Web User Privacy Notice

Updated: February 21, 2023

Policy

This web user privacy notice for Centretown Community Health Centre (doing business as CCHC) ('CCHC', 'we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your personal information when you use our web-based services (‘Online Properties’ and/or 'Services'), such as when you:

Visit our website at http://www.centretownchc.org, or any website of ours that links to this web user privacy notice.

Engage with us online in other related ways, including making inquiries, registering for and/or accessing Services, receiving promotional communications, or answering web surveys.

What personal information do we process? When you visit, use, or navigate our Online Properties and Services, we may process personal information, including but not limited to your name, contact information, location, and/or IP address, depending on how you interact with CCHC and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? As a healthcare providing organization, we may process sensitive personal information as well as personal health information in the course of normal business. We do so only with your consent or as otherwise permitted by applicable law.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information? We may share the personal information of our web users in specific situations and with specific categories of third parties for the purposes identified in section 3 (see “When and With Whom Do We Share Your Personal Information” below).

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. If a privacy breach is detected, it will be reported to our affected web user(s) at the earliest opportunity.

What are your rights? All of our web users have privacy rights enshrined by Canadian privacy legislation (PIPEDA). Clients who share personal health information with us via our website or other online properties also enjoy legal protections under Ontario’s Personal Health Information Protection Act (2014). At all times, you have the right to control when and how your information is used.

How do you exercise your rights? The easiest way to exercise your rights is by contacting our Privacy Officer (privacy@centretownchc.org). We will consider and act upon any request in accordance with applicable privacy laws.

Want to learn more about what CCHC does with any information we collect? Please read the procedure below.

Procedure

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you submit forms on our Online Properties and/or register for Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on our Online Properties, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
phone numbers
email addresses
mailing addresses
passwords
usernames
contact preferences
contact or authentication data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

health data
sociodemographic data (e.g. gender identity, race/ethnicity, indigenous status, household income)
provincial health insurance numbers or other government identifiers

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Online Properties.

We automatically collect certain information when you visit, use, or navigate our Online Properties. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Online Properties and/or Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access our Online Properties and/or Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Online Properties and/or Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Online Properties, including:

To facilitate user profile creation and authentication and otherwise manage user profiles. We may process your information so you can create and log in to your user profile, as well as keep your user profile in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.

To protect our Online Properties and Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To evaluate and improve our Online Properties and Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Online Properties and Services, products, marketing, and your experience.

To identify usage trends. We may process information about how you use our Online Properties and Services to better understand how they are being used so we can improve them.

To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

Cloud Computing Services
Communication & Collaboration Tools
Data Analytics Services
Data Storage Service Providers
Finance & Accounting Tools
Government Entities
Healthcare Providers & Tools
Payment Processors
Performance Monitoring Tools
Sales & Marketing Tools
User Profile Registration & Authentication Services

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this web user privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this web user privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an profile with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your user profile at any time.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your user profile, to respond to service requests, or for other non-marketing purposes.

User Profile Information

A web user profile is a collection of information that describes a specific user's characteristics, preferences, and behaviors on a particular website or online platform. This information is usually collected through the user's interactions with the website and can include data such as login credentials, browsing history, demographic information, and preferences for content, language, and notification settings.

The purpose of a web user profile is to help personalize your website experiences. In addition, a user profile can also help a website provide a more seamless and efficient user experience by remembering the user's preferences and automatically applying them on future visits.

If you would at any time like to review or change the information in your user profile or terminate your profile, you can:

Upon your request to terminate your user profile, we will deactivate or delete your profile and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Online Properties. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at privacy@centretownchc.org.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this web user privacy notice.

9. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this web user privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this web user privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this web user privacy notice frequently to be informed of how we are protecting your information.

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@centretownchc.org or by post to:

ATTN: Privacy Officer

Centretown Community Health Centre

420 Cooper Street

Ottawa, Ontario K2P 2N6

Canada

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by emailing privacy@centretownchc.org.