What is personal information? What is personal health information? “Personal information” means information about an identifiable individual, including information that can be used alone or with other information to identify, contact or locate a single person. “Personal health information” means, for our purposes only (i.e. this is not a comprehensive definition), identifying information about an individual that relates to the physical or mental health of the individual and to the providing of health care to the individual. This Policy applies to information we collect, use or disclose about you, as follows: On https://evika.io/ and/or through the application located at https://app.evika.io/; In e-mail, text and other electronic messages with you (together with the above, the “Site”); and When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this Policy.
What information do we collect? We collect and use several types of information from and about you, including:
Personal information, such as your (or the recipient of a gift’s) name, mailing address, e-mail address, telephone number, year of birth, Internet protocol (IP address), gender, profession and user name or other similar identifier; Sensitive personal information, such as your billing and account information, including credit card and/or debit card information, but only if you are purchasing products or service through our Site; Sensitive personal health information, such as your weight, height, diagnosis, year of diagnosis, type of care you receive, type of housing, and physical abilities (e.g. vision, hearing, mobility) and how they vary over time and under different circumstances; Non-personal information (i.e. information that does not directly or indirectly reveal your identity), such as demographic information, or statistical or aggregated information. This information may sometimes be derived from personal information, including sensitive personal information; Technical information, such as your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your Internet connection, the equipment you use to access our Site and usage details; and Non-personal details about your interactions with the Site, such as clickstream to/through/from our Site (including dates and times), products or services you view or search for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from page(s), and any phone number(s) used to contact us.
How do we use your information? We use information that we collect about you or that you provide to us, including any personal information and personal health information: To present the Site and its contents to you, and permit you to use our Site and any of its features; To provide you with information about products or services that you may wish to purchase from third parties; To enable you to register for an account through the Site, and to provide you with notices about your account; To fulfill any purpose for which you have provided information that has been described to you at the time of collection, or for any other purpose with your prior consent; To carry out our obligations and enforce our rights arising from any contracts with you, or to comply with legal requirements; To notify you about changes to our Site or any products or services we offer, provide or display though it; To improve our Site, products and services, marketing, or customer relationships and experiences, including personalizing your Site experience by delivering the type of content and product and service offerings in which you are most interested; and To communicate with you (always with appropriate consent).
Please note that by submitting your credit card and/or debit card information through the Site, you expressly consent to the sharing of this information with our Payment Partner (as defined in the Terms). Our Payment Partner will collect, store, and process your credit card, debit card and other payment information on our behalf using industry-standard security measures. We do not store any payment and/or credit information, except for the last 4 digits of your credit card number for ease of reference if you wish to make a purchase in the future and select a card to use, however our Payment Partner may store payment and/or credit information. We assume no responsibility or liability whatsoever with respect to such information in the event of a breach of confidentiality or security.
As mentioned above, we collect certain sensitive information about your diagnosis and/or disability. We use this information, together with any additional information or input you may provide, to help third parties make decisions about how to best support and improve the global ecosystem for assistive devices. These third parties may include service or product providers, insurance agencies or government organizations. The information will help their determinations of how to best develop, improve and fund assistive devices and medical equipment. We also help introduce third party sellers of assistive devices and medical equipment to the Ontario and wider Canadian markets.
We may also use the information we have collected to enable us to measure or understand the effectiveness of the advertisements we display to you and others, and to deliver relevant advertising to you and other users concerning products and services that may be of interest to you. If you have opted-in to receive them, we may send you periodic e-mail communications. If you would no longer like to receive all or part of these communications, you may always opt-out by using the unsubscribe mechanism at the bottom of our e-mail communications or e-mail communications sent on our behalf, by adjusting your user preferences through your account on our Site, by checking or unchecking (depending on the circumstances) the relevant box located on the form where we collect the information at issue, or by e-mailing us at firstname.lastname@example.org. If you have not opted-in, you will not receive the applicable communications.
How do we collect information about you? We use different methods to collect your information, including through: Direct or indirect interactions with you when you provide it to us, for example, by filling in forms or corresponding with us, in connection with the purposes described above under the section “How do we use your information”. Interactions may be indirect where a caregiver assists you with providing us with such information through your account; Automated technologies or interactions, as you navigate through our Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. For more information, please see the section below entitled “Information we collect through cookies and other automatic data collection technologies”; and Third parties or publicly available sources, for example, our partner clinics and other business partners.
You may also provide information for us to publish or display on public Site areas or transmit to other Site users or third parties. You are able, through your account on the Site, to control how much of your personal information and/or personal health information appears in connection with any of your User Submissions (as defined in the Terms), if any. In other words, you will have the option to contribute User Submissions anonymously such that other users of the Site and/or third parties will be able to view your User Submissions without knowing from where or whom they originate.
Disclosure of your information We may disclose aggregated information about our users, and information that does not identify any individual, without restriction but always in compliance with applicable law. We may however disclose personal information and personal health information that we collect or you provide as follows: To help third parties make decisions about how to best support and improve the global ecosystem for assistive devices. These third parties may include service or product providers (including third party sellers of assistive devices) insurance agencies or government organizations; In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information and personal health information we hold about our customers and users is among the assets transferred; To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others, though we do not disclose data about identifiable individuals to our advertisers. We may provide them with aggregate information about our users (for example, we may inform them that 400 men between 25 and 35 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information and personal health information we have collected from you to enable us to display our advertisers’ advertisement to that target audience; To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information and personal health information confidential and use it only for the purposes for which we disclose it to them; To contractors, service providers and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to keep personal information and personal health information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information and personal health information with the same standards set out in this Policy; and To fulfill the purpose for which you provide it, or for any other purpose disclosed by us when you provide the information and obtain your prior consent. We may also disclose your personal information and personal health information: To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law; To enforce or apply our Terms [link] and other agreements; and/or If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers, or others.
Transferring your personal information and personal health information We may transfer personal information and personal health information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to keep personal information and personal health information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information and personal health information with the same standards set out in this Policy. We may process, store, and transfer your personal information and personal health information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information and personal health information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy laws. By submitting your personal information and personal health information or engaging with the Site, you consent to this transfer, storage, or processing.
Data Security The security of your personal information and personal health information is very important to us, especially your sensitive personal information and sensitive personal health information. We use physical, electronic, and administrative measures designed to secure your personal information and personal health information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. We also use a back-end infrastructure platform that is fully compliant with applicable laws and guidelines regarding personal information and personal health information. For
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information and personal health information, we cannot guarantee the security of your personal information and personal health information transmitted to our Site. Any transmission of personal information and personal health information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
Data Retention Except as otherwise permitted or required by applicable law, we will only retain your personal information and personal health information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information and personal health information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent, though we will always disclose risks (if any) to you at the time consent is obtained.
Accessing and correcting your personal information and personal health information It is important that the personal information and personal health information we hold about you is accurate and current. Please keep us informed if your personal information or personal health information changes. By law you have the right to request access to and to correct the personal information and personal health information that we hold about you. To change or delete any of your personal information or personal health information, you may log into your account on our Site and edit or remove information about you. If you want to review, verify, correct, or withdraw consent to the use of your personal information or and personal health information you may also send us an e-mail at [*] to request access to, correct, or delete any personal information or personal health information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We reserve the right to charge you a fee to access your personal information and personal health information, however, we will notify you of any fee in advance. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information and personal health information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information and personal health information that we hold about you, or we may have destroyed, erased, or made your personal information and personal health information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information and personal health information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Compliance Officer, Paul van der Vorst, at email@example.com. If you delete your User Submissions from the Site, copies of your User Submissions may remain viewable in cached and archived pages or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Submissions, is governed by our Terms [link].
Age and Capacity of Individual By using this Site, you represent that you are both capable and at least the age of majority required to consent to the collection, use or disclosure of personal information and personal health information in your jurisdiction. No one that is incapable or under such age of majority in his or her province of residence may use the Site, or provide any personal information and personal health information to or on the Site. We do not knowingly collect personal information and personal health information from anyone that is incapable or under such age of majority in his or her province of residence. If we learn we have collected or received personal information or personal health information from an individual that is in capable or under such age of majority in his or her province of residence, we will delete that information. If you believe we might have any information from or about an individual that is incapable or under such age of majority in his or her province of residence, please contact us at firstname.lastname@example.org.
Changes to this Policy We will post any changes we make to this Policy on this page. If we make material changes to how we treat our users’ personal information and personal health information, we will notify you by e-mail to the e-mail address specified in your account and through a notice on our home page. You are responsible for ensuring we have an up-to-date, active, and deliverable e-mail address for you, and for periodically visiting our Site and this Policy to check for any changes.
Contact information and challenging compliance We welcome your questions, comments, and requests regarding this Policy and our privacy practices. Please contact us at:
Paul van der Vorst, Privacy Compliance Officer
612 Seawind Trail, Waterloo, ON, N2K 4G4 [toll-free phone number] (toll-free)
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information and personal health information, and our compliance with this Policy and with applicable privacy law. To discuss our compliance with this Policy please contact our Privacy Compliance Officer using the contact information listed above.
TORONTO 85252-1 1639483v2