- The types of personal information collected, accessed, used, or otherwise processed by the Mobile App (the “App”);
- Our practices for collecting, using, maintaining, protecting, and disclosing that personal information; and
- How information is shared, including (without limitation) with your employer (“Employer”) in connection with your potential attendance at your workplace or other property or premises you may visit in connection with your employment (collectively “Establishments”).
This Policy applies only to information about identifiable individuals (“personal information”), which We collect in this App and other electronic communications sent through or in connection with this App.
This Policy does not apply to information that:
- We collect offline or on any other Company apps or websites, including websites you may access through this App.
- You provide to, or is collected by, any third-party (including your Employer).
- Information that is not about an identifiable individual, where there is no serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.
Our websites, our other apps, and other third-parties may have their own privacy policies, which We encourage you to read before providing information on or through them.
Users Under the Age of 18
The App is not intended for use by individuals under 18 years of age, and We do not knowingly collect personal information from individuals under 18. If We learn we have collected or received personal information from a user under 18 without verification of parental consent, We will delete that information.
Information We Collect and How We Collect It
We collect information from and about users of our App, on behalf of your Employer, as follows:
- We collect information about you, directly from you, when you provide it to Us by downloading and registering to use the App;
- We collect information about you, directly from you, when you provide it to Us by answering the Health Questionnaire (as defined below); and
- Certain information is collected automatically when you use the App.
Information You Provide to Us
When you download, register with, or use this App, We may ask you to provide certain information, including your name, email address, phone number, employer name, and office address.
Health Questionnaire Information
Each day that you wish to enter a participating Establishment, the App will ask you questions that will assist in determining if you are presenting risk factors that may prohibit you from entering that Establishment (“Health Questionnaire”). These questions will relate to risk factors associated with contagious illnesses. Accordingly, some personal health information will be collected via the App.
Automatic Information Collection and Tracking
When you download, access, and use the App, the App may use technology to automatically collect:
- Usage Details. When an individual accesses or uses the App, we may automatically collect certain details, including page views, clicks, communication data and any other resources accessed or used on or through the App.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
- Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
- Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, verifying system and server integrity).
How We Use Personal Information
We use the personal information that We collect, or that is provided to Us, in order to:
- Provide our services to your Employer, including confirming that you meet the criteria to enter any relevant Establishment.
- Assist your Employer to meet its legal obligations, including with respect to screening employees or visitors for risk factors associated with contagious illnesses, logging visitor information, and complying with any reporting obligations associated with health risks.
- Perform contact tracing and exposure notifications if required or requested by your Employer.
Disclosure of Your Information
We will disclose your personal information to your Employer, for the purposes of providing our services. The information that we disclose to your Employer includes your name, the results of your Health Questionnaire(s), and the dates and times of your entry into any relevant Establishment. Information disclosed to your Employer will be used by your Employer for the purposes of:
- Screening employees or visitors for risk factors associated with contagious illnesses.
- Determining whether you are permitted to enter any relevant Establishment(s);
- Logging visitor information;
- Contact tracing, if you report any risk factors or are diagnosed with a contagious illness;
- Complying with any reporting obligations associated with health risks; and
- Any other purposes disclosed to you by your Employer.
Information that is disclosed to your Employer will be handled in accordance with the privacy and data protection policies, procedures and practices of your Employer. Your Employer may also further disclose your information to third parties at your Employer’s discretion. We are not responsible for the actions or omissions of your Employer, including for any use or disclosure of your personal information (or failure to protect your personal information) by your Employer. If you have any questions regarding how your information will be handled by your Employer, you should contact your Employer directly.
We may also disclose personal information that We collect or that you provide to Us through, or in connection with, the App, as follows:
- To our subsidiaries and affiliates, including Angus Systems Group, Inc., for the same purposes that We use the information.
- To government and regulatory bodies and institutions when required by law, including public health authorities. We also reserve the right to voluntarily provide information to public health authorities in a de-identified and aggregated form.
- For any other reasonable purpose disclosed by Us when you provide the information, with your consent (express or implied, as appropriate, in accordance with applicable laws).
- Where otherwise required by applicable law, including to comply with any court order, law, or legal process.
- Where permitted by applicable law, if We believe disclosure is necessary or appropriate to protect the rights, property, health or safety of the Company, our affiliates and subsidiaries, our clients, or others.
Some of our affiliates, subsidiaries and service providers may be located outside the country in which you reside. Personal information will be stored in Canada and the US, and therefore, may be accessible to courts, law enforcement, and national security authorities in either or both of these countries.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
Retention of Your Information
We will retain your personal information for as long as necessary for the purposes set out in this policy. If you no longer want us to use your personal information you may close your account by contacting us to make such a request as set out below (see Contact Information), subject to providing satisfactory proof of identity where applicable. We will retain your personal information to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, your Employer may also be required to retain and use your personal information in order to comply with their own legal obligations.
Accessing and Correcting Your Personal Information
Individuals who wish to access, erase, change, rectify, update or restrict the processing or object to the processing of any personal information, may contact us to make such a request as set out below (see Contact Information), subject to providing satisfactory proof of identity where applicable. Such requests will be considered, and handled in accordance with the applicable laws in the jurisdiction where you work.
Your California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We will not use the information obtained from this App for those purposes.
We have implemented measures designed to secure personal information from theft, accidental loss, and from unauthorized access, use, alteration, and disclosure. All personal information that you provide to Us, or that We otherwise collect in connection with the App, is encrypted and stored on our secure servers behind firewalls.
The safety and security of the information also depends on you. Where We have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential and secure. We recommend that you choose a secure password, and We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although We endeavour to protect the information that is provided to Us, We cannot guarantee the security of information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures We implement.
The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Policy to check for any changes.
You may contact our General Counsel at Legal@angus-systems.com, 1125 Leslie Street, Toronto, ON M3C 2J6, or 416-385-8550, in order to obtain information about this Policy or our handling of your personal information, or to submit a request to access, update or rectify your personal information.
Last modified: August 7, 2020