Privacy Policy
Salus Global Corporation (“SalusGlobal“, “we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy (this “Policy”) has been created to help you understand the types of information we may collect from or about you when you visit our website [www.salusglobal.com] (the “Website”); use our services, including our MoreHub platform (the “Platform”); or otherwise when communicating with us. This Policy also describes our practices for collecting, using, maintaining, protecting and disclosing that information.
BY USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, STORAGE, USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION BY US IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR THE TERMS OF USE [Terms of Use], YOU SHOULD NOT ACCESS OR USE OUR WEBSITE OR PLATFORM.
1. OVERVIEW OF OUR PRIVACY POLICY
The purpose of this Privacy Policy is to inform you of our privacy practices and policies, including:
- what personal information we collect and why we collect it;
- how we use your personal information;
- who we share your personal information with;
- your options to control access, update and remove your personal information from the Website; and
- who you can contact should you have questions or concerns about our privacy practices.
This Privacy Policy is designed to comply with applicable privacy legislation in Canada, including the Personal Information Protection and Electronic Documents Act. You should read this Privacy Policy carefully. This Privacy Policy is incorporated into and forms part of and is subject to our Terms of Use [Term of Use].
2. CONSENT FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
By accessing or using the Website or Platform, you agree to the terms of this Privacy Policy. We may update or change our Privacy Policy from time to time (see Section 13 below, Changes to This Privacy Policy). You agree that your continued use of the Website and/or Platform indicates your consent to this Privacy Policy and constitutes acceptance of those changes, so please check this Policy periodically for updates. We may notify you by email or by posting a notice on the Website’s and Platform’s home pages whenever there is a material change to this Privacy Policy. If you do not agree with changes made to this Privacy Policy, you should stop using our Website and Platform.
When you provide Salus Global with your personal information through the Website, Platform, any of our forms, or otherwise, you consent to the collection, use, and disclosure of such information in accordance with this Policy or for the purposes identified to you at the time you provided the personal information.
You may withdraw your consent to the collection, storage, use, disclosure, and retention of your personal information at any time, subject to legal and contractual restrictions and reasonable notice, by contacting us using the information provided below in Section 15. Withdrawal of your consent to the collection, storage, use, disclosure and retention of personal information may result in you being unable to continue use of our services, including the Platform.
3. THE KINDS OF PERSONAL INFORMATION WE COLLECT
The information we collect from you depends on how you use our Website and Platform. We will only collect personal information that is reasonably necessary for the purpose of providing our services to you. You should exercise discretion when disclosing your personal information to us and should not disclose sensitive or confidential information that you wish to remain private.
Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (de-identified data).
For Website users, we collect the following personal information about you:
- your IP address;
- your browser type;
- when you accessed the Website (e.g., date and time);
- your contact information (e.g., e-mail address), if you choose to provide it when communicating with us; and
- any optional information you may choose to provide to us in submitting feedback or inquiry on our Website.
For registered users of our Platform, we collect the following personal information, in addition to the personal information listed above:
- first and last name;
- password;
- email address;
- occupation;
- place of work, including the facility where you will be participating in our program;
- logs of activities completed during use of the Platform;
- information about how you use our Platform, such as what sections you have visited and what features you use;
- test, survey, quiz, and evaluation results; and
- any optional information you choose to make available on the Platform, such as comments, photographs, videos, or any other content you may post.
Your decision to disclose your personal information to us is entirely voluntary. If you do not provide the personal information necessary or withdraw your consent for us to use your personal information, you may not be able to access or use the Platform.
4. HOW WE USE THIS INFORMATION
We use information that we collect about you or that you provide to us, including any personal information, for the following purposes:
- To register you to use the Platform and to authenticate users for security purposes;
- To administer and manage access to the Platform and your user account;
- To provide registered users with services through the Platform;
- To monitor Platform engagement;
- To obtain feedback on your experience using the Platform;
- To maintain, evaluate and improve our Website, Platform and any other products or services of ours;
- To provide you with information that you request from us, including customer support;
- To notify you about changes to this Privacy Policy, our Website, Platform, or any other products or services we offer or provide though it;
- To enforce our Terms of Use and other policies or guidelines posted on the Platform;
- To send you marketing and promotional information, if you elect to receive it;
- To understand, research, and improve our services, including to compile aggregated, non-identifiable information and/or de-identified data for research, marketing, and analytics purposes;
- In any other way we may describe when you provide the information;
- For any other purpose with your consent; and
- As permitted by, and to comply with, applicable laws and regulations.
When you elect to take tests on the Platform, your test results will be used to create aggregate test reports and will be aggregated in such a manner that your personal information will not be disclosed. Aggregate reports may be made available to a registered hospital facility to determine its aggregate team performance. Aggregate data and reports may also be used by Salus Global for program administration, program analysis, assessment, and marketing.
Salus Global may use aggregated information about our users, and information that does not identify any individual, for itself and third parties, without restriction.
In the event we wish to use your personal information for any other purpose than as set out in this Section 4 above, we will notify you through an update to this Privacy Policy.
5. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information about you from the following sources:
- Directly from you. This is information you have voluntarily provided while entering your personal information on the Website or Platform, or when corresponding with us by mail, phone, e-mail, or otherwise.
- From automated technologies. This includes cookies, tags, web beacons, pixels and other technologies to track and collect information on how you use the Website and Platform.
- Information others provide about you. We may receive content, communications, and information provided by other users when they use the Platform. This can include information about you that other users post about you, including uploads of photographs, or videos through the Platform.
6. WHO WE SHARE THIS INFORMATION WITH
Personal information submitted to our Website or Platform is kept confidential, unless disclosed in accordance with this Privacy Policy.
We do not sell, rent, or lease to third parties any personal information we collect about you. We may share personal information to third parties such as our service providers, consultants, subcontractors and professional advisers to assist us in managing, monitoring and/or optimizing our Website or Platform; to market our goods and services; or for any other purpose described in this Privacy Policy. To the extent that any personal information is provided to third parties, we require that they be bound by obligations consistent with this Policy and that they only collect, use, or disclose your personal information for the purpose of providing such services to us.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- To another entity purchasing (including for diligence purposes prior to purchase) the assets of Salus Global, provided that entity abides by this Policy or a similar privacy policy;
- To enforce or apply our Terms of Use and other agreements; and
- With your consent.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
For registered users, personal information you provide to us may be shared with other registered users of the Platform for the purposes set out in this Privacy Policy. For example, some information, such as the information you choose to post, will be accessible to other registered users using the Platform. Test results, including any quiz and survey results, will be stored in a secure file together with your personal information and will not be released to any party without your personal written consent. Your individual results will be accessible to you only via a password specifically assigned to you. Reports summarizing your participation history, including which activities in which you have participated, will be accessible to the team at your facility and to any other authority responsible for administering the program for your facility. Activity reports may include your name.
7. SECURITY
Salus Global has implemented certain technical and security commitments to keep your personal information safe and secure. Personal information is protected by security measures appropriate to the nature of the information to protect against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. However, as the internet and technology constantly changes and evolves, there is no way to guarantee that your information will be 100% safe. In addition, the transmission of information via the internet is not always secure, and therefore we cannot ensure, warrant, or guarantee the security of any such personal information.
By using the Website or Platform, you agree that you are using the Website or the Platform and transmitting personal information at your own risk. You should only access the Website and the Platform within a secure environment to limit threats. We are not responsible for circumvention of any privacy settings or security measures contained in the Website or Platform.
Salus Global shall comply with, and provide you with, reasonable assistance in complying with applicable laws with respect to any unauthorized use, access, or disclosure of personal information.
If you think the personal information you provided to us has been improperly accessed, used, or disclosed, or if you suspect that there has been unauthorized use of your personal information, please contact us immediately as set out in Section 15 below.
8. CHILDREN’S PERSONAL INFORMATION
Our Website and Platform, and any services available from it, are not directed to users under the age of 18. Salus Global does not knowingly collect information from children under 18 years of age. If you learn that a user under the age of 18 has provided us with their personal information without having parental or guardian consent, please contact us (see Section 15) immediately so we can delete this information from our records.
9. RETENTION AND STORAGE OF PERSONAL INFORMATION
We retain personal information for as long as you are a registered user of the Platform. If your account has been inactive for a period of five (5) years, personal information that is no longer required (e.g., e-mail address, first and last name, etc.) will be securely destroyed or deleted according to our guidelines and procedures. We comply with all legislative and regulatory information retention requirements.
We currently store and process your personal information and other content you provide to us on servers located in Toronto and Montreal, Canada. In some circumstances, your personal information may be stored, processed, shared, or otherwise used on servers belonging to other third-party service providers located within or outside of Canada, including those in the United States, or to other trusted third parties based in other countries. Our service providers are only permitted to store, process and access your personal information, and are not otherwise authorized to collect, use or disclose your personal information, except in accordance with the purposes set out in this Privacy Policy or as required by applicable law. However, it is possible that foreign governments, courts, law enforcement or regulatory agencies may be able to access your personal information under foreign laws.
By using our services, including the Website or Platform, or otherwise providing us with personal information, you agree to the transferring of your personal information in accordance with this Privacy Policy and applicable data protection laws and regulations.
10. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You have the right to access personal information that we hold about you, such as:
- the personal information we collect and retain;
- the categories of personal information concerned;
- the purposes of the processing;
- details to whom your personal information has been/will be disclosed;
- how long we retain your personal information;
- if we did not collect the information directly from you, information about the source, and
- how to lodge a complaint with the correct supervisory authority.
You may also request from us:
- that we update any incomplete or inaccurate information about you; and
- that we remove your personal information from our profiles, in accordance with applicable laws.
Under certain circumstances, it is possible that we may not be able to provide you with all of the information you may have requested. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Fees may be applied to any copy of the requested personal information. We will provide the reasons for denying access upon request.
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.
You may also request deletion of your personal information. Please note that such a request could be refused because your personal information is required to provide you with the services you requested, or that it is required by applicable laws.
You may request this information by contacting us at privacy@salusglobal.com. Additional contact information is set out in Section 15 below.
11. MARKETING
If you have elected to receive marketing messages from us, you may opt out of receiving future marketing messages by following the instructions provided in each such communication. However, you cannot opt out of receiving all emails from us, such as emails about the status of your account on the Platform.
12. COOKIE POLICY
Our Website and Platform uses cookies to collect and store certain information in accordance with this Policy. A ‘cookie’ is a small text file sent from a website and stored on the user’s computer by the user’s web browser. Upon visiting a site that uses cookies, a cookie is downloaded onto your computer or mobile device. The next time you visit that site, your device will remember useful information such as preferences, visited pages, or logging in options.
Cookies are widely used to add functionality to websites, or to ensure they work more efficiently. We use cookies to optimize the user experience and ensure the services function properly.
Most web browsers allow some control to restrict or block cookies through the browser settings; however, if you disable cookies, this may affect your ability to use certain parts of our Website or Platform. For more information about cookies please visit https://www.aboutcookies.org.
13. CHANGES TO THIS PRIVACY POLICY
Salus Global may amend this Policy from time to time. If we make material changes to how we treat your personal information, we will notify you by e-mail to the primary e-mail address specified in your account (if any) or through a notice on the Website or Platform home pages. If you are a registered user of our Platform, you are responsible for ensuring we have an up-to-date, active and deliverable e-mail address for you. Otherwise, you are responsible for periodically visiting our Website or Platform, as applicable, and this Privacy Policy to check for any changes.
14. TERMS OF USE
Our Terms of Use can be found at [Terms of Use]. This Privacy Policy is incorporated into our Terms of Use.
15. CONTACT US
To review or update your personal information in our possession, withdraw consent for the collection, use, and/or disclosure of your personal information, or inquire about the details of this Privacy Policy, please contact us at:
ATTN: Privacy Officer
Salus Global Corporation
8 Prologis Blvd, Suite 102
Mississauga, Ontario, L5W 0G9
Please note that when requesting access to personal information, we may request confirmation of your identity to protect you.