Privacy Policy
Effective Date: 01 January 2020

INTRODUCTION:

Welcome to Verto Inc., an Ontario, Canada corporation having its registered address at:

1903-59 East Liberty Street 
Toronto, Ontario
M6K 3R1

Verto Inc. (referred to in this Policy as “us”, “we”, “our”, or “Company”) operates Verto.ca and GoVerto.com website domains, Vertoflow.com, VertoEngage.com, Vertohub.com, RightPathflow.com, and MindMergeApp.com web portals, MindMerge Application Software and Verto Flow mobile application software (hereinafter referred to as “Service(s)”).

Verto Inc. is committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) about our customers and the information they provide while utilizing our services. The Company strives to support our customers with our services while respecting your privacy expectations and protecting your Personal Information (the “Privacy Expectations”). To demonstrate our commitment to protecting your Privacy Expectations, we have developed this privacy policy (“Privacy Policy”), which describes how we will collect, use, disclose and protect your Personal Information through your use our services. This Privacy Policy aims at satisfying the requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the General Data Protection Regulation (“GDPR”), the Personal Health Information Protection Act (“PHIPA”) and the Health Insurance Portability and Accountability Act (“HIPAA”).

Our Privacy Policy governs your visit to our services and explains how we collect, safeguard and disclose information that results from your use of our Service. Our Term of Use(“Terms”) govern use of our service and together with the Privacy Policy constitutes your agreement with us.

We may use your data to provide and improve our service. By using our service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

PERSONAL INFORMATION COLLECTION:

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally Identifiable Information (PII) may include, but is not limited to: a) Email address, b) First name and last name, c) Phone number, d) Address, State/Province, ZIP/Postal code, City, e) Cookies and usage data.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Registration may be required for using some of our services. As part of this registration, we may require that you submit certain information that is relevant to the purposes of the Service. As such, in addition to the above PII, registration information may include, but is not limited to: a) profession, b) hospital affiliations, c) username and password. Once a business has registered, access shall be granted to a group of users within the facility and control of that business, including but not limited to doctors, physicians and employees of the business.

Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (i.e. IP address), browser type, browser version, language and time zone preferences, operating system, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use: 

       a. Session Cookies: We use Session Cookies to operate our Service.
       b. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
       c. Security Cookies: We use Security Cookies for only securing your login sessions
       d. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be                   relevant to you and your interests.

We may implement other third-party analytics services that use cookies. We will ensure that no personally identifiable information is included in those cookies. If the use of cookies by any service provider differs materially from the practices already listed, we will revise this policy accordingly and notify existing customers of the change(s).

Other Data
You may send electronic information or physical documentation to us in the following forms: messages or transaction information relating to your interactions with your clients and/or patients in accordance with PHIPA and HIPAA requirements, receipts, personal data in text and picture form; and other subscriber-generated content provided to us in the normal course of your use of service, including but not limited to posts, profiles, comments, suggestions, forwarded messages, feedback information, usage information, transaction information and traffic data (as defined below).

USE AND DISCLOSURE OF PERSONAL INFORMATION:

General use
The Company will not use or disclose Personal Information for purposes other than the identified purposes of the Service. We may use your Personal Information (defined above) for various purposes:

• to provide and maintain our Service;
• to notify you about changes to our Service;
• to allow you to participate in interactive features of our Service when you choose to do so;
• to provide customer service and support, administrative messages, resolve disputes, and troubleshoot        problems including helping third-party service providers fulfil their functions;
• to gather analysis or valuable information so that we can improve our Service;
• to monitor the usage of our Service;
• to detect, prevent and address technical and security issues;
• to fulfill any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you      and us, including for billing and collection;
• to provide you with notices about your account and/or subscription, including expiration and renewal          notices, email-instructions, etc.;
• to provide you with news, special offers and general information about other goods, services and events      which we offer that are similar to those that you have already purchased or enquired about unless you        have opted not to receive such information;
• in any other way we may describe when you provide the information;
• for any other purpose with your consent;
• to enforce our Terms of Use; and
• to comply with any legal or regulatory requirements.

Third-party disclosure
We may share Personal Information or feedback with affiliates, third-party vendors, consultants and other service providers who work for us. We may share your first name and comments or feedback with third-parties. We will not tie any other information, other than your first name, that can identify you to your comments or feedback. However, third-parties may be able to tell who you are from your comments, particularly if you provide your full name or your contact information in the comments.

Surveys
From time to time, the Company may offer you the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for those contests, giveaways or promotions. From time to time, the Company may also ask you to participate in surveys designed to help us improve the Service. Any Personal Information provided to the Company in connection with any survey will be used only in relation to that survey and as elsewhere set forth in this Policy.

Acquisition of the Company
In the event that the Company, or all or a portion of our business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, your Personal Information shall be one of the transferred assets.

Retaining Information
Unless otherwise specified in a Statement of Work (“SOW”) or other contract, we may retain your personal information while you have an account with us and thereafter for as long as we need it for purposes not prohibited by applicable laws and subject to the provisions in our Terms. This data may be retained for ten (10) years from creation (the “Archival Term”). If you require your Personal Information or other content loaded into the Service (the “Client Data”) to be retained for any period following the Archival Term, there must be a new contract explicitly stating such time, in accordance with the Master License Agreement. Local backups will be retained for a period of six (6) months.

Legally compelled disclosures
Notwithstanding the foregoing, the Company reserves the right (and you authorize the Company) to share or disclose your Personal Information when the Company determines, at its sole discretion, that the disclosure of such information is necessary or appropriate:

to enforce our rights against you or in connection with a breach by you of this Privacy Policy or the Terms of Use;
to investigate or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others;
to prevent prohibited or illegal activities; or
when required by any applicable law, rule, regulation, subpoena, or other legal process.

USE AND DISCLOSURE OF NON-PERSONAL INFORMATION:
The Company may keep track of the web sites and pages our customers visit within our Service, in order to determine what services are the most popular. This data may be used to deliver customized content and advertising within the Service to customers whose behavior indicates that they are interested in a particular subject area.

We may share with third-parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, for example, or how many users clicked on a particular advertisement. Such information does not identify you individually.

DISCLOSURE OF PAYMENT CARD INFORMATION:
To use certain services, we may require credit or debit card account information. By submitting your credit or debit card account information to us, you expressly consent to sharing of your information with third-party payment processors, other third-party service providers, and applicable businesses.

DATA RETENTION:
Businesses may terminate their account by providing written notice through the Service or by email to support@goverto.com. After 90 days of receiving and acknowledging a termination request, or immediately after we terminate our relationship with you, the business profile, including all offered promotions, will be removed from the Service, but we may retain information about you for the purposes authorized under this Privacy Policy and our Terms unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal and contractual obligations.

SECURITY MEASURES:
We take your privacy very seriously. Our security measures strive to adhere to PIPEDA, GDPR, PHIPA and HIPAA requirements when conducting our work as a Health Information Network Provider and Electronic Service Provider, as well as with the best practices of health care providers. To keep your Personal Information secure, you are required to safeguard your user name and password information in accordance with the Terms of Use.

In order to keep the Personal Information secure, we restrict unauthorized access through protective policies, procedures, and technical measures, including but not limited to:

providing reasonable physical and electronic safeguards with regard to the storage of Personal Information as set out in the Master License Agreement;
limiting access to your Personal Information to those employees or contractors who we reasonably believe need to come into contact with that information to provide products or services to you or in order to do their jobs; and governing employees and other contractors by strict standards and policies to ensure that Personal Information is secure and treated with the utmost care and respect.
Please note that no data transmission over the internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect your Personal Information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

If you have a security related concern, please contact us at the contact details provided below. We will work closely with you to ensure a quick and personal response to your concerns.

CONSENT AND PRIVACY SETTINGS:
By using the Service, you consent to the collection, use and disclosure of your Personal Information by us in the manner described in this Privacy Policy. You may always opt not to disclose certain Personal Information, but which may restrict access certain features of the Service. For example, your name and email address are necessary to complete the registration process. At any time after registration, you may opt out of most email communication from us by clicking on the opt-out link at the bottom of our emails, or by contacting us at the contact details listed above. However, we may still contact you for administrative and technical purposes. Withdrawing consent will not apply to actions the Company has already taken based on your prior consent.

By providing your phone number, businesses expressly consent to receive direct dial calls, from Verto Inc. for any urgent and administrative issues. When you sign up for an account, you are opting in to receive emails and notifications from the Service itself and/or other users of the Service.

ACCURACY OF INFORMATION AND INDIVIDUAL ACCESS:
We rely on you to ensure that the Personal Information you enter into the Service is as accurate, complete and up-to-date as necessary for the purposes for which it is intended to be used. You may make changes or corrections to your Personal Information at any time. You may review or update your personal information by clicking your settings tab in your business dashboard or in the menu located within your personal profile.

When updating your personal information, we may ask you to verify your identity before we can act on your request. Unless required by law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical. Where we can provide information access and correction, and when required by law, we will do so for free.

We make every effort to ensure the accuracy of the information in our reports, displays, articles and support queries. However, you must verify all information created from your use of the Service. We recommend that you consult a professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk. You are responsible for ensuring that the information you have entered into our system is accurate, reliable and complete.

MERCHANT’S ACCESS FOR YOUR EMPLOYEES OR CONTRACTORS:
If you are a Merchant, in order for you to use certain features of the Service, you may be required to provide Personal Information relating to your employees, agents, contractors and representatives (“Company Representatives”) from time to time. You acknowledge, and represent to us that you will not share your subscriber identification, and that your Company Representatives shall register for their own subscriber accounts on our Service. You agree to indemnify and hold us harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from your disclosure to us of Personal Information relating to your Company Representatives to enable us to set up a user account for such Company Representatives.

OUR THIRD-PARTY SERVICE PROVIDERS:
We may share your Personal Information with service providers who help us to run our operations or to otherwise fulfill your request or as required by law. Our service providers are restricted from using your Personal Information in any way other than for the service they are providing. We ensure that such third parties maintain reasonable and appropriate safeguards and we utilize our best efforts to ensure they sign confidentiality agreements or have similar confidentiality requirements included in their standard agreement.

You own your data in accordance with the rules for subscriber-generated content set out in the Terms of Use and can download your own data via the Service at any time.

BUSINESS TRANSFERS:
We may share information from or about you with subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honour this Privacy Policy.

LINKS TO OTHER SITES:
Links to sites controlled or operated outside of our domain (each individually a “Third-party Site” and collectively the “Third-Party Sites”) are provided as a convenience to you only and do not imply an endorsement by us of a Third-Party Site or the company it purports to represent. We do not assume any responsibility for information and materials found on, or the privacy practices of, a Third-Party Site. This Privacy Policy does not apply to a Third-Party Site.

DISCLAIMER:
IF YOU CHOOSE TO ACCESS THE SERVICE, YOU DO SO AT YOUR OWN RISK, AND ARE RESPONSIBLE FOR COMPLYING WITH ALL LOCAL LAWS, RULES AND REGULATIONS. WE MAY LIMIT THE AVAILABILITY OF THE SERVICE, IN WHOLE OR IN PART, TO ANY PERSON, GEOGRAPHIC AREA AND/OR JURISDICTION WE CHOOSE, AT ANY TIME AND IN OUR SOLE DISCRETION. OUR PRIVACY POLICY DOES NOT COVER THE INFORMATION PRACTICES OF OTHER COMPANIES AND ORGANIZATIONS WHO ADVERTISE OUR SERVICES, AND WHO MAY USE COOKIES, PIXEL TAGS, AND OTHER TECHNOLOGIES TO SERVE AND OFFER RELEVANT ADVERTISEMENTS.

NOTIFICATIONS:
In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we may notify you by the email address registered to your account.

We will never send email messages to customers requesting confidential information such as passwords, credit card numbers, or social security or social insurance numbers. Please do not act on any such emails as you may compromise your Personal Information by replying or by following links to a fraudulent website.

MISCELLANEOUS:
If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for convenient reference only and are not to affect the interpretation of this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY:
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US:
If you have any questions about this Privacy Policy, please contact us:
By email: privacy@goverto.com

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you can contact the Privacy Commissioner of Canada at:
112 Kent Street,
Ottawa Ontario, K1A 1H3
1.800.282.1376
http://www.priv.gc.ca/ 

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