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Privacy Policy

Last Updated: 31 August 2021

Togetherall Canada Limited is committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Togetherall collects from or about you, as well as how we use and to whom we disclose that information. Please review this entire document carefully.

By using the Site, you agree to the Terms and this Privacy Policy. If you do not agree to the Terms and this Privacy Policy, you may not use the Site.

 

Privacy Policy Effective for Canada

It is Togetherall’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes such legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy / health information laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

 

Definitions

  • Togetherall” (as well as “We” or “Us” means Togetherall Canada 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.
  • 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 www.togetherall.com and pages therein under the control of Togetherall.
  • Terms” means the Member Terms which incorporate Our House Rules detailed on the Site from time to time.
  • You” means you, the user of the Site, and “Your” and “Yourself” shall be interpreted accordingly.

 

Our Privacy Commitment

As above, 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.

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.

 

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 or by writing to theteam-ca@togetherall.com. 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.

 

Why We Collect and Use Personal Information

We may collect and use Your Personal Information (including your postal code, date of birth, gender, ethnicity, IP address, phone number and email address) 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.
  • Register You if you are Referred: If applicable, you may be referred to Us by a third party, such as your institution, organization, or employer, in which case that entity will need to obtain your consent to share your email address and any further relevant information with Us. For example, they may provide us with Your full name, Your telephone number, or a reference number, after obtaining Your consent to do so. We may disclose necessary information with the person that referred You to Us, including that You have activated an account with Us.
  • 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 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 certain 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; and
  • Better understand who You are: We may collect certain demographic information that you provide to us for the purposes of allowing us to create anonymized reports and data (as described below) and to better improve our services.
  • Provide you with the services that you seek from us; and
  • Pursuant to applicable law: We may collect, and use Your Personal Information if We have a right or an obligation to do so under applicable law. This may be done (i) to protect the rights, property, or safety of Togetherall, our customers, or others (e.g. against error, fraud, theft, and damage to our goods and property), (ii) to enable Us to comply with applicable laws or regulatory process, or (iii) to enforce or apply our terms of use and other agreements. This includes exchanging information with other companies and organisations for the purposes of security, risk reduction and fraud protection. Without limiting the generality of the foregoing,

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

 

Why We Collect and Use Member Content

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:

  • Present the Member Content 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.

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.

 

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.

 

When We May Disclose Your Personal Information

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, and our employees and contractors in various jurisdictions, so that We may operate Our business and provide service to users outside of local business hours. As a result, Your Personal Information may, subject to applicable laws, be collected, used, processed, stored or disclosed in Canada, the European Economic Area (“EEA“), the United States, the United Kingdom, Serbia, Australia and New Zealand. As such, Your Personal Information may potentially be accessible to law enforcement and national security authorities of those jurisdictions.

We may also disclose your Personal Information to our third party escalation partners  who respond to and manage risk or crisis situations on Our behalf and who are authorized to disclose your Personal Information to third parties in order to provide these services. Information we provide in these circumstances include Your username, postal code, phone number, email address, IP address, other identifying information about the individual at risk (such as name and address), clinical scenario and assessment, details about the given situation, and any other information that may assist in managing the risk or crisis. The same information may be used by Togetherall staff, and may be disclosed to police, emergency medical services, and other local authorities to respond to a crisis situation.

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.

 

Your Consent Is Important to Us

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.

Typically, We will seek Your consent at the time that We collect Your Personal Information. In certain circumstances, Your consent may be obtained after collection but prior to Our use or disclosure of Your Personal Information. If We plan to use or disclose Your Personal Information for a purpose not previously identified (either in this Privacy Policy or separately), We will endeavor to advise You of that purpose before such use or disclosure.

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 assume that, unless you advise us otherwise, You have consented to the collection, use and disclosure of Your Personal Information as explained in this Privacy Policy.

 

Retention and Destruction of Personal Information

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.

 

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.

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.

 

Marketing

Business Customers

This section does not apply to Members and only applies to the representatives of our business customers.

We may also use Your Personal Information to send You and keep You updated with information by e-mail or message through the Site about existing and new services from Us and to send You information by e-mail or message through the Site about related products or services of selected third parties that may be of interest to You.

If at any time you wish to no longer receive our marketing emails, or no longer consent to our use of the tracking pixel, an unsubscribe link is found at the bottom of every email where you can opt out.

You have the right at any time to stop Togetherall from contacting you. If you no longer wish to be contacted for marketing purposes, please email marketing@togetherall.com.

Members

This section applies to Members of the Togetherall platform.

To opt-out of receiving these messages as a Member or as an Account holder, You can also use the facility contained in any such communication or change Your ‘Account settings’ through Your Togetherall profile on the Site. You may also contact Us to opt out using the information under the ‘Contacting Us’ section above: please state Your member name, and from whom You do not wish to receive further communications.

Also see the ‘Your Rights’ section below, for information about how to withdraw Your consent to receive these messages.

 

Cookies

If you opt-in to receiving our emails, you are consenting to our use of a tracking pixel.

A tracking pixel operates in a similar way as cookies are used in web browsers. A tracking pixel is usually part of electronic mail marketing. We use the tracking pixel to gather data on how our email activity is received such as, but not limited to, device, IP address, open time, link activity and website activity if a user clicks through to our website from our marketing emails. We use this information to create a better site experience for you and our customers, help personalise emails and tailor the site experience for all who opt in to hear from us.

Our Sites use certain cookies, pixels, beacons, log files and other technologies. Please see our Cookie Policy to learn about the cookies we use and how to manage your preferences.

Privacy Policy Changes

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. The “Last Updated” date at the top of the Policy lets you know when the Privacy Policy was last revised.

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.

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. 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.

 

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by Our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Togetherall any obligations outside of, or in addition to, those imposed by Canada’s federal and provincial health information / privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial health information / privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

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.

 

Additional Terms Applicable for Alberta

To the extent that You provide us with any individually identifying health information, We are collecting such information pursuant to sections 20, 22(1), 24 of the Health Information Act (Alberta) as an affiliate of Alberta Health Services, custodian, and are using such information to provide you with the services We offer on Our Site.