Last Updated May 18, 2020

Privacy Statement

Application of this Privacy Statement

Thank you for visiting the Santé Circle Health (“SCH”) Website (the “Website”). This Privacy Statement describes SCH’s policy and practices in relation to Personal Information (defined below) collected through the Website. More specifically, this Privacy Statement explains how we collect, use and disclose Personal Information, the choices you have regarding such use and disclosure, and how you may access and correct that information.

SCH places a high value on privacy and is committed to respecting the privacy of our Website users. We recommend you read this Privacy Statement carefully as by visiting or using the Website, you will be consenting to the policies and practices described in this Statement. If you do not consent, please exit and do not use the Website.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last updated” date which appears at the top of this page.

Personal Information

In this Privacy Statement, “Personal Information” means information about an identifiable individual that SCH receives through the Website. This information may include but is not limited to your name, home address and content that you provide to SCH or post on this Website. Personal Information does not include information about you in any professional capacity, including your name, business title or office, business address, telephone number or email.

Collection & Use of Personal Information

SCH does not automatically collect your Personal Information: Personal Information is only collected if you supply it voluntarily, usually through contacting us via e-mail, or registering in a secure portion of the Website.

SCH will use your Personal Information to respond to your inquiries or requests. We may also access your Personal Information in the course of maintaining the Website or monitoring Website activity, and use your Personal Information as otherwise permitted or required by law. SCH will not use your Personal Information for spamming, unsolicited bulk or commercial email, or third-party or commercial marketing purposes.

External Links

When navigating to self-managed virtual care tools or healthcare team-managed virtual care programs, you may find links to external websites not managed by SCH. For programs and tools not managed by SCH, these links are provided on an “as-is” basis and SCH has not certified, conducted any privacy or risk assessments, and/or conducted other due diligence initiatives. When you click on an external link not managed by SCH, you will be subject to the Privacy Policy/Statement and Terms of Use of the organization hosting that tool. SCH recommends you read and become familiar with that Privacy Policy/Statement and Terms of Use. When you do visit SCH’s website and access a virtual care program or tool not managed by SCH, the following non-identifiable information could be collected from you such as; number of visitors, number of registrations to the self-managed virtual care tool that originated from SCH link clicks, number of site visits, total sessions, average number of sessions per user and session duration, average time on page, unique page views, hour of the day visited, and total number of post-login site visits to the self-managed virtual care tool including registration page visits. Should you have any questions about the programs and tools not managed by SCH, please contact the respective organization directly.

Cookies

In order to evaluate the Website, and for site security and law enforcement purposes, SCH may collect certain information from your computer, including without limitation, your IP address, browser type, domain names, access times and referring website addresses (collectively referred to as “Technical Information”). To obtain this Technical Information, SCH may use various kinds of software devices, including “cookies.” A “cookie” is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we collect and store in cookies to any Personal Information you submit while on the Website. However, some Technical Information can be used to derive certain Personal Information. For more information, see the Privacy Commissioner of Canada’s report posted at https://www.priv.gc.ca/en/opc-actions-and-decisions/research/explore-privacy-research/2013/ip_201305/(accessed as of July 2017).

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We use session cookies to make it easier for you to navigate the Website. We use persistent cookies to allow you to navigate based on past usage so as to provide ease of use for return visits to the Website. You can remove persistent cookies by following directions provided in your Internet browser’s “Help” file. You can also set your browser to disable cookies, but this Website may not function properly if you do.

SCH does not disclose Technical Information except in accordance with applicable law.

Privacy Officer

All comments, questions, concerns or complaints regarding SCH’s management of your Personal Information or this Privacy Statement, including requests for access to or the correction of your Personal Information, should be forwarded to our Privacy Officer as follows:
Santé Circle Health
200 – 5700 Yonge Street
Toronto, Ontario M2M 4K2
Attention: Privacy Officer
E-mail: privacy@santecirclehealth.com