you.	Identity Data Contact Data Usage Data Marketing and Communications Data
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Identity Data Contact Data Usage Data Marketing and Communications Data
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Data Contact Data Usage Data Marketing and Communications Data

5. Marketing

5.1 We strive to provide you with choices and will only use your personal information when we have your consent. You can also ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at [email protected].

6. Third party marketing

6.1 We do not share your personal information with any third parties for their own marketing purposes.

7. Change of purpose

7.1 We will only use your personal information for the purposes for which we collected it and which we have notified to you, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We can only use your personal information for the purpose for which it was obtained or for a consistent use with that purpose.

7.2 If we need to use your personal information for an unrelated purpose, we will notify you and either ask for your consent or notify you (depending on which is most appropriate) we will explain the legal basis which allows us to do so. 

7.3 Please note however that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

8. Disclosure

8.1 We may share your personal information with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal information) above. 

8.1.1 Other members of staff in the same group of companies as EIDO from time to time to ensure the efficient operation of each member of the group and where appropriate to ensure that our services work properly.

8.1.2 External third parties such as:

8.1.2.1 service providers who provide IT, system administration and support services, developers cloud service providers and payment service providers.

8.1.2.2 professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

8.1.3 Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice. 

8.2 We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. 

8.3 Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

9. Where in the world do, we transfer your personal information to?

9.1 Some of the third parties we share your personal information with are based outside Canada. As a result, your personal information will be transferred to, or accessed from, other than Canada such as the United Kingdom, countries in the European Union and the United States of America.

9.2 Whenever we transfer your personal information out of Canada, we ensure that equivalent protection is in place to protect it. 

10. How do we keep your personal information secure?

10.1 We have put in place appropriate security measures to prevent your personal information from being accidentally or inadvertently lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know it and who are bound by strict obligations of confidentiality.

10.2 We have put in place procedures to detect and respond to any suspected or known personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

11. How long do we keep your personal information for?

11.1 We will only keep your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 

11.2 To determine the appropriate retention period for personal information, we consider the purpose(s) for which your personal information was collected, the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your personal information and whether we can achieve those purposes without handling your personal information at all. We also consider where applicable legal, regulatory, tax, accounting or other requirements. 

11.3 In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) so that we then use it for research and/or statistical purposes, in which case we may use this information indefinitely without further notice to you.