Effective Date: January 1, 2022
The purpose of this Policy is to describe our privacy practices, including the kinds of personal information we collect about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes your rights and the decisions you can make about your personal information.
We reserve the right to amend this Policy at any time by posting a revised version on our Website. We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the top of this Policy. Depending on the circumstances, we may also decide to send you a notice electronically that the Policy was changed. If you continue to use the Website or the Application after this Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.
Information We Collect
Information we may collect about you includes:
Account Information: When you sign up for an Embodia account or contact us, you voluntarily give us certain personal information, including your e-mail address and name. If you sign up as a patient of a health practitioner, you may be asked to provide additional information requested by your health practitioner at the time of signing up.
Questionnaires and Electronic Medical Record: If you are a patient, we collect information you submit to us if your health practitioner asks you to complete questionnaires on our Application. We may also receive personal health information if you or your health practitioner enrols in our electronic medical record service and uploads such information onto our Application.
Videos: If you are a patient, your health practitioner may request us to record videos of you to assist you in completing your exercises and to provide feedback. We only will record you with your consent.
Transactional Information: This includes your payment and financial information (such as your credit/debit card information, and/or banking information) and information on the services that you have purchased or are subscribed to.
Using Information We Collect
We may use the personal information we collect about you in order to:
- Communicate with you for the purposes you have separately indicated when you signed up to the Website or during your use of the Application;
- Learn more about you and your product preferences and to personalize your experience by looking at, among other things, the IP address of your computer and your activity on the Website and Application;
- Assist us with providing you with our services and a positive and secure experience on the Website and Application;
- Provide you with customer support services and to process your purchases of any of our services;
- Fulfill the purposes for which you provided the information or that were described when it was collected;
- For the management and administration of our business, and to address problems with, and to improve, our Website and Application design, services, and offerings;
- Identify and protect against fraud and other criminal activities;
- Comply with legal or regulatory requirements; and
- For any other purpose with your consent.
Sharing Your Personal Information
We share the information we collect about you with the other users you connect and communicate with on the Application and through our Website (such as between a patient and health practitioner). Connecting to other users requires both your consent and the consent of the other user.
In accordance with this Policy, we may also share your personal information with our service providers, such as those we rely on to host our Website and facilitate payments. We only permit service providers to process your personal information for specified purposes in accordance with this Policy and we require service providers to have appropriate safeguards in place to protect your personal information. We may also share information with our financial, insurance, legal, accounting or other advisors that provide professional services to us.
We may share your personal information with a third party if, in our good faith judgment, doing so is required to: comply with laws or regulations; respond to a valid subpoena, order, or government request; establish or exercise Embodia's legal rights or defend against legal claims; investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person; or as otherwise required by law. We do not sell or rent your personal information.
If Embodia is to be sold, merged or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition or disposal is completed, the purchaser may use and disclose your personal information only to the extent described in this Policy.
Lastly, we may share your information in any other way we may describe to you when you provide the information, or for any other purpose with your consent.
How Long We Retain Your Personal Information
We will retain your personal information to the extent necessary for the purposes for which it was collected as described in this Policy, to comply with applicable laws, to comply with Continuing Education Units (CEUs) guidelines, and for reasonable backup, archival, audit, or other similar purposes.
Your Decisions About Your Personal Information
At any time you can contact us to: stop receiving e-mails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which Embodia may have provided your personal information; close your account; and amend or request a correction of your personal information. You can always unsubscribe from receiving promotional e-mails from us by simply clicking the 'unsubscribe' link provided at the bottom of every promotional e-mail from us.
If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any personal information. If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.
Generally, you may withdraw at any time your consent for us to use and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to use your personal information as may be required to provide you with requested services, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent to use and disclose this information, we may no longer be able to provide you with the functionality offered by our Website and Application.
We use browser tracking cookies (or "cookies"), which are small text files that are placed on the hard disk of a computer by a website. Cookies are uniquely assigned to you, and can only be read by a website or web server that issued the cookie to you. Types of cookies we use include:
Strictly necessary cookies: These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website. This category of cookies cannot be disabled.
Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website.
We also use browser 'log files' which record certain information when you visit a website, including your internet protocol (IP) address.
We aim to provide you with a safe experience. We have in place reasonable physical, technical, and administrative safeguards to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying use or modification. Transmission of data from your computer or smartphone to our servers is done over a Secure Socket Layer (SSL) 256-bit encrypted connection. Please note, however, that while we try to create a secure and reliable Website and Application for users, the confidentiality of any communication or material transmitted to or from the Website or via e-mail cannot be guaranteed.
We limit access to your personal information within Embodia to individuals on a need-to-know basis and who have agreed to an information protection agreement which states the individual must have just cause for accessing personal information in an account.
Transferring Your Personal Information
Your personal information may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. 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.
If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of Embodia.
Links to Other Sites
Questions or Comments
If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us at firstname.lastname@example.org, or by delivery in person, by courier or by the mail to Embodia Privacy Officer at 6th Floor, 10 Dundas St E, Toronto, ON M5B 2G9. If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.
If after contacting us you do not feel that we have adequately addressed your concerns, you may contact:
The Office of the Privacy Commissioner of Canada