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Privacy Policy - Canada

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‘Member’ means a member of the site and ‘membership’ shall be interpreted accordingly.

‘Member Content’ means any information that a Member enters or uploads to the Site, excluding Personal Information entered to register, but including information entered to activate an account, in the Account Settings and Your Profile sections of the Site, in bricks, Talkabouts and Guided Support sessions.

‘Member Name’ means the anonymous username You select to identify Yourself to other Members and which will be available to wall guides.

‘Personal Information’ means information about an identifiable individual, including You and others, e.g. Your real name, email address, postal code and date of birth.

‘Site’ means the website located at togetherall.com and pages therein under the control of Togetherall (the “Site”).

‘Terms’ means the Member Terms which incorporate Our House Rules and Privacy Policy detailed on the Site from time to time.

‘We’ or ‘Us’ means Togetherall Limited, a company having a registered office at 550 Burrard Street, Bentall 5, Vancouver, British Columbia, Canada, V6C 2B5 and ‘Our’ shall be interpreted accordingly.

‘You’ means You, the User of the Site and ‘Your’ and ‘Yourself’ shall be interpreted accordingly


Our Privacy Commitment

We take Your privacy rights very seriously and seek to ensure the highest standards of compliance with Canadian privacy legislation and requirements.

Our Privacy Policy explains how We collect, use, disclose and retain Your Personal Information and how You can protect Your privacy when You use the Site.

Our Privacy Policy is incorporated into and subject to the Member Terms of the Site. By accessing and continuing to use the Site, You accept the terms of this Privacy Policy.

Please note that We may update and amend Our Privacy Policy from time to time and We will post any changes on the Site. It is Your responsibility to check regularly if there have been changes and to review such changes. We will indicate with a “last updated” date at the top of the Policy when Our Privacy Policy was last revised. If You do not agree with any of Our Privacy Policy then You are not permitted to use the Site.


Contacting Us

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.


Protecting Your Privacy and Identity

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:

  • You must choose a Member Name that is not related in any way to Your real name or nickname. Other Members will see Your Member Name.
  • Do not post details such as Your real name, names of family members or friends, place information, e.g., where you live, where You receive healthcare or places You like to visit, Your phone number or Your e-mail address.

The Site has privacy settings that You may use to protect Your identity. For example:

  • Talkabouts (TAs) You may choose whether to participate in Community TAs. You may also invite other members to join Group TAs (GTAs) or Personal TAs (PTAs). Only other Members whom You’ve invited to participate may see Your Member Content in GTAs and PTAs. We may also access GTAs and PTAs.
  • Journals and Goals You may choose to use tools which are private and other members cannot view. However these tools are still monitored by Wall Guides to ensure the safety of our members on Togetherall. Journal and Goal tools are available through the ‘Resources’ page on the Site.

If you do not use Our privacy settings, other Members will see the Member Content You post with Your Member Name beside it.


How we Collect and Use Personal Information

We collect and use Your postal code, date of birth and email address (which is Personal Information) to:

  • Register You: We collect Your postal code, date of birth and email address to register You and create Your Member account. More particularly, We use Your postal code and date of birth to confirm Your eligibility for Membership.
  • Administer the Site and Your Membership: If You enter Your email address when You login, We will use it to authenticate You. We use Your Personal Information to present it to You in ‘My Account’. We may also use Your Personal Information 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.
  • Process and deal with any complaints made by or about You.
  • Investigate usage of the Site that may be inappropriate.
  • Seek compensation from you or take other action including legal action as set out in the Member Terms.
  • Communicate with You: We email you messages about Member Terms the Site and Your Membership, and notifications about new content and activity on the Site pertinent to You, e.g., that You have received a private message. If You do not wish to receive notifications, You may turn them off in the ‘Account Settings’ section of the Site.
  • Respond to You: If you contact Us, We will collect and use any Personal Information You provide to Us to process and respond to Your message. Your query will be directed to our customer support team which may be based outside of Canada. If You request a password reset or other support, We will email You instructions and information to help resolve Your request.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Togetherall Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of security, risk reduction and fraud protection.

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 will always inform You about why We wish to collect Your Personal Information and ask You for Your consent before collecting it. We limit Our collection of Personal Information to what is necessary for the purposes for which We wish to collect, use or disclose it. For example, We keep the information that You provide to activate Your Account (e.g., Your ethnicity and gender) separate from Your postal code, email address and date of birth.

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 Ontario by using Your postal code along with that of other Members.


How We Collect and Use Member Content

Ordinarily, Your Member Content, including the information that You enter to activate Your account (e.g., gender and ethnicity) will not constitute Personal Information. 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 use and disclose Member Content to:

  • Present the Member Content to You when You visit the Site.
  • Customize content that We present to You on the Site, or in emails and notifications that We send to You and other Members. For example, We may include Your Member Name when
  • We notify another Member that You have sent them a private message.
  • Monitor, develop and improve the Site, and optimize Your experience of them.

As described above, create reports and data for: statistical, analytical and reporting purposes; research; and for evaluating and enhancing the Site. We may disclose such reports and data to external parties, including funders. For example, We collect and use the information that You enter to activate Your Account (e.g., gender and ethnicity) to create aggregate, anonymous information or reports about Membership and usage of the Site.

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. Our Wall Guides do not have access to Your Personal Information, including Your email address.


Information that the Site Automatically Collects

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.


How we May Disclose Your Personal Information

We may disclose Your Personal Information to third parties: if We are required to do so by law or 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 Limited, 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.


Retention and Destruction of Personal Information

We will retain Your Personal Information for three 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.


Accessing and Correcting Your Personal Information

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.



Cookies are small pieces of information stored by Your browser on Your device’s hard drive. We use cookies to allow Us to track which pages are viewed on the Site, to determine how frequently particular pages are visited, to determine the most popular areas of the Site and generally to monitor usage of the Site. We also use cookies to save a record of access to Courses so We can remind You to complete courses, and to ‘bookmark’ bricks’ positions on the Site. Most web browsers automatically accept cookies, though You do not have to. If you wish to disable cookies You can do so by readjusting Your browser settings. If You disable cookies You will still be able to use the Site, however You may not be able to use all features of the Site. For more information on cookies and how to disable them, consult the information provided by the Interactive Advertising Bureau https://www.iab.com/.


Third Party Cookies

When using the Site, Your browser may receive cookies from third parties including Google, Facebook and AddThis. Using Facebook and AddThis, you can post a link to the Site’s homepage on Facebook. We use Google Analytics to help analyze the use of the Site and improve visitors’ experience. We receive anonymous, aggregate reports about Site usage for this purpose. Google Analytics creates the reports by using cookies to collect and generate information about Your use of the Site. We cannot identify individuals from the Google Analytics reports. We do not control the use of cookies by third parties- please review Your browser settings and readjust them if You wish to disable or block cookies. For more information about Google Analytics and how it collects and processes data, consult its site “How Google uses data when you use our partners’ sites or apps” https://policies.google.com/privacy/partners.


Protecting Your Personal Information and Member Content

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. We use computing systems in secure facilities to store Your Personal Information.

You also play an important role in protecting Your Personal Information and Member Content. For example:

  • You must keep Your password for the Site confidential. We ask You not to share Your password with anyone.
  • Use an email account to which only You have access to receive emails and notifications from us.
  • If You access the Site from a shared device, remember to log out.

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.


Your consent

We store Your Personal Information in Canada, except for any Personal Information You submit using our contact form which may be stored outside of Canada. We store Your Member Content within the European Economic Area (‘EEA’) which has laws that differ than the laws of Canada with respect to information and more particularly, requirements to disclose or produce information. We may be required to disclose Member Content stored in the EEA under an order made under the laws of the EEA, including to governments and their agencies, courts and law enforcement. By submitting Your Member Content, You agree to its transfer, storing and processing in the EEA.

By clicking ‘submit’ or ‘I agree’ during the registration process or by Your continued use of the Site you expressly agree to this Privacy Policy. This is Our entire and exclusive Privacy Policy and it supersedes any earlier version. It should be read in conjunction with the Member Terms and any additional applicable terms posted on the Site.


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