1. Commitment to Privacy of Personal Information
WillKin Health is committed to protecting the privacy of individuals who use its services. This Personal Information Protection Policy (the “Policy”) describes the policies and practices of WillKin Health with respect to the collection, use and disclosure of personal information. WillKin Health collects uses and discloses personal information only with the consent of the individual, except as otherwise permitted or required by law. The Policy may be updated from time to time, with updates approved to reflect developments in practices, new technology or the law. Updates will be made available in the same ways as the Policy. WillKin Health collection, use and disclosure of personal information will be governed by the version of this Policy in effect at the time.
We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
2. Personal Information
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information. This Policy applies to personal information of visitors to the website willkin.ca (the “Website”).
- WillKin Health generally collects information from you through:
- Subscription to newsletter
- Requests or questions you submit to us via forms or email (e.g., support forms, contact forms, program information)
- Your communications and dealings with us
- Your participation in contests or research
- Personal information collected at the Website may include: your contact information, such as full name, email address, city and whether you are identifying yourself as a patient, carer, family member, healthcare professional or exercise professional (kinesiologist or exercise physiologist).
- Information collected about your computer or other electronic device may include: your Internet Protocol (IP) address, domain name, browser type, date and time of your request and information provided by tracking technologies, such as cookies and single- pixel tags; if you use a mobile device to access our websites and online resources, we also may collect information about your device, such as your device
This policy DOES NOT apply to information that:
- We collect offline or through any other means, including on any other Company or third-party website
You provide to or is collected by any third party, through any application or content (including advertising) that may link to or be accessible from or on the Website.
WillKin Health is responsible for all personal information under its custody or control. The Owner of WillKin Health has been appointed as Privacy Officer for WillKin Health. The Privacy Officer may delegate day-to-day responsibility for administration of this Policy to other employees, but the Privacy Officer remains accountable for WillKin handling of personal information.
Our Privacy Officer may be contacted at: 93 boul. de Fontainebleau, Blainville, QC, Canada. Tel: 438-403-6049.
4. Information we may collect about you
We may collect and use several types of information from and about you, including:
- Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (“personal information”).
- We provide an opportunity for any user to unsubscribe from any mailing or subscription lists or opt-out of contact for marketing purposes on an ongoing basis by accessing our Website, using the unsubscribe mechanism at the bottom of our e-mails, or by e-mailing our Privacy
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service
5. How we collect information about you
We may use different methods to collect your information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or
- User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third
- Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- Third parties or publicly available sources, for example, our business
6. How we use your information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to
- To provide you with information, products, or services that you request from
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide
- To provide you with notices about your account/subscription, including expiration and renewal
- To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal
- To notify you about changes to our Website or any products or services we offer or provide though
- To improve our Website, products or services, marketing, or customer relationships and
- To allow you to participate in interactive features, social media, or similar features on our
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to
- In any other way we may describe when you provide the
- For any other purpose with your
We may also use your information to contact you about goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form), adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail our Privacy Officer.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Newsletter: WillKin Health collects and uses personal information (name and email address) from individuals who have taken the option to be part of our bulletin to occasionally send them information about updates on our educational materials, products and/or services.
7. Transferring your personal information
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
Willkin Health may also transfer your personal information in situations where we are legally required or permitted to do so. The type of information we are legally required to disclose may be related to criminal investigations, government requirements, or to enforce our rights or investigate suspected illegal activities. In some cases, such as legal proceedings or court orders, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed and we take precautions to ensure that the authorities requesting disclosure have legitimate grounds for doing so. We may disclose certain personal information when we believe that such disclosure is reasonably necessary to protect our rights, property, or safety, in applicable cases and as permitted by law.
8. Data Security
The security of your personal information is very important to us. We respect the highest industry standards in this area. Thus, we use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted.
In order to protect our business, we implement a security retention window for certain personal information for a period of 7 years, three months after account deletion. During this period, account information will be retained under the terms of this policy even if you are no longer active. We assure you that your personal information will never be used or transferred.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
9. Data retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
10. Accessing and correcting your personal information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- Information protected by solicitor-client
- Information that is part of a formal dispute resolution
- Information that is about another individual that would reveal their personal information or confidential commercial
- Information that is prohibitively expensive to
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users.
WillKin Health uses personal information only with the consent of the individual, except as otherwise permitted or required by law. All registration information is submitted to us on a voluntary basis. Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our Privacy Officer (email@example.com). Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
Our collection, use, or disclosure of your personal information requires your consent. Depending on the nature and sensitivity of your personal information, your consent to the collection, use and disclosure of such information may be express and positive (which may be oral, in writing or electronic) or implied (such as by using our products or services or by not responding to our offer to remove your personal information from our marketing lists), in which case we assume that you consent. Consent may be given by your authorized representative. You may withdraw your consent at any time as long as you give reasonable notice of withdrawal.
Withdrawal or refusal of consent is subject to legal and contractual restrictions. Willkin can collect, use or disclose your personal information for legal, security or certain processing reasons when authorized by law. For example, we must provide your personal information in response to a search warrant or other legally valid enquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law.
If we make a change to this policy that materially affects your rights and obligations, we will notify you 15 days prior to implementing the changes for your consent. In all other cases, we recommend that you review this policy regularly.
WillKin Health protects personal information against such risks as loss or theft, unauthorized access, disclosure, copying, modification, and destruction by using appropriate security measures. WillKin Health employees with access to personal information are required to respect the confidentiality of that information pursuant to their employment agreement with WillKin Health. Employees also participate in privacy training. WillKin Health implements methods of protecting personal information that include limiting access to the information, restricting access to offices where information is held and technological measures such as passwords.
14. Governing Law
This Policy and all related matters shall be interpreted in accordance with the laws of the Province of Quebec and the federal laws of Canada applicable therein.
15. Questions and Complaints
For further information about this Policy or the practices of WillKin Health related to personal information, or to make a complaint, please contact the Privacy Officer at 438- 403-6049 and firstname.lastname@example.org. We will respond to your request within 45 days. If we need more time, we will notify you in writing of the reason and the additional time. WillKin Health will investigate all complaints and is committed to taking appropriate action as a result of that investigation.