Healthnet Canada Inc. (“HealthNet”, “we”, “us”) respects your privacy and will strive to protect the confidentiality of your personal information. This Privacy Notice explains our personal information processing practices, including how and why we collect your personal information, how we use it, and how we safeguard it. We encourage you to read this Privacy Notice to familiarize yourself with our practices.
1. When does this privacy notice apply?
This Privacy Notice describes our practices in connection with the personal information collected about individuals interacting and using our products and services, including our website, https://www.healthnetcanada.ca/app (the “Site”).
“Personal information” is any information that can be used, either alone or in combination with other information, to identify an individual, but excludes information used solely to communicate with an individual in relation to their employment or business functions.
2. Why do we collect and how do we use your personal information?
We may collect and use your personal information as follows:
| Context | Type of Personal Information (Examples) | Primary Purpose for Collection & Use |
|---|---|---|
| Register for an account | Contact information (e.g. name and email address); Registration information (e.g. username, password, password hints, and security information that is used for authentication purposes). | Administer your account and provide you with account-related functionality, including accessing and posting on our community forum |
| Completing your profile | Contact information (e.g. name and email address); Employment information (current occupation and previous work experiences); Education information (e.g. education level, schools attended, major or area of study, and current status); Certification information (e.g. type of certification you hold, the issuing institution, and the year issued). | Maintaining your account and providing you with the ability to connect with government agencies and organizations that provide training and accreditation. |
| Using the ‘Contact Us’ webform | Contact information (e.g. name and email address); Personal information you may input in the message field. | Responding to your inquiries and actioning your requests. |
| Interact with the Site | Personal information automatically collected through cookies and other similar technologies. | Please see ‘Cookies and similar technologies’ below. |
| Posting on the community forum | Information you provide via our online community forum | Monitoring and moderating your posts. |
We may also use your personal information to protect and defend our rights and interests, as well as those of our employees, directors, officers, agents, parents and subsidiaries, including to manage and respond to legal claims or disputes.
3. Cookies and similar technologies
When you use the Site, we may automatically collect some types of personal information such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We typically collect this kind of information using “cookies” or other similar technologies such as “tracking pixels”. A cookie is a text file or piece of data a website stores on your device when you visit a web page. Cookies can be used to record your internet browsing activity and to personalize your online experience when you search for information. Tracking pixels can also be used to check if you have accessed content, monitor web traffic and provide information similar to cookies. Below, we describe how we use cookies and similar technologies.
(a) Persistent cookies
We use persistent cookies to measure Site usage, including browsing behaviour. We do this to improve how the Site works and to measure the effectiveness of the Site and our communications. For example, we use persistent cookies to track which parts of the Site you visit, which of our online marketing ads you click and your response rate, and the keywords you searched to find our site. If our ad is on a third-party site, we may collect the address of the site where you click the ad, but we don’t track or create a profile of your activity on third-party sites.
(b) Session cookies
Software applications or third parties may create cookies to store configuration information on your computer. These cookies allow you to view videos or other rich media on the Site.
(c) Opting out of cookies
You can block or disable third-party cookies in your browser settings so that your browser accepts only first party cookies, which are those cookies belonging to the site you are currently browsing, including cookies from us when you’re on the Site.4. Why and with whom do we share your personal information?
We may share your personal information with information technology, cloud and web-hosting services that help us store, compile and organize your information, and provide you with the services and Site.
We may also disclose your personal information to:• Government entities;
• Public and private training institutions;
• Other healthcare providers or institutions.
We disclose personal information to these entities in order to facilitate training, accreditation and business development opportunities at your request.
In certain situations, HealthNet and our third party service providers may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
As permitted by law, we may transfer or assign your personal information as a result of, or in connection with the planning, due diligence and implementation of business transactions, including merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, liquidation or other business transactions
We may also disclose your personal information:
• during emergency situations or where we reasonably believe it is necessary to protect the safety, health or security of a person or group; or
• otherwise with your consent.
Be aware that our website may contain links to other websites provided and maintained exclusively by third parties not subject to this Privacy Policy. We have no control or authority over third-party websites and are not responsible for any information that you may submit on those websites.
5. How do we protect your personal information?
We have established and implemented governance procedures and security safeguards regarding the protection of personal information. These procedures and safeguards are proportionate to the nature and scope of our activities and are approved by our Privacy Officer.
For instance, we have governance procedures to:
• prevent unauthorized access to your personal information;
• define the roles and responsibilities of the members of its personnel throughout the life cycle of the personal information;
• respond to privacy questions, complaints, or breaches (see below);
• limit the use of your personal information to the purposes communicated to you;
• honour the choices you made about your personal information; and
• retain your personal information only for the period we need it to serve you and manage our business and legal obligations.
We review our procedures and security measures on a regular basis. We do this to ensure they remain effective and appropriate.
6. Where do we store your personal information?
Your personal information may be processed and stored outside of the province in which you reside and/or outside of Canada by us or our third-party service providers for the purposes set out in this Privacy Notice. Specifically, your personal information may be stored or processed in Google’s Cloud-based servers, which are run on Google’s global infrastructure. We only do so as permitted by law and with adequate protections. However, you should know that data protection laws of these jurisdictions may differ from Canadian or Quebec laws. Service providers are bound by the laws of the jurisdiction in which they are located. As a result, they may be required to disclose your personal information in response to authorized demands from government authorities, law enforcement, or courts of their jurisdictions.
7. How long do we keep your personal information?
We only retain personal information for as long as is necessary for us to fulfill the purpose for which it was collected or to comply with legal or regulatory requirements. At the end of the retention period, your information is deleted.
8. What rights do you have?
You have the following rights with respect to your personal information:
• Right of access: You have the right to obtain information on the processing of your personal information and in some cases, to receive a copy of this information. This includes the right to request information about how we process your personal information, including what personal information we collected from you and how it is being processed.
• Right to rectification: You have the right to request that we correct or complete your inadequate, incomplete or inaccurate personal information.
If you are a resident of Quebec, you may also have the following additional rights:
• Right to deletion: You have the right to request that we delete your personal information, subject to our right to continue retaining information we need to retain to fulfill our legitimate interests or meet legal or regulatory obligations.
• Right to be forgotten: You have the right to request that we cease disseminating your personal information.
• Right to data portability: You may request any computerized personal information we have about your in a structured and commonly used technological format.
9. Accuracy and Updating Personal Information
We take care to ensure that the information we have is accurate and up-to-date. However, we also rely on you to tell us when your personal information changes. You can access, update and correct errors in your personal information by writing to the Privacy Officer using the contact information provided below. Depending on the nature of the information you are requesting and the complexity of your request, we may ask you to put your request in writing.
10. Withdrawal of Consent
It is your right to withdraw your consent to the collection, use and disclosure of your personal information at any time. To withdraw your consent, please write to our Privacy Officer using the contact information provided below. Upon receiving your request to withdraw your consent, we will stop using and disclosing your personal information, subject to legally permissible exceptions.
11. Contact
If you would like to exercise your rights, or have any questions or concerns about this Privacy Notice or our compliance with this Privacy Notice, please contact our Privacy Officer by email at privacy@healthnetcanada.ca , or by mail at:
Healthnet Canada Inc.
123 Edward Street, Toronto, ON. M5G 1E2
Attention: Privacy Officer
12. Changes to This Notice
We may update this Privacy Notice from time to time by posting additions or modifications to this page.