Privacy Notice

As used in this Privacy Notice, the terms "we", "us", "our", and "Trudell" mean Trudell Medical International Inc., including Trudell Animal Health a division of Trudell Medical International Inc., and its affiliate, TMI Medical Distribution Inc. We are committed to protecting the security and privacy of all Personal Data collected by us and under our possession or control and ensuring that we conduct our business in compliance with laws on privacy, data protection and data security.

For purposes of this Notice, "Personal Data" shall mean any information relating to an identified or identifiable natural person as defined by applicable privacy legislation. This Notice is intended to comply with applicable privacy and data protection requirements in the regions where we operate. Where required by local law, including the Personal Data Protection and Electronic Documents Act ("PIPEDA") in Canada, the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA") (collectively, "CPRA"), and the General Data Protection Regulation ("GDPR") in the European Union, European Economic Area, and United Kingdom, the collection, use, and disclosure of Personal Data will be carried out in accordance with those laws.

This Notice sets out:

The types of Personal Data that we collect, including from customers, individuals visiting our website, visiting our offices, and interacting with us in the normal course of our business;
How we may process, disclose or use individuals' Personal Data;
The purposes and legal basis for our processing and use of individuals' Personal Data;
How we transfer Personal Data outside of the European Union ("EU"), Switzerland and United Kingdom ("UK"); and
Individuals' rights with respect to our processing, use or disclosure of their Personal Data.

The Types of Personal Data We Collect

We collect Personal Data when you fill out registration forms, subscribe to newsletters, order products, or provide us with other information (such as completing a survey), for processing and use in accordance with this Notice. Depending on how you use this website or our services, the Personal Data we collect from you may vary.

In the past 12 months, we have collected, used, and disclosed the following categories of Personal Data about visitors and users, in accordance with applicable privacy laws, including the GDPR and the CPRA. These categories reflect our current and recent processing activities.

This section is intended to provide transparency regarding our data practices for all users. Specific rights regarding the categories of Personal Data described below may differ based on your jurisdiction.

The categories of Personal Data we may collect include:

Identifiers such as name, company name, job title, address, phone and fax numbers, email, username, and Internet Protocol (IP) address.
Customer Records Information such as name, contact details, billing address, and payment card details (such as card number, expiration date, and security code); also includes information used to create an online account (username, password, security question and answer).
Protected Classification Characteristics include date of birth, age, gender, marital status, dependent/spousal or other family information.
Commercial Information includes purchase and customer service history - products or services purchased, obtained, or considered.
Biometric Information not typically collected unless provided (for example, if health apps enable such collection).
Internet or Other Electronic Network Activity Information includes location data (device IP address, country, and postal/zip code), browsing history and usage patterns, device information, clickstream data, and data collected through cookies, web beacons, and similar technologies.
Geolocation Data includes approximate or precise location data linked to your device or as derived from your IP address.
Sensory Data is not typically collected unless you submit audio, electronic, visual, or similar content to us (such as through video calls or voice submissions).
Professional or Employment-Related Information which includes job title, employer, company name, information obtained when interacting with us or through social networking platforms.
Non-public Education Information is not typically collected unless you submit this information in the content you provide.
Inferences Drawn from Other Personal Data such as profiles reflecting preferences, characteristics, or customer behavior, derived from the information collected about your online or purchase activity.
Sensitive Personal Data includes account login credentials, health information you may provide through affiliated apps, financial data (payment card numbers with security codes), and demographic information subject to enhanced protection, as defined in certain jurisdictions.

If you use our website to make an online purchase, your name, address and credit card information is sent directly to third-party service providers we use to manage order fulfillment and credit card processing. The service providers are not permitted to use the information you provide except for the sole purpose of order fulfillment or credit card processing on our behalf.

What device information do you collect?

Device and Browser Information: We may collect information about your computer and/or device, including device type, IP address, device identifier, and operating system. We collect this information by using cookies or similar technologies.
Location Data: If you have access to your location enabled on your mobile device, we may collect location information, including precise and imprecise location derived from your IP address.
Information and Statistics on Site Usage: We may collect technical data about your use of our Site and how you interact with digital advertisements and promotions, including content viewed or downloaded, time spent on pages, links clicked, promotional emails opened, features used, and dates and times of interactions. We collect this information using cookies and similar technologies.

How we use your Personal Data

Consistent with applicable data privacy laws, we use your Personal Data for the following reasons:

For legitimate business purposes: We use your Personal Data to: (i) deliver services or carry out transactions that you have requested; (ii) provide information about our products, services, transactions, and advertisements that may be of interest to you; and (ii) make our communications with you more relevant and personalized to you.
To comply with our legal obligations: We may be required to: (i) comply with laws, regulations, court orders, or other legal process; (ii) establish, exercise or defend legal claims; and (iii) detect, prevent and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or misuse of our Site, products or services; complying with our obligations to retain certain business records for minimum retention periods.
To process a contract to which you are a party: We may need to process your Personal Data for the purpose of fulfilling a contract or to provide a product or service you requested.
Because you have given your consent: There are times when we may need to obtain your consent to allow us to use your Personal Data for one or more purposes set out above. When we process your Personal Data in such circumstances, it will be consistent with the scope of the consent you provide us.

External Websites

Yes, our Site may contain links to other websites. You should review the Privacy Policy of the other websites that you may link to via our Site as their Privacy Policy may differ from ours. Please be aware that we are not responsible for the privacy practices of other websites.

"Do not Track" and Third Party Use

We do not respond to "do not track" signals. However, we respect your privacy and do not track your online activities or collect Personal Data based on the presence of the signal.

Third parties may collect information about your online activities over time and across different websites when you use their site. Please review the privacy policies of third-party providers for more information about their tracking practices.

Cookies and Tracking

A "cookie" is a file of information that is placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, holding items in your shopping cart, and providing you with advertisements that have been tailored to your interests. For more information on Cookies, how we use them, the third parties we work with who use them, and how you can control them, please refer to our Cookie Policy.

Google Analytics

We use Google Analytics, a web analytics tool that helps us understand how visitors engage with the Services. We obtain your specific, opt-in consent before collecting or using any data that can identify, locate, or profile you via these technologies. To learn more about how Google uses information from sites or apps that use its services, please visit https://policies.google.com/technologies/partner-sites.

Google Ads

If you consent via our cookie banner, our website uses Google Ads (formerly Google AdWords) conversion tracking and remarketing services provided by Google Ireland Limited ("Google"). Google Ads allows us to measure the effectiveness of our advertising campaigns and to display targeted ads to users who have previously interacted with our website.

Google uses cookies and similar technologies to record when users click on an ad and visit certain pages on our site (conversion tracking). Through remarketing functions, we can deliver tailored advertisements to visitors based on their preferences and browsing behavior. For these purposes, Google processes data such as IP addresses, cookie identifiers, device information, and interactions with our ads and website.

The collection and transmission of this data are carried out by Trudell and Google as joint controllers. Google is solely responsible for subsequent processing after receipt. For more information on how Google processes personal data, including the legal basis it relies on and how you can exercise your rights, please see Google's privacy policy at https://policies.google.com/privacy.

Facebook Pixel

If you consent via our cookie banner, our website uses the Facebook Pixel of Meta ("Facebook Pixel"). This allows us to track the activities of users after they have been redirected to our website by clicking on a Facebook ad. This enables us to track the performance of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.

Data collected on our website via the Facebook Pixel is transmitted to Facebook. The collection and transmission of that data is carried out by Trudell and Facebook as joint controllers.

Facebook is solely responsible for the processing of the data transmitted by the Facebook Pixel once it has been transmitted. For more information on how Facebook processes personal data, including the legal basis on which Facebook relies and how you can exercise your rights against Facebook, please see Facebook's privacy policy at https://www.facebook.com/about/privacy.

TikTok Pixel

If you consent, via our cookie banner, we use the TikTok Pixel on our website. The TikTok Pixel is a TikTok advertiser tool provided by TikTok Technology Limited ("TikTok").

The TikTok Pixel is a JavaScript code that allows us to understand and track visitors' activity on our website. The TikTok Pixel collects and processes information about the use of our website and the devices used to do so (e.g., IP address, email address, device ID, device type and operating system) ("event data"). The event data collected via the TikTok Pixel is used to better target our ads and improve personalized advertising in general. For this purpose, the event data collected via the TikTok Pixel on our website is transmitted to TikTok. TikTok uses email or other login or device information to identify users of our website on its platform and associate them with a TikTok user account. TikTok then displays targeted and personalized advertising to its users and creates interest-based user profiles. The TikTok Pixel also uses cookies to store information on the device you are using.

The collection and transmission of the event data is carried out by Trudell and TikTok as joint controllers. TikTok is solely responsible for the processing of the event data once it has been transmitted. For more information on how TikTok processes personal data, including the legal basis on which TikTok relies and how you can exercise your rights against TikTok, please see TikTok's privacy policy at https://www.tiktok.com/legal/page/eea/privacy-policy/en.

Microsoft Clarity

If you consent via our cookie banner, we use Microsoft Clarity to better understand how users interact with our website and to help us improve user experience. Clarity is a web analytics and session replay tool that collects data through cookies and similar technologies to capture information about website usage, such as pages visited, scroll activity, mouse movements, clicks, and engagement patterns. Clarity may also collect information about your device (e.g., browser type, operating system), approximate geographic location based on IP address, and technical identifiers.

The data collected may be used to generate heatmaps and session recordings, which help us analyze how users navigate and interact with the website. Microsoft Clarity does not collect sensitive data such as keystrokes in form fields, and fields designed to collect personal or sensitive information are automatically masked. The data may be stored and processed by Microsoft on our behalf in accordance with their Privacy Statement.

The legal basis for this processing, where required by applicable law, is your explicit consent. Microsoft Clarity is only activated after you have provided clear and affirmative consent through our cookie consent banner or tool. You can withdraw your consent at any time by adjusting your cookie preferences via the consent management tool or by changing your browser settings to disable cookies.

Data collected through Microsoft Clarity is retained for up to 13 months, after which it is automatically deleted. We do not use this data to identify you directly, and it is used solely for website optimization, diagnostics, and aggregated analytics purposes.

How do you share Personal Data?

We only disclose your Personal Data to third parties as follows:

Consistent with our ability to provide services to you, we use affiliated and unaffiliated service providers all over the world, including web servers, cloud storage systems, CRM providers, email services, content support teams, to help us deliver our products and services.
We may also share your data with the following affiliates of Trudell, Trudell Healthcare Solutions Inc., Trudell Medical Australia Propriety Limited, Trudell Medical UK Limited, Trudell Medical Europe Ltd. and TMI Medical Distribution Inc. (the "Affiliates"). The Affiliates will process your Personal Data where we believe it is consistent with the context in which the information was collected or with your consent.
We will disclose data If we believe in good faith such disclosure is necessary (1) to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us; (2) to enforce our Terms of Use and Privacy Policy; (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (4) as we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of Trudell, the users of our services, or third parties; or (5) as permitted under applicable laws to meet national security and similar requirements;
In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;
We will otherwise share Personal Data only with your consent.

How long do you store my information?

We keep your Personal Data only so long as we need it to provide the Site to you and fulfill the purposes described in this Policy. Retention periods can vary based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, resolution of disputes and enforce our agreements, we'll remove it from our systems.

Privacy of Minors

We do not knowingly collect Personal Data from individuals under the age of 18. To access or use the Site, you must be at least 18 years of age otherwise you may not use the Site. If you have reason to believe that a child under the age of 18 has provided us with Personal Data without parental consent, please contact us. If we become aware that a child has provided us with Personal Data without parental consent, we will remove such information.

Data Transfers

Some of the services we provide are hosted and provided outside of the European Economic Area (EEA), including Canada and the United States, for the purposes described in this Policy. If you are an EEA resident and we transfer your Personal Data outside of the EEA, we will only do so for the purposes described in this Policy and in accordance with applicable data privacy laws. This shall include either (i) ensuring that the recipient country has an adequate level of data protection laws (and provide a similar degree of protection to the EEA/UK); or (ii) including standard clauses approved by the European Commission/UK Information Commissioner's Office in our transfer contracts.

For residents of Quebec, before any international data transfer, we conduct a Privacy Impact Assessment to ensure that the destination jurisdiction provides an adequate level of protection for your Personal Information. In jurisdictions where the protection is not equivalent to that of Quebec, your explicit consent is required. Consent is obtained through clear, separate opt-in mechanisms on this website, such as cookie banners or consent forms.

You may withdraw your consent at any time by adjusting your cookie preferences or contacting us directly. Withdrawing consent may limit your ability to access certain features or services.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data.

Who controls my data?

Trudell is the controller of your Personal Data.

The information about you that we collect, process and use/or use through the Site is controlled by Trudell and some of the services it provides are hosted and provided outside of the European Economic Area (EEA), including Canada and the United States, for the purposes described in this Policy. Privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.

What are my rights?

Depending on your region, you have rights under applicable privacy laws which may include:

Right to Be Informed:

You have the right to ask us whether we process your Personal Data and if we do, you have the right to request access to your Personal Data that we process, together with the following information: (i) the purposes of the processing; (ii) the categories of Personal Data we process; (iii) the recipients of your Personal Data; (iv) the anticipated retention period of your data where possible, or the criteria used to determine the retention period; (v) your right to request rectification or erasure of your Personal Data, or restriction of the processing of such data; (vi) your right to file a complaint with a supervisory authority; and (vii) whether we use your Personal Data to make automated decisions that have legal or other similar effects on you.

If you are subject to an automated decision, you have the right to request meaningful human review and to contest the decision.

Right to Rectification:

You have the right to request correction of your Personal Data if such information is inaccurate. If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided under the "How to Contact Us" section of this privacy policy.

Right to Erasure:

You have the right to request deletion of your Personal Data if (i) the Personal Data is no longer necessary for the purpose it was originally collected or processed; (ii) if we process your information on the basis of consent, and you withdraw your consent; (iii) if we process your Personal Data for our legitimate business interest and you object, and there is no overriding legitimate interest to continue this processing; (iv) if we have processed your Personal Data unlawfully; (v) the deletion is legally required.

We are not required to erase your Personal Data to the extent that we need to process it: (i) to exercise the right of freedom of expression and information; (ii) to comply with a legal obligation; (iii) for the performance of a task carried out in the public interest or in the exercise of official authority; or (iv) for the establishment, exercise of defense of legal claims.

Withdrawal of Consent:

If you have given us consent to use your Personal Data as described in this Privacy Policy, your consent can be withdrawn by you at any time by contacting us using the contact details provided under the How to Contact Us section below. In the case you withdraw your consent, the use of your information until then remains legal. After you have withdrawn your consent, your Personal Data may continue to be used, as far as this is legally permissible as listed above.

Right to Restrict Processing:

You may request that we restrict processing your Personal Data in the following circumstances: (i) when you contest the accuracy of your Personal Data, for the period of time we need to verify the accuracy of your Personal Data; (ii) when the Personal Data has been unlawfully processed and you oppose the erasure of it, but instead request that we restrict the use of the Personal Data; (iii) when we no longer need the Personal Data, but you need us to keep it in order to establish, exercise or defend a legal claim; or (iv) if you object to the processing of your Personal Data for our legitimate business interests, for the period of time we need to verify whether our legitimate grounds override yours interests.

Right to Data Portability:

You have the right to receive Personal Data you provided to us when: (i) the processing of the Personal Data is based on your consent or is necessary for the performance of a contract between you and us; and (ii) the processing of your Personal Data is carried out by automated means.

Right to Object:

You have the right to object to the processing of your Personal Data if it is for direct marketing purposes or to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing materials (such as postal marketing or telemarketing), you may by contacting us using the details provided under the "How to Contact Us" section.

Right to File Complaint with Local Data Protection Authority:

We will use our best efforts to address and settle any requests or complaints brought to our attention. In addition, you have the right to complain to your local data protection authority if your privacy rights are violated.

Right to Object to Profiling and Automated Decision-Making:

If we use your Personal Data for profiling or automated decision-making, you have the right to object and request that such processing be reviewed by a human.

Right to File a Complaint:

We encourage you to contact us first to resolve any concerns. If you remain unsatisfied, you may file a complaint with your local data protection authority, including the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec, or with the appropriate supervisory authority in your region.

If you would like to exercise your rights regarding your Personal Data, you can exercise these rights by contacting us using the details provided under the "How to Contact Us" section.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within thirty (30) days. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolution of disputes and enforce our agreements.

Your Consumer Rights as a California Consumer

The CPRA entitles California residents to certain rights. If our processing of your Personal Data is subject to the CPRA, you are entitled to the following rights:

Right to Access/Know. You have the right to request what Personal Data we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort. You may only make a request for access twice within a 12-month period.
Right to Deletion. You have the right to request the deletion of your Personal Data that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
Right to Correct. You have the right to correct inaccurate Personal Data that we collect or maintain.
Right to Opt Out of Sale/Sharing. Except as otherwise provided herein, we do not sell Personal Data or share this information with third parties for targeted advertising purposes.
Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt out, correct, or limit use of sensitive Personal Data under the CPRA.
Right to Limit Use of Sensitive Personal Data. You have the right to limit the use of your sensitive Personal Data when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number (or country-specific equivalent), driver's license number, biometric information, precise geolocation, and racial and ethnic origin.

To exercise your privacy rights, you may submit a request by contacting us at privacy@trudellmed.com. To opt out of the sale or sharing of your Personal Data via cookies, please visit Do Not Sell My Personal Information or utilize the opt out preference signal to instruct us to not sell or share any of your Personal Data collected online. The opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings.

You must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the Personal Data and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

Only you, or a person that you authorize to act on your behalf may make a request related to your Personal Data. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

Rights of Nevada Residents

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your Personal Data. You may submit a request to opt-out of future sales by contacting us at privacy@trudellmed.com regarding the sale of such information. Please include "Opt-Out Request Under Nevada Law" in the subject line of your message.

How to Contact Us

By email: privacy@trudellmed.com

By mail: 725 Baransway Drive, London, Ontario N5V 5G4

By fax: 519-455-9053

If your questions, concerns, or complaints have not been resolved to your satisfaction, you may contact our Privacy Officer by emailing privacy@trudellmed.com.

Updates to Our Privacy Policy

We may revise this Policy from time to time by posting an updated version on the Site, along with information on any material changes. The revised Policy will be effective immediately and any modifications will apply only to the Personal Data we collect after the posting. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Site is subject to the most current effective version of this Policy.

Last Updated: November 14, 2025