Our collection, use and disclosure of personal information
In most cases, we collect personal information directly from you when you purchase, register for or interact with us for our Services. In some cases, it may be optional for you to create an account, or consent to the collection, use or disclosure of your personal information, in order to access our Services across various platforms. In some cases, we may collect personal information from a third party with your consent or as otherwise permitted by law. We will typically identify to you the purposes for which we may collect, use and disclose your personal information at the time that we collect such information. In general terms, such purposes include:
- To deliver Services to you which you have requested or signed up for;
- To establish and manage your subscriptions and accounts with us;
- To respond to your requests, questions and inquiries;
- To advise you of information, products and services which may be of interest to you;
- To meet our legal obligations and as permitted by law.
Below we describe in more detail how we collect, use and disclose information for certain Services.
Automatically Collected Information
Some information concerning your use of the Services will be collected automatically as you use them, for example:
- Internet Protocol (“IP”) address used to connect your computer to the Internet;
- Computer, device and connection information, such as browser type and version, operating system, mobile platform and unique device identifier (“UDID”) and other technical identifiers;
- Location information for location-aware Services to provide you with more relevant content for where you are in the world.
We collect and use this information to generate aggregate/non-identifiable information in order to further develop, provide and manage the Services and for research purposes.
When you sign up for a Subscription (e.g., Complete Concussion Management Inc. newsletter, courses, webinars, etc.), you are required to provide your name and email address. This information is used to deliver information to your email address, contact you and administer your Subscription, and enable you to log in to manage your subscription.
We may also ask for additional, optional, information, which is not required to participate in the Subscription service, for example, address and profession/occupation. We collect and use this information in order to gain a better understanding of our subscribers to improve our Services, and to generate aggregate/non-identifiable demographic information. To opt out of such use, please do not provide the optional information, or you may contact our Privacy Officer at any time as indicated below.
Applications (‘apps’) and location information
When you download our location-enabled app (e.g., which provides localized clinic information based on the location of your device), you will normally be prompted to either permit or deny the app to use location information from your device. You will be assigned a Primary Clinic based on your geographic location and/or the affiliation of any sports team for which you or your child or your ward are associated that will assist in conducting your concussion care.
If you deny permission for the app to use location services, the portions of the app that rely on location information will not function. If you permit the app to use location services, we may periodically collect information about the location of your device. We may use this information to customize content and the Services, to allow us to adapt the Services to your needs, to research the effectiveness of our network and to develop new features and Services.
Mobile device identifiers
A mobile device identifier is an anonymous identifier of your cell phone. The identifier information is sent back to Complete Concussion Management Inc. along with other data such as the precise location of your phone if you have enabled location information in the app as you use our app or browse the web. The data does not identify you personally. We may share non-identified identifiers with third parties for advertising use, analytics, to ensure you receive a better consumer experience, in order to better understand our users in general and to guide our product improvements.
You can limit the range of data that your phone sends to us by disabling the identifier on your mobile device. This will not affect how your device operates. Details about mobile device identifiers and how to disable/reset the identifier for your specific device can be found at https://support.apple.com/en-us/HT202074 and http://www.ghacks.net/2015/04/20/how-to-reset-your-advertising-id-on-android/.
When you submit an inquiry using our online forms, we request your name and email address, along with the comment or inquiry for the purpose of acting on the information and responding to you. This information may be shared with persons outside of Complete Concussion Management Inc. as required to respond.
Retaining and safeguarding personal information
We will take steps to retain personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. For our continuing education courses, we will take steps to retain personal information for a period of 5 years (minimum) and as long as necessary afterwards to fulfill the purpose for which it was collected and as permitted or required by law. We have implemented physical, organizational, contractual and technological measures designed to help protect your personal information from loss or theft, and unauthorized access, disclosure, copying, use or modification. However, complete confidentiality and security is not possible or guaranteed. For example, internet use and communication is subject to potential interception, loss and alteration. You acknowledge and agree that Complete Concussion Management Inc., its affiliates and related companies shall not be responsible for any damages you may suffer as a result of the transmission of confidential or sensitive information in relation to the Services.
Where we store your personal information
The data that we collect from you is stored in Canada. However, non-identifiable information that we share with third parties may be stored in a location outside of Canada. By submitting your personal data, allowing us to collect your personal data or using the Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
Links to other websites and services
The Services may contain links to other websites and services, or be available only in connection with certain third parties and their websites, apps or services (e.g. social media providers). Complete Concussion Management Inc. is not responsible for the content or privacy practices of such third parties, or the information disclosed to them, and encourages you to review the privacy policies of such websites, apps and services.
Questions, complaints and requesting access to personal information
If you have any questions or complaints about privacy, or to request access or correction to your personal information, please submit a written request to us by mail or email at:
Attention: Privacy Officer
Complete Concussion Management Inc.
2655 Bristol Circle, Oakville, ON, Canada, L6H 7W1
Please note that if your request concerns your personal health information, we may refer you to your Primary Clinic.
Additional Privacy Documentation
A privacy breach constitutes any theft, loss or unauthorized collection, use or disclosure of personal health information. All breaches are investigated by the Privacy Officer in collaboration with the relevant business units, and IT personnel if required, with mitigating strategies and recommendations identified and implemented in order to prevent future breaches from occurring.
Click here for more information about the process for identification, reporting, notification, containment, investigation, and remediation of privacy incidents including privacy breaches, suspected privacy breaches, privacy complaints, and privacy inquiries.
It is vital to our company that our information, in all forms, be protected from unauthorized use, modification, loss, or copying. Click here to view the document sets out the default standards which must be met to ensure that control.
Complete Concussion Management is a private full-service concussion management organization that is committed to providing the highest level of concussion care around the world. CCMI understands the importance of and is committed to respecting privacy, safeguarding confidential information and ensuring the security of PHI within its custody or control. Click here to review how CCMI meets this commitment through its Privacy Program.
CCMI has also created this frequently asked questions (FAQs) document to give patients and their families information about the services and safeguards CCMI employs with respect to our web-based EMR system called the CCMI Concussion Database System.