Last Modified: March 1, 2018
LIFECARE PORTAL INC.
At LifeCare Portal Inc. (the “Company”, “we” or “us”), we are committed to safeguarding and protecting the privacy of Personal Information (defined below) that is provided to us in the course of the Company’s operations, including in its operation of the LifeCare Portal (the “Portal”).
The purpose of this Privacy Statement is to inform you about the types of Personal Information we collect, use, and disclose. It explains how we collect, use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently.
The following topics will be covered in this Privacy Statement:
- What is Personal Information?
- How do we collect your Personal Information?
- Where do we store your Personal Information?
- How do we use Personal Information that you provide?
- To whom do we provide the Personal Information that you provide?
- When and how do we obtain your consent?
- How do we ensure the privacy of the Personal Information you provide to us when dealing with our affiliates and other third parties?
- How long will we use, disclose or retain Personal Information you provide to us?
- How can you review your Personal Information that we have collected, utilized or disclosed?
- How do you know that the Personal Information we have on you is accurate?
- What if the Personal Information we have on you is inaccurate?
- How fast will we respond to your written requests?
- Are there any costs to you for requesting information about your Personal Information or our privacy practices?
- How do we know that it is really you requesting your Personal Information?
- What safeguards have we implemented to protect the Personal Information that you provide?
- How do you contact us regarding access to your Personal Information or our privacy practices?
What is Personal Information?
“Personal Information” is any information that about an identifiable individual, such as the following:
- contact information
- health history
- appointments and schedules
- communications with other users of the Portal within your network
- Geographical location is tracked within the app
LifeCare is an online portal for helping manage the long-term care of a family member or friend (the “Care Recipient”) – and for sharing information with other family members or friends who are involved in their care (the “Care Network”). The Portal helps both the Care Recipient and members of the Care Network manage day-to-day responsibilities regarding the Care Recipient, allowing them to assign and delegate tasks, and sharing necessary medical information with each other.
In using the Portal, you may submit your own Personal Information. You may also submit the Personal Information of a family member or friend. For example:
- You may be the Care Recipient, and may wish to provide Personal Information to the Portal regarding friends and family whom you intend to be members of your Care Network.
- You may be a friend or family member of a Care Recipient, and may wish to provide a Care Recipient’s Personal Information to the Portal to support their long-term care.
- You may be a member of a Care Network and may wish to provide Personal Information about other friends and family members whom you wish to invite to be members of that Care Network.
By submitting Personal Information about another individual, you must only do so if you have the consent of that individual (or their substitute decision-maker, where applicable). You are responsible for your failure to do so (and not LifeCare).
2. How do we collect Personal Information?
We will always collect Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent, or as otherwise required or permitted by law. Generally, however, we collect Personal Information directly from you on a voluntary basis.
3. Where do we store Personal Information?
For users who are identified at the time of account registration as residing in Canada, we store Personal Information that you provide on our servers (or those of our service providers) in Canada.
For users who are identified at the time of account registration as residing in the United States, we store Personal Information that you provide on our servers (or those of our service providers) in the United States.
4. How do we use Personal Information that you provide?
Generally, we identify the purposes for which we use the Personal Information that you provide at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use Personal Information for the following purposes (the “Purposes”):
- to register or administer your user account;
- to respond to your requests, complaints or inquiries;
- to administer specific functions of our website;
- such purposes for which the Company may obtain consent from time to time; and
- as otherwise required or permitted by law.
5. To whom do we disclose Personal Information that you provide?
Generally, we do not disclose Personal Information that you provide to us. We will only make disclosures of such Personal Information to those persons, if any, for which you provide your consent.
Notwithstanding the foregoing, we may transfer Personal Information that you provide to us to our third party service providers with whom we have a written agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as our service providers that provide technical support or data storage or processing.
In addition, we may send Personal Information outside of the country for the Purposes, including for process and storage by service providers in connection with such Purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Officer (see question 16 below).
6. When and how do we obtain your consent?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing any Personal Information you provide to us for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances.
We also require users who are submitting Personal Information to the Portal that is about another individual, to only do so if they have the consent of that individual (or their substitute decision-maker, if applicable).
7. How do we ensure the privacy of the Personal Information you provide to us when dealing with our affiliates and other third parties?
We take appropriate steps to ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Information are contractually obligated to comply with Canadian privacy laws and our privacy practices.
8. How long will we use, disclose or retain Personal Information you provide to us?
We will use, disclose or retain Personal Information that you provide to us for as long as necessary to fulfill the purposes for which that Personal Information was collected, and as permitted or required by law.
9. How can you review your Personal Information that we have collected, used or disclosed?
If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by law. We will attempt to make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.
10. How do you know that the Personal Information we have on you is accurate?
We will attempt to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you to supply us with updates to your Personal Information, as required, using the functionality of the Portal (or by other means, where appropriate).
11. What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
12. How fast will we respond to your written requests?
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada (or applicable provincial privacy commissioner) in respect of this time limit.
13. Are there any costs to you for requesting information about your Personal Information or our privacy practices?
We will not charge any costs for you to access your Personal Information in our records without first providing you with an estimate of the approximate costs, if any.
14. How do we know that it is really you requesting your Personal Information?
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
15. What safeguards have we implemented to protect the Personal Information that you provide?
We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only employees, who are granted access to the Personal Information that you provide, are those with a business ‘need-to-know’ or whose duties reasonably require such information.
16. How do you contact us regarding access to your Personal Information or our privacy practices?
All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Statement or our privacy practices, should be forwarded to our Privacy Officer as follows:
Address: Attn: Chief Privacy Officer
LifeCare Portal Inc.
200 Yorkland Blvd, Suite 710
Toronto, ON M2J 5C1
E-mail: [email protected]