Last Updated : 2023-09-22
We collect and use several types of information from and about you, including:
Non-Personal Information: 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 any specific feature from any of our Websites or Apps. This type of information will not allow us to personally identify you.
Personal Information: personal information refers to any information concerning a natural person that enables that person to be identified, directly or indirectly (“Personal Information”). To use our Services, you must first provide such Personal Information about you that will allow you to be identified. This type of information will not be collected without your consent. For certain parts of the Services, such as creating an account, we collect Personal Information that you voluntarily provide to us using the Services, and could include information such as your name, email address, telephone number, mailing address, date of birth and personal information in relation to your health, (if applicable to the Services provided).
Personal Information provided to us by third parties: We may obtain Personal Information about you through other third parties, such as when you register with such party (e.g. your employer) to start benefiting from any of our Services they make available to you via their employee benefits, health services portal, or any website or mobile application. We may also automatically import some of the Personal Information that you provide to such third parties into your account to use our Services.
Technical Information: such information includes 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 Websites and/or Apps, and usage details.
Non-personal details about your Website or App interactions: such information includes the full Uniform Resource Locators (URLs), clickstream to, through and from any of our Websites and Apps (including date and time), products and services 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 number.
- Details of your visits to, and use of, our Websites and Apps, including traffic data, location data, and other communication data and the resources that you access and use via the Websites or Apps.
- Information about your mobile device and/or computer and internet connection, including your IP address, operating system, and browser type.
- metadata and other information associated with other files stored on your device (when using our Apps). This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Automatically collected information: The information we collect automatically is statistical information and may include Personal Information, and we may maintain it or associate it with Personal Information that you provide to us, or receive from third parties. It helps us to improve our Websites and Apps and to deliver better and more personalized Services, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our Websites and Apps according to your individual interests, and recognize you when you return to our Websites or Apps.
The technologies we use for this automatic data collection may include, but are not limited to:
Web Beacons: pages of our Websites, our Apps, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages, used the Apps or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
In the course of its activities as an employer and recruiter, HALEO collects, uses and communicates Personal Information. For our employees, this collection falls within the essential management of labor relations. As for job applicants, their information is collected and used to assess their suitability for available positions, which may involve information obtained from third parties for background checks or professional references. If an applicant is not selected, their information is retained for a reasonable period of time for future opportunities, unless a request for deletion is made. In addition, we maintain certain Personal Information on our former employees, including their names and contact details, for possible professional or regulatory requirements.
4. HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
- Direct interactions with you: when you provide us information, for example, by filling in forms, creating an account, applying for a job opening, or corresponding with us by phone, email, or otherwise;
- User contributions: you may also provide information for us to publish or display on public Website areas or transmit to other Website or App users or third parties;
- Automated technologies or interactions: as you navigate through our Websites or use our Apps. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
- Third parties or publicly available sources: for example, our business partners, or your employer and/or their employee benefits provider.
The purpose of our collection and use of Personal Information is to:
- Provide, maintain, execute and improve the Services;
- Run and improve advertising campaigns (read further below on our “Advertising Purposes”)
- Create your account so you may access and benefit from the Services;
- Invoice for our Services;
- Perform internal operations, including, for example, preventing fraud and abuse of our Services to resolve software problems and operational problems, to perform data analysis, testing and research and to monitor and analyze trends in use and activity;
- In the case of job applicants, to contact the applicant and assess whether we will hire them;
- Managing our employment relationships;
- Send you our newsletter or any other communication that may be of interest to you, including information about products, services, promotions, and news, and for marketing campaigns destined to our users that promote our products and services, or to offer you the products and services of our trusted partners, provided that you have given your explicit consent to receive such communications, and that you can withdraw your consent at any time by following the unsubscribe link provided in such communications or by contacting us;
We may also use and disclose your Personal Information for the following purposes: (i) to enforce the terms of any agreement between you and us; (ii) to protect the rights, property, or security of any individual or entity; or (iii) when mandated by applicable laws or in response to a lawful request from government authorities. Additionally, we may anonymize and aggregate certain Personal Information for research or development purposes related to the Services.
In furtherance of our commitment to offer tailored experiences and promotions to our customers, we may share specific Personal Information, namely email addresses and phone numbers, with trusted third-party advertising platforms, notably Google Ads and Google Analytics.
This collaboration allows us to gauge the impact and success of our advertising endeavours, ensuring our customers receive pertinent and beneficial offers. Such data-sharing is exclusively purposed for this objective and is governed under our rigorous data protection protocols.
Our use of Google Ads and Google Analytics might involve tools facilitating targeted advertising based on Personal Information we submit to such tools. We remain dedicated to ensuring that any shared data is utilized in alignment with our privacy principles and in compliance with prevailing laws and statutes.
Customers reserve the right to opt-out of this specific Personal Information sharing. To exercise this privilege or to glean further insight into our data management practices, please contact firstname.lastname@example.org.
We expressly acknowledge that we will not use your Personal Information for any other purpose without your consent. We will only collect Personal Information to the extent necessary for the purposes described above.
6. RIGHT TO EXAMINE INFORMATION
You have the right to review the Personal Information we collect. If you would like to review this information, please send a written request to email@example.com. We reserve the right to charge you a reasonable administrative fee to access your information in accordance with applicable laws. In some cases, we may not be able to give you access to all of your Personal Information (eg, if the information also relates to another person’s Personal Information).
7. PROMOTIONAL COMMUNICATIONS
You may choose not to receive promotional messages from us by following the instructions in these messages. If you unsubscribe, we may still send you non-promotional communications, such as those about your account, the Services you requested, or our current business relationship with you.
8. SHARING INFORMATION
We do not sell, lease nor rent to anyone the Personal Information we collect and store. We do however communicate the Personal Information we have collected with certain third parties as follows:
- Statistical Analysis: We may share Non-Personal Information and Personal Information that has been anonymized and aggregated with third parties, including but not limited to statistical, machine learning, advertising, or marketing purposes. No Personal Information will be shared in this way.
In addition, our Services may integrate with online platforms of third parties that provide marketing and management tools to companies to help us deliver the Services to you, which means in such cases that your Personal Information may be shared with such third parties to provide the Services.
By submitting your Personal Information or engaging with any of our Websites or Apps, you consent to such communication of your Personal Information.
10. COMMUNICATING YOUR PERSONAL INFORMATION OUTSIDE OF QUEBEC OR CANADA
When data is located outside of Canada, it may be accessible by foreign governments, courts and law enforcement authorities, if required by law or court order. We only communicate or otherwise transfer Personal Information outside of Canada in compliance with applicable Canadian laws and for lawful purposes.
When we do communicate Personal Information outside of Quebec, and sometimes outside of Canada, we do so only to perform the Services, or to support our business in order to be able to perform our Services reasonably efficiently and to offer them at commercially reasonable costs.
Before communicating Personal Information outside of Quebec, we conduct a privacy impact assessment in compliance with applicable Quebec law. This assessment evaluates: (i) the sensitivity of the information; (ii) the purpose of its use; (iii) the safeguards in place, including contractual safeguards; and (iv) the legal regime applicable in the jurisdiction to which the information would be communicated, particularly the principles of protection of Personal Information applicable there. Personal Information is communicated only if the assessment demonstrates that the information would benefit from adequate protection, particularly in accordance with generally recognized privacy principles. We encourage you to review the privacy policies and terms of service of each third-party service provider you interact with.
11. THIRD PARTIES AUTHORIZED TO RECEIVE PERSONAL INFORMATION
Below is a list of the third-party online service providers that we use for the provision of our Services and to whom we may transfer some of your Personal Information to enable us to perform the Services:
- Salesforce (salesforce.com) – for customer relationship management (CRM) and sales automation.
- Hubspot (hubspot.com) – for marketing automation, customer relationship management (CRM), and sales automation.
- Microsoft 365 (microsoft.com/microsoft-365/) – for email, document collaboration, and other business productivity tools.
- Calendly (calendly.com) – for scheduling and managing appointments.
- Active Campaign (activecampaign.com) – for marketing automation, email marketing, and customer relationship management (CRM).
- Clickup (clickup.com) – for project management and collaboration.
- Medstack (medstack.co) – for cloud hosting and data privacy compliance.
- Azure (azure.microsoft.com) – for cloud hosting and data privacy compliance.
- Stripe (stripe.com) – for payment processing.
- Webflow (webflow.com) – for website design and development.
- Amazon Web Services (aws.amazon.com) – for cloud hosting and data privacy compliance.
- Quickbooks (quickbooks.intuit.com) – for accounting and financial management.
- Docusign (docusign.com) – for electronic signature and document management.
- Google Analytics (analytics.google.com) – for website traffic analysis and reporting.
- Google Ads (ads.google.com) – for online advertising and pay-per-click (PPC) campaigns.
- Google Tag Manager (tagmanager.google.com) – for tag management and deployment of marketing and analytics tags.
- Amplitude (amplitude.com) – for product analytics and user behavior analysis.
- Meta Pixel (facebook.com/business/tools/meta-pixel) – for tracking conversions and creating custom audiences for Facebook advertising.
- LinkedIn Insights (business.linkedin.com/talent-solutions/talent-insights) – for analyzing job market trends and talent acquisition insights on LinkedIn.
Please be advised that we do not control the practices of the above third-party service providers, but we have entered into written agreements with each of the above third-party service providers. Under the terms of these agreements, each third-party provider undertakes to comply with all applicable laws, including those related to the protection of Personal Information. Some of these third-party service providers may not be located in Quebec; therefore, Personal Information may be communicated outside of Quebec to these third parties to enable them to support our business operations, but such Personal Information will only be communicated to them if necessary for the purposes you have given us authorization for..
12. PERSONAL INFORMATION AND INFORMATION SECURITY GOVERNANCE POLICIES
Our Commitment to Your Privacy. We take the security and responsible management of your Personal Information extremely seriously. Our governance policies, specifically tailored for Personal Information and information security, have been formally approved by our Privacy Officer. These protocols are designed to match the scope and complexity of our various business activities. The following subsections provide comprehensive details in clear and simple terms to inform you about our governance policies and practices concerning Personal Information.
Data Lifecycle Management. Our protocols cover the full life cycle of your Personal Information. We retain your Personal Information only as long as necessary to fulfill the purposes for which it was initially collected. After the Personal Information has served its purpose, we ensure its secure and responsible destruction or anonymization, following strict guidelines, unless applicable law requires us to keep them longer.
Handling Complaints. In line with our commitment to the protection of Personal Information, we have established a formal process for receiving, investigating, and resolving any complaints about the safeguarding of your Personal Information.
Security Measures. To protect your Personal Information, we employ a multi-layered security approach that includes physical, electronic, and administrative measures to prevent unauthorized access, usage, alteration, and disclosure of your Personal Information.
While these security measures align with industry best practices, it is important to acknowledge that the absolute security of your Personal Information during online transmission or when using Internet services cannot be unconditionally guaranteed. Such transmissions are, therefore, at your own risk.
We strive to present this policy in a straightforward and easily understandable manner, ensuring you are fully aware of how we handle your Personal Information.
13. 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.
14. EMPLOYEES, AGENTS AND SELF-CONTRACTORS
15. THIRD PARTY LINKS
16. THIRD PARTY TRACKING TECHNOLOGIES
17. CONTACT US
18. PRIVACY OFFICER
If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may send us an email at the email address of the privacy officer to request access to, correct, or delete any Personal Information that you have provided to us.
HALEO PREVENTIVE HEALTH SOLUTIONS INC.
Whenever you provide your consent to the collection, use, communication and retention of your Personal Information, you have the legal right to withdraw such consent. To withdraw consent, if applicable, contact the Privacy Officer. Please note that if you withdraw such consent, we may not be able to provide you with our Services. Please note that we will send you a confirmation email upon receipt of your request.
The Services are not intended for persons under 15 years of age. If HALEO realizes that Personal Information about people under the age of 15 has been inadvertently collected, it will delete it without delay.
20. TERMS AND CONDITIONS OF USE
HALEO’s Policy and General Practices are designed to ensure compliance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”, SC 2000, c.5) of Canada and the Act respecting the protection of personal information in the private sector (CQLR c P-39.1) of the Province of Quebec. If you have any questions regarding compliance with these laws, please contact us at the above address.