Effective Date: May 20, 2020
As above, We take Your privacy rights very seriously and seek to ensure the highest standards of compliance with Canadian privacy legislation and requirements.
To the extent that You provide us with any Personal Information, We are collecting such information pursuant to sections 20, 22(1), 24 of the Alberta Health Information Act, and are using it to provide you with the services We offer on Our Site.
If You have any questions, concerns or suggestions about Our privacy practices, please get in touch with Our Privacy Officer using Our contact form. Your query will be directed to our customer support team which may be based outside of Canada. Please remember to protect Your privacy if You contact Us (e.g., do not include information about Your health or Your Member Name or other information from any Member Content that you provide anonymously). Regular email is never a secure method of communication.
To the extent that you have any questions about the collection, use, disclosure or retention of Your Personal Information, you may also contact:
Linda Kongnetiman, BSW, MSW, PhD, RSW
Provincial Manager Information and CYFI Standards
Alberta Health Services
Provincial Addiction & Mental Health
10101 Southport Rd. SW, Cube 2241,
Calgary, AB T2W 3N2
Our main aim in providing the Site is to provide a safe place for You to share Your thoughts, feelings and discussions with others in a confidential environment, where Your anonymity is respected. To protect Your and other Members’ anonymity, read and apply Our House Rules.
Please be aware there is a risk that Members could identify You from information You post on the Site. To protect Yourself:
The Site has privacy settings that You may use to protect Your identity. For example:
If you do not use Our privacy settings, other Members will see the Member Content You post with Your Member Name beside it.
We may collect and use Your Personal Information (including your postal code, date of birth and email address) to:
From time to time, We may collect additional Personal Information from You when You provide it. For example, We may present a research survey to You within the Site and collect Personal Information from You if You agree to participate.
We may use Your Personal Information to create reports and data that contain information that cannot be used to identify You. We use such reports and data, and may disclose them to external parties, such as funding sources, for: statistical, analytical and reporting purposes; research; and for evaluating and enhancing the Site. For example, We may produce reports that identify how many Members live in different parts of Alberta by using Your postal code along with that of other Members.
Please be aware that Member Content will constitute Personal Information if it can be used to identify You; We may delete Member Content if We believe that it is Personal Information.
We may collect and use Member Content to:
Other Members have no access to the Member Content You provide when You activate Your account, or enter into Your Account Settings or Profile. Other Members may view Your Member Name and the Member Content You provide in bricks, Talkabouts and Courses, subject to Your privacy settings. Our wall guides may view the Member Content You provide in any brick, Talkabout and Course session, along with Your Member Name.
As further described in our House Rules, if We have serious and immediate concerns for the safety of yourself and/or others, We may use and disclose Your Personal Information (including any applicable Member Content) for the purposes of potentially trying to get You (or others) assistance from third parties.
Our webservers automatically collect information about Your visit to the Site including, but not limited to, traffic data, location data, weblogs and other communication data. Although We do not ordinarily set out to identify You from Your Internet Protocol (IP) address, We treat IP addresses as Personal Information. We may use data that Our webservers automatically collect about Your use of the Site, including IP addresses, to: investigate any suspected breaches of, and enforce Our House Rules and Member Terms, e.g., to help Us determine if a Member has registered more than once; to process and deal with any complaints made by or about You; to investigate usage of the Site that may be inappropriate; and to obtain compensation from You or take other action including legal action as set out in the Member Terms.
We use information automatically captured by Our web servers that is not Personal Information to see how the Site is being used and customize it for Your benefit.
We may share Your Personal Information with Our employees, contractors, consultants, affiliates, and other parties who require such information to assist Us with managing Our relationship with You, including: (i) third parties that provide services to Us; and (ii) third parties that assist Togetherall in the provision of services to You.
For example, We may share Your Personal Information from time to time with Our third party clinical service providers, as well as Our information technology and data processing service providers so that We may operate Our business. As a result, Your Personal Information may, subject to applicable laws, be collected, used, processed, stored or disclosed in the United States, the United Kingdom, Australia and New Zealand. As such, Your Personal Information may potentially be accessible to law enforcement and national security authorities of those jurisdictions.
As above, We may disclose Your Personal Information if We are required or have the ability to do so by law, in order for Us to comply with any legal obligation; in order to enforce or apply Our Member Terms and other agreements; or to protect the rights, property, or safety of Togetherall, Our customers, or others. This includes exchanging information with other companies and organizations such as the police, regulatory bodies or legal advisers for the purposes of security, risk reduction and fraud protection. For example, We may disclose Your Personal Information to the police in connection with any alleged criminal offence.
It is important to Us that We collect, use or disclose Your Personal Information where We have Your consent to do so. Depending on the sensitivity of the Personal Information, Your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from Your action or inaction. For example, when You enter into an agreement with Us, We will assume Your consent to the collection, use and disclosure of Your Personal Information for purposes related to the performance of that agreement and for any other purposes identified to You at the relevant time.
As We have described above, We may collect, use or disclose Your Personal Information without Your knowledge or consent where We are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw Your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting Us (as described below). All communications with respect to such withdrawal or variation of consent should be in writing. In certain circumstances, the withdrawal of consent may render Us unable to continue to provide Our services where the collection, use or disclosure of Your Personal Information is necessary to provide such services.
We may retain Your Personal Information for up to three (3) years after Your licence to use the Site expires. After that time, We delete or securely destroy it in accordance with Our document retention policies.
We may, pursuant to Our Member Terms, retain the Member Content indefinitely.
When Your Membership licence is still current, You may login to the Site at any time to view Your Personal Information. If Your licence has expired, You may reactivate it by accessing the Site or communicating with Us through the contact form for assistance with Your access request. We will reactivate Your account for two weeks in order for You to access Your Personal Information. You may update Your email address at any time by logging in and accessing ‘Account Settings’.
Tip: You may click on Your My Profile section and see all the Member Content You have posted in one place. You may also see all Your bricks, TAs and Course content by visiting those sections of the Site.
It is important that the information contained in Our records is both accurate and current. If Your Personal Information happens to change during the course of Our relationship, please keep Us informed of such changes.
In some circumstances We may not agree with Your request to change Your Personal Information and will instead append an alternative text to the record in question.
We use appropriate administrative, physical and technical safeguards to protect Your Personal Information from loss or theft, unauthorized access, use or disclosure, or modification or destruction. For example, We train Our personnel to protect Your privacy and require them to comply with Our policies and procedures that protect Your Personal Information.
You also play an important role in protecting Your Personal Information and Member Content. For example:
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to the Site; any transmission is at Your own risk. For the avoidance of doubt, We cannot guarantee complete security; for example, (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of Your Personal Information at any time.
This site is not intended for individuals in an emergency. If You are in a life-threatening situation, please immediately dial Your country’s emergency number available here, or go to Your nearest Accident and Emergency department.
This site is not intended for individuals in an emergency. If you are in a life-threatening situation, please immediately dial your country's emergency number available here, or go to your nearest Accident and Emergency department.
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