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Privacy Policy Of Liberator Communications Canada

Last Revised: February 2018

Who we are

Liberator Communications Canada (“Liberator”, “us”, “we”, “our”) is a subsidiary of the Prentke Romich Company (PRC). PRC is a manufacturer and supplier of speech generating devices which are durable medical equipment and strives to achieve the following:

Purpose and application of the policy

The purpose of this privacy policy is to describe to you, Liberator customers and other visitors to our website, how personal information about you, including personal health information, that has been provided to Liberator by you or others may be used and disclosed by us and how you can request access to and/or the correction of your personal information in our records. This policy also explains how you may contact us with questions about this policy, our privacy practices or our management of your personal information. Please review this policy carefully.

This policy applies only to Liberator and its website and does not apply to any other websites that you may be able to access from this website. 

Please note that we reserve the right to amend this policy from time to time to reflect changes in applicable law or our personal information management practices.  The date of the last amendment is provided at the top of this policy.  Please review the policy if the date indicates that it has been amended since the last time you transacted with us or visited our site as by doing so, we will understand you to be agreeing to the amendments.  For clarity, any amendments to this policy will be effective for all personal information that we maintain.

What is “personal information” and "personal health information"?

By “personal information,” we mean information about an identifiable individual.

Personal health information is a subset of personal information.  It is current, past or future information, relating to the physical or mental condition of an individual, the provision of health services to that person, or payment for the provision of health services to that person, whether created or received by Liberator from health care providers, payors or customers.  Personal health information does not generally include information available or reported in a summarized or grouped manner, such as aggregate information and statistics.  In this policy, the acronym “PHI” will be used to mean personal information and personal health information.

Liberator’s collection of PHI

Liberator only collects, uses and discloses your PHI in conformity with applicable law. When you purchase a product or service from us, fill out a form, or browse our website, you are accepting the conditions of our privacy policy which means that you are consenting to our collection, use, disclosure and storage of your PHI in accordance with this policy.

We may collect certain PHI to better serve you, including in the event you have questions about a product you have purchased from us. Examples of such PHI are: name, address, e-mail address, phone number and product serial number. Liberator will use and store PHI electronically and physically in both Canada and in the United States.

We may use your browsing activity on our website to customize the information we provide to you. Cookies are used to provide you with the best experience on our website.  A cookie is a small piece of data stored on your hard drive containing some anonymous demographic information that does not reveal your specific identity.  Examples include: zip code, time zone, user preferences, web visits, IP address, browser and device information, domain name and referring website.  

Liberator may collect PHI indirectly through interactions with your health care providers through applications, interviews, surveys, and other forms. PHI may be obtained in writing, in person, by telephone, and electronically. The information we collect varies depending on the purpose for the collection, but generally includes information needed to process a request for equipment, Liberator may collect your name, address, telephone number, date of birth, medical history, diagnoses, treatment, provider identification and treatment information, financial responsibility and payment information, and family and advocate contact information.

How does Liberator protect PHI internally?

We have policies and procedures in place to protect your PHI against unlawful access, use and disclosure. Access to PHI is restricted to only those employees who need it to provide services, products, or benefits to our customers or respond to inquiries of website visitors. We maintain physical, technical, and procedural safeguards to protect PHI against unauthorized access, use and disclosure. We have a Privacy Officer who is responsible for developing, educating Liberator personnel about, and overseeing the implementation and enforcement of our policies and procedures designed to safeguard PHI.  The contact information for our Privacy Officer is provided below.

Liberator use and disclosure of PHI

Liberator may use and/or disclose your PHI, without your consent where permitted or required by law:

For these purposes, Liberator uses PHI internally and discloses it to health care providers, insurers, third party administrators, plan sponsors and other payors, vendors, consultants, government authorities and their respective agents. Liberator maintains a “Minimum Necessary Disclosure Policy”, which means we limit the disclosure of PHI to the minimum amount necessary to accomplish the stated purpose.

Other activities permitted or required by law

Liberator respects your privacy and will not sell, rent, or loan PHI to any third party without your consent. The following may be necessary to effectively provide equipment to you:

Your right to access your PHI

Except in limited circumstances set out in the law, you have the right to obtain a copy of your PHI in our records by making a request in writing to our Privacy Officer.  If you request an electronic copy of your PHI, we will try to provide you with the PHI in the electronic form and format of your choice if it is readily available. You may be charged a fee for obtaining a copy of your PHI. 

How to request disclosure of your PHI to third parties

Many customers ask us to disclose their PHI to people in ways not described above.  For example, a customer may want us to make her records available to a neighbor who is helping her resolve a question about her care or payment for that care. You may contact our Privacy Officer to obtain a form to authorize us to disclose your PHI to a person other than you or an organization or for reasons other than those described above.

If you fill out a form and later change your mind about the special authorization, you may send a letter to us at the address listed on the form to let us know that you would like to revoke the special authorization. In any communication with us, please provide your name, address, patient or member identification number, and a telephone number where we can reach you in case we need to contact you about your request.

What other rights do you have with respect to your PHI and how can you exercise those rights?

You have a right to ask us in writing to restrict our use or disclosure of your PHI. As set out above, you may request PHI disclosure restrictions to family members, advocates or others involved in your care. Also, as set out above, we may not be able to agree to a restriction if the use or disclosure you are trying to prevent is required or permitted by law, including in the case of an emergency. For clarity, restrictions will not be effective to prevent uses or disclosures of PHI for activities permitted or required by law.

You have a right to request that we correct your PHI in our records for as long as we maintain them. You must make the request in writing to our Privacy Officer and explain the reason why the proposed correction is required.  We may deny your request if: (i) we determine that we did not create the PHI, unless the originator of the PHI is no longer available to act on the requested correction; or (ii) if we believe that the PHI is accurate and complete. Note that a correction may take several forms, for example, we may add an explanatory statement to a record of PHI rather than change it.  Where we decide we are unable to make a correction you have requested, we will add a note to that effect in your records.

You have a right to receive an accounting of disclosures of your PHI made by Liberator to any third party in the six years prior to the date on which the accounting is requested.  You may not have the right to information about disclosures made for certain purposes including but not limited to national security and law enforcement purposes. You must make any request for an accounting in writing. We may charge a fee to fill more than one request in any given year.

You have the right to request that we communicate with you about health matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to our Privacy Officer. We will not ask you the reason for your request. We will endeavor to accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

What does Liberator do with PHI of persons no longer affiliated with Liberator?

Liberator does not necessarily destroy PHI when individuals terminate their relationships with us. The information may be necessary for many of the purposes described in this policy, even after the person stops receiving services through Liberator. In many cases, PHI is subject to legal retention requirements. The policies and procedures that protect PHI against inappropriate use and disclosure will continue to apply regardless of the status of the individual to whom it relates.

How is this policy made available?

Liberator posts this policy on our website and provides a copy to individuals who have submitted equipment purchase requests upon the receipt of the submission or, upon contact with a Liberator representative for purposes of evaluation, whichever is earlier.

Liberator Communications Canada is required by law to provide individuals with notice of its privacy practices. We are required to abide by the terms of the policy currently in effect.

What should I do if I want a paper copy of this policy, if I have questions about it, or if I think my privacy rights have been violated?

If you would like a paper copy of this policy, have questions about it, or believe its terms have been violated with respect to your PHI, please let us know immediately. If you wish to file a complaint, you can write to or call us at the address and number listed below. You will not be penalized for filing a complaint.

Liberator Communications Canada Privacy Officer 
1022 Heyl Rd. 
Wooster, OH 44691 

Please include your name, address, and a telephone number where we can contact you, and a brief description of your concern. If you prefer, you may lodge an anonymous complaint.