At Preventia Technologies Canada, we are committed to protecting your privacy.
Preventia’s Ten Privacy Principles
Personal information is information that can be used to identify or contact you individually, and other information that Preventia needs to provide you with the products and services you have requested. Personal information we collect typically includes your name, general location and the elements of your medical history and related conditions you input withing the COVID Risk APP. Under certain circumstances, an IP address and IMEI number of your device may be considered personal information.
Principle 1 – Accountability
Preventia may on occasion use outside companies, called third parties, to help us provide our products or services to you. Regardless of where these third parties are located, we require that they also comply with PIPEDA and with Preventia’s Privacy Principles.
Principle 2 – Identifying Purposes
You have a right to know how your information will be used. Preventia will explain why we need your information before or when we collect it, if the purpose is not already clear. We will assume that the purpose is clearly identified when we use your personal information to:
- Ensure the App’s algorithms are presented with all necessary data to help you obtain an adequate risk stratification result, including using your general location (based on the postal code you will provide and without using the GPS location feature of your device) to generate infectious heat maps;
- If you choose to enable this option within the App by entering your Employer’s unique code, allow your Employer to analyze and review the relevant data to their management of your risk stratification result;
- Ensure that you are properly enrolled to use our products and services and to receive any associated technical support; and
- Inform you of any important product revisions or updates.
If relevant, Preventia will also collect log information that includes your IP address and your device’s IMEI number and the time that you access our service. This information is stored in log files and is used for security, to improve performance and for aggregated and statistical reporting. This log information is not linked to personal information gathered elsewhere on the Website.
Preventia may also use your personal information for secondary purposes such as:
- Further refining the App’s algorithms by exposing it to additional data;
- Letting you and/or your Employer know about new or upgraded Preventia products and services;
- Providing anonymized, aggregate-level data to universities, research institutes and government institutions to help them refine and/or design their public health response, and;
- Inviting you to participate in patient surveys or other opinion-gathering devices.
Aggregate data is general information about groups of patients and/or Employers, and does not identify individuals. Preventia may combine your information with that of other patients or Employers to generate aggregate data that can be used to improve our products and services or develop new ones. For example, we may tell a third party how many patients and/or Employers have enrolled to a particular service, but not identify that you personally are an enrolled patient.
Preventia will not disclose your personal information to any third parties without your consent, except under the following limited circumstances:
- As is reasonably required to fulfill your service or product requirements, provided such third parties shall be bound to appropriate privacy requirements;
- To comply with a legal process such as a law, regulation, search warrant, subpoena, court order or law enforcement request;
- To resolve a contractual dispute regarding your and/or an Employer’s use of any Preventia product or service;
- To resolve issues related to the use of your account for illegal activities; or
Principle 3 – Consent
You control any future secondary use of your personal information, such as sharing it with marketers. You can prevent future secondary use of your information by “opting out” when Preventia collects your information or at any time by simply contacting us. Opting out only applies to the secondary purposes because we may need to contact you regarding the usability of our services or notify you of important product revisions or updates. To change your privacy preferences, please go to the App’s “Profile” section under the “Privacy” tab.
Principle 4 – Limiting Collection
Preventia will collect personal information only for the purposes we have identified or for the primary uses described above. We shall collect information by fair and lawful means only. We will collect personal information in the following circumstances:
- When you subscribe to use our services, whether free or through a paid subscription;
- When you input personal information within the App after subscribing to use our services, whether free or through a paid subscription;
- When you provide payment information for use with a paid subscription;
- When you contact Preventia to request information;
We will mark as optional any question we ask that seeks information that is not necessary to provide you and/or your Employer with the Preventia product or service you and/or they request.
Preventia uses “cookies” to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your e-mail address or identity. We may use “persistent cookies” to save your registration ID and login password for future logins to our service. We may use “session cookies” to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. You can change your browser options to stop accepting cookies or to prompt for your permission before accepting cookies. Choosing to decline cookies may affect your access to our products and services.
The App does include links to third-party Web sites. These third-party Web sites may assign different cookies to you. Those cookies may be used to track your involvement with the advertising site. You may choose not to accept these cookies. Preventia does not control these parties, and you should review their privacy policies to learn more about what, why and how they collect and use personal information.
Principle 5 – Limiting Use, Disclosure, and Retention
Preventia will not use or disclose your personal information other than for the purposes for which it was collected unless we receive your consent or unless we are required or permitted to by law. The content of the files stored on our service is encrypted and only you and/or your Employer can decrypt it. When providing information in response to a legal inquiry or order, we will verify its validity and disclose only the information that is legally required. Preventia will make reasonable efforts, within the bounds of the law, to notify you should your personal information be subject to disclosure.
Preventia will follow internally set guidelines and use reasonable care in the disposal, destruction, or de-identification of personal information to prevent unauthorized parties from gaining access to such information. As stated above, Preventia will, however, keep anonymized, aggregate level data and make it available to universities, research institutes and government institutions to help them refine and/or design their public health response.
Principle 6 – Accuracy
Preventia will maintain accurate, complete and up-to-date personal information as required for the identified purposes associated with its collection. Please let Preventia know if your contact or other personal information changes. To update your personal information, please go to the App and log into your account’s profile section.
Principle 7 – Safeguards
Preventia protects the personal information in our possession and control by using security safeguards appropriate to the sensitivity of the information. We work to protect personal information from loss, misuse and unauthorized alteration using industry-recognized security safeguards. We restrict internal access to personal information to select members of our team. When you and/or your Employer use our service, Preventia asks for the creation of a password. You and/or your Employer will need your password to access any files stored on our service.
YOU AND YOUR EMPLOYER MUST SAFEGUARD YOUR RESPECTIVE PASSWORD AND KEYS. Passwords and keys are not stored on the App. Consequently, should you or your Employer lose or forget these, we cannot provide these or reset your passwords. Should a connecting device be lost or become inoperative, you and/or your Employer may log in to your account on the App and deselect the affected device(s) .
We will maintain a record of every breach of security safeguards involving personal information under our control. We will notify you and your Employer of any breach of our security safeguards involving your personal information if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you.
Principle 8 – Openness
When you email Preventia a request or concern, the Privacy Officer or somebody designated on the Officer’s behalf, will review your email and will respond within a reasonable period of time that should not excess thirty (30) days.
Principle 9 – Individual Access
Upon your written request, and subject to exceptions as permitted or mandated by law, Preventia will inform you of the existence, use and disclosure of your personal information and will give you access to the information. You may challenge the accuracy and completeness of your information and have it amended as appropriate.
Principle 10 – Challenging Compliance
Preventia maintains procedures for addressing and responding to all inquiries or complaints from patients and/or Employers about Preventia’s handling of personal information. We will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures.
Our Privacy Officer and staff working at the Officer’s direction may seek external advice where appropriate before providing a final response to individual complaints.
Preventia shall investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending its policies and procedures.
For More Information
We appreciate hearing any comments, questions or concerns that you may have about our policies, practices and customer service. Please contact our Privacy Office at firstname.lastname@example.org