Papaya Health
Last modified: May 6, 2022
Papaya Health Inc. (“Papaya”, "Company" or "We") respects your privacy and has committed, through the implementation of this policy, to protecting your privacy by complying with the Freedom of Information and Protection of Privacy Act (R.S.O. 1990, c F.31). Papaya may be considered an agent under applicable health privacy information legislation, including Ontario’s Personal Health Information Protection Act (“PHIPA”) and its regulations. The Company may also act as a service provider, information manager, electronic service provider, or personal health information custodian under PHIPA and is committed to upholding the company’s obligations under PHIPA.
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.
PHIPA also defines “personal health information” (“PHI”) to include any information that
(a) relates to the physical or mental health of the individual, including information that consists of the health history of the individual’s family, or
(b) relates to the providing of health care to the individual, including the identification of a person as a provider of health care to the individual.
In this policy, “information” shall refer to both personal information and PHI.
This policy describes:
We will only use your 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.
Further, by accessing or using this Website, you are consenting to the collection, use and disclosure of your information, including your PHI.
You may also give this consent through a validly appointed substitute decision-maker. Substitute decision-makers can act on behalf of another individual. These include:
This policy applies to information we collect, use, or disclose about you:
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
This policy DOES NOT apply to information that:
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
We provide an opportunity for any user to unsubscribe from our appointment reminders, requests for service reviews, newsletters, and other electronic communications, 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 e-mailing to [admin@papayahealth.ca].
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
Information You Provide to Us
The information we collect directly from you on or through our Website may include:
You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies [alone or in conjunction with web beacons or other tracking technologies] to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising may help support our Website so that you can enjoy free content.
You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
We use information that we collect about you or that you provide to us, including any personal information, for the purposes listed above, and specifically:
We may also use your information to contact you about our own and third-parties' 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 order form/registration form), use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at [admin@papayahealth.ca]. For more information, see Choices About How We Use and Disclose Your Information.
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.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
We may also disclose your personal information:
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, including the PHIPA.
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
The security of your personal information is very important to us. 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 are committed to ensuring that your information, and especially your PHI, is not lost, stolen, or used by anyone that should not have access to it. We will also ensure that it is kept private and stored and disposed of, in a secure way. We will ensure that everyone who performs services for us protects your privacy and only uses your information in the way you have agreed it can be used.
If consent is given to let a family or legal representative have access to your PHI, these representatives may have access to those parts of your health records that have been identified in the consent authorizing them to act. You have the right to withdraw or change the conditions of this consent, subject to provisions set out in the PHIPA.
We employ structural, organizational and technological safeguards to protect your PHI against unauthorized access and loss. All staff that come into contact with your PHI are aware of its sensitive nature and are trained in the appropriate use, disclosure and protection of your PHI. We also require any third party organizations, vendors and other contractors to protect the privacy of your PHI and to use such information only for the purposes you have consented to, or that are permitted or required by PHIPA.
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.
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.
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [support@papayahealth.ca].
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the information, and particularly the PHI, 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.
You can review and change your personal information by logging into the Website and visiting your account profile page.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [support@papayahealth.ca] to request access to, correct, or delete any personal information that you have provided to us. 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 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:
If you are concerned about our response or would like to correct the information provided, you may contact our [Privacy Officer/[Brenda De Silva] at [Brenda@papayahealth.ca].
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. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use [https://www.papayahealth.ca/term-condition].
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 us at [support@papayahealth.ca]. 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.
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by through a notice on the Website home page.
We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:
[Brenda De Silva]
[brenda@papayahealth.ca]
[and/or via our toll-free number:
[1-877-515-0887]]
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our [Privacy Officer] using the contact information listed above.
You have the right to make a complaint to the Information and Privacy Commissioner of Ontario, if you are concerned with how we have handled your PHI.
The Commissioner can be reached at:
The Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto ON M4W 1A8
1-800-387-0073
Fax: 1-416-325-9195
www.ipc.on.ca