Purpose of this Policy

The purpose of this Privacy Policy is to let you know what kind of information ConnexHealth Inc. (Connex, we, us and our) may gather about you. Connex values our customers and we respect your privacy and personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws).

This privacy policy (“Privacy Policy” or “Policy“) describes how Connex treats your personal information obtained through the ConnexHealth.ca website and any subdomains [ConnexMatch.ca, ConnexNav.ca, ConnexPets.ca and ConnexKids.ca] thereof, including those linked in the footer of the ConnexHealth.ca website (collectively “Website“, any mobile application (“App“) owned and operated by Connex (collectively referred to as “Platform“) in this Privacy Policy and as a result of accessing any other services provided by Connex (the “Services”). The Policy describes the kinds of personal information Connex collects 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 the decisions you can make about your personal information. You may require us to change, amend or delete the personal information that you have provided to us at any time.

Connex’s Privacy Policy is governed by the information handling practices of the Personal Information Protection and Electronic Documents Act (PIPEDA), Personal Health Information Protection Act (PHIPA), and applicable provincial and professional standards.

At Connex, all employees are accountable and committed to ensuring that your personal information is held in the strictest confidence. As required, Connex will amend this document and its Privacy Policy when changes to privacy legislation or best practices are known.

The Platform may contain links to third parties’ websites or apps. We are not responsible for the privacy practices or the content of those websites. The Platform may also contain links to terms and conditions and privacy policies of third-party providers who provide tools or services on a website. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those tools, services or websites

Definitions

The following definitions apply in this Privacy Policy:

1. “Account” means your membership account with ConnexHealth Inc.;
2. “Client Member(s)” means Users who establish an Account with ConnexHealth Inc. to access the services of Service Provide Members;
3. “Personal Information” means individual’s identifiable information such as their name and date of birth.
4. “Policy” means this Privacy Policy as amended from time to time;
5. “Privacy Act” means, collectively, PIPEDA, PHIPA and any other legislation that may be relevant to the business of Connex;
6. “User Agreement” means the agreement between Connex and each User of the Website which sets out the terms and conditions in respect to the Site, and is located at ConnexHealth.ca/terms-of-use;
7. “Service Provider Member(s)” means a member that provides services to Client Members;
8. “Users” or “Member: means Client Members and Service Provider Members Collectively and Visitors; and
9. “Visitors” means individuals who visit and browse the Site but do not create an Account.

Unless the context provides otherwise, capitalised terms not defined in paragraph 2.1 or elsewhere in this Policy have the meanings given in our Terms of Use Agreement located at ConnexHealth.ca/terms-of-use

 Who does Connex collect Personal Information from?

We may collect Personal Information from:

1. Visitors when they visit our Webite; and
2. Users.

User consent

By submitting Personal Information through our Website or Services (including when you register yourself or another person as a User), you agree to the terms of this Policy on your own behalf or on behalf of the person whose information you are submitting, and you expressly consent to the collection, use and disclosure of that Personal Information in accordance with this Policy.

Types of data we collect

The information Connex collects about you depends on how and why you access our Website and use our Services.

We collect Personal Information and anonymous data, as described below.

a. Information you provide to us
i. If you are a Service Provider Member, when you create an Account, we will collect Personal Information from you, such as your first and last name, birth date, driver’s license number, other information by which we can identify you or verify your identity (such as passport details), your certification to work with our Client Members, the results of any applicable screening checks, your criminal history, ethnicity, gender, religion, email and mailing address, phone number, work experience, salary/income, professional license numbers, education, interests, hobbies, professional and personal references, profile picture and video, professional skills and abilities, life style information, schedule availability, music preferences and bank information to facilitate direct deposit of earnings; or

ii. If you are a Client Member, when you create an Account, we will collect Personal Information from you, such as your first and last name, birth date, driver’s license number, other information by which we can identify you or verify your identity (such as passport details), your criminal history, gender, religion, email and mailing address, phone number, family or emergency contacts, care services needed, care plan, health conditions, activities, interests, music preferences, household information and credit card information to facilitate payment processing.

b. Sensitive Information

i. We may collect sensitive information (including health information) from Client Members and Service Provider Members when they choose to provide information about themselves or someone else on whose behalf they are authorized to act, and (in the case of Client Members) their care requirements, through the Website.

c. Other ways we may collect Personal Information

i. We collect and retain information on your behalf, such as files and messages that you store using your Account.

ii. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the message, in order to send you a reply or otherwise action your feedback.

iii. When you post messages or upload content within our Website, the information contained in your posting will be stored on our servers, and other Users to whom you provide access will be able to see such messages and content.

iv. We also collect other types of Personal Information that you provide to us voluntarily, such as your operating system and version, and other requested information if you contact us via e-mail regarding support for the Services.

v. We may also collect Personal Information at such other points in our Website that state that Personal Information is being collected. Please note that you can choose not to provide us with certain information, but this may limit the features of the Site or Services you are able to use.

d. Information collected via technology

i. To make our Website and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address, domain name, and/or a date/time stamp for your visit.

ii. Connex uses cookies on our Website. Cookies are very small files which a website uses to identify you when you come back to the website, and which store details about your use of the website. We use cookies to improve the experience of Users and enable Users to access secure areas of our Website. You may choose to disable cookies by adjusting the privacy settings in your browser, but you may not be able to access some parts of our Website or Services if you do so.

iii. We may also use or enable third party analytics services to track and analyze anonymous data from Users of our Website and Services.

iv. If, in future, you use the location-enabled services, Connex may receive information about your actual location (such as GPS signals sent by a mobile device or via your web browser when on the Site).

e. Information collected from others about you

Other Users may provide us personal information about you through our Website or the Services. Examples include when a Client Member posts feedback regarding a Service Provide Member, when a Service Provider Member uploads notes or other information regarding a Client Member to our Website.

f. Information collected from third parties

We may receive personal information and/or anonymous data about you from companies that assist Connex in providing the Services, such as service providers who assist with identifying you or verifying information provided by you (e.g. your police check), or companies that offer their products and/or services on our Site
.
g. Unsolicited Information

Where we collect unsolicited information (being information provided to us without us having sought the information), we will only hold, use and disclose that information if we could otherwise do so had we collected it by the means described above. If that unsolicited information could not have been collected by the means described above, then we will destroy, permanently delete or de-identify the information as appropriate.

Use of Your Personal Information

General use

In general, we use the personal information we collect either to provide the Services to you, to respond to requests that you make, or to aid us in serving you better, including in the following ways:

1. to facilitate the creation of, and secure, your Account on our network;
2. to send you a welcome e-mail and to verify ownership of the e-mail address provided when Your Account was created;
3. to identify you as a User in our system;
4. to prompt you to set up your profile after you have created your Account (if you do not do so at the same time as creating your Account);
5. to run or verify background checks, including police, reference and other screening checks;
6. to verify your credentials;
7. to provide improved administration of our Website and Services;
8. to provide the Services you request;
9. to improve the quality of experience when you interact with our Website and Services;
10. to tailor the features, performance and support of the Website or Services to you;
11. to send you administrative e-mail notifications, such as security or support and maintenance advisories, or to inform you when our Terms of Use Agreement or any of our policies (including this Policy) have been updated;
12. to respond to your inquiries or requests and/or troubleshoot problems;
13. to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
14. to send newsletters, surveys, offers, and other promotional materials related to our Services and for other ConnexHealth Inc. marketing purposes;
15. to customize the advertising you may see on the Website or through the Services;
16. to collect and/or distribute money; and
17. to verify your compliance with your obligations in our Terms of Use Agreement or other ConnexHealth Inc policies.

Creation of Anonymous Data

We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyse request and usage patterns so that we may enhance the content of our Services and improve Website navigation. Connex may use anonymous data for any purpose and may disclose anonymous data to third parties as it sees fit.

Disclosure of Your Personal Information

We may disclose your Personal Information as described below and as described elsewhere in this Policy.

Disclosure to other Users

1. We may share your Personal Information with third parties to whom you ask us to send (or otherwise make available) that information, including other Members. Except:
2. 1. for those Users to whom you direct us to provide access to your personal information (via your Privacy Settings or otherwise); and
   2. as described in paragraph (b) below,
4. we do not disclose the personal information of any Member to any other Member. We do, however, provide other Service Provider Members with the opportunity to communicate with you through an anonymous in-browser message box.
5. If you are a Service Provider Member, we will display, your username and the first few words of your profile description, in a results listing if a Visitor or a Member has searched for Service Provider Members in or near your area. However, your full profile can only be viewed by Members who have signed in to their Account, not by Visitors.
6. Service provider Members and Client Members are described on the Website by their first name and first initial of their surname only. When a Client Member and a Service Provider Member wish to make contact with each other for the purposes of arranging for contracting for Services, Connex will release personal information about each person to the other person (this will include each person’s full name and contact details, and may include health information and other sensitive information collected by us in accordance with this Policy).
7. If you are a Service Provider Member, we may provide a copy of your police check, working with children check, any other applicable screening checks and certifications, references, qualifications or other profile documents to Client Members who engage you on the Website.

Third party service providers

1. We may share your Personal Information with our third-party service providers to:
2. 1. provide you with the Services that we offer you through our Website;
   2. conduct quality assurance testing;
   3. facilitate creation of accounts; and
   4. provide technical support.

2. Examples of such third-party service providers include companies that administer and verify background checks, and companies that process payments from both Service Provider Members and Client Members. We take reasonable steps to ensure these third-party service providers do not use your Personal Information other than to provide the services requested of them by Connex.

Marketing Direct

1. As indicated above Connex may use information collected from or about you for the purpose of sending you marketing and promotional information and materials.
2. If you wish to opt out of receiving direct marketing communications from Connex, please use the unsubscribe option (in the case of e-mail communications) or contact us directly using the details below. If you wish to opt-out of receiving direct marketing communications from third party organizations to whom we have disclosed your Personal Information, you may make a separate request to that organization.

Marketing on third party sites

We may disclose your Personal Information, such as your email address and telephone number, to the operators of other websites, social media platforms and search engines, so that we may deliver tailored advertisements to you via those websites, platforms and search engines.

Affiliates and acquisitions 

1. We may share some or all of your Personal Information with our related, affiliated or subsidiary companies joint ventures, or other companies under a common control, all as defined in the Business Corporations Act (Ontario) (“Affiliates”), in which case we will require our Affiliates to honor this Policy.
2. If another company acquires the shares in ConnexHealth Inc., the business, or our assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Policy.

Disclosure of Personal Information to overseas entities

 We may transfer or otherwise disclose your Personal Information to third parties located outside Canada, including to third parties who provide information technology and other services to us. Those third parties may be located in the United States or other countries. By providing Personal Information to us, you consent to the transfer of that Personal Information to entities located outside Canada.

Other disclosures

1. Regardless of any choices you make regarding your Personal Information (as described herein), Connex may disclose Personal Information to third parties if it believes in good faith that such disclosure is necessary:
2. 1. in connection with any legal investigation;
   2. to comply with relevant laws, or to respond to subpoenas or warrants served on us;
   3. to lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;
   4. to investigate or assist in preventing any violation or potential violation of the law;
   5. where another permitted general situation or permitted health situation (as defined in the relevant legislation) applies; and/or
   6. where disclosure is reasonably necessary for a law enforcement related activity.

2. If you are a Client Member, you acknowledge that a Service Provider Member may use Personal Information about your emergency contact to get in touch with that person if necessary.

Data collection

Information collected by ad networks

We may use third-party advertising companies to serve ads when you visit our Website. These companies may collect and use information (not including your name, address, email address, or telephone number) about your visits to the Website and other websites in order to provide advertisements about goods and services to you that are tailored to your interests. This information is collected using cookies. As indicated above, you can disable cookies by changing your browser settings, but if you do, some parts of our Website may not function properly.

Information collected by other third parties

1. This Policy addresses only our use and disclosure of Personal Information we collect from and/or about you. If you disclose information to others, including to other Users, those persons or organizations will not be bound to act in accordance with this Policy.
2. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

Your choices regarding your personal data

Unless you become a Member, Connex does not collect information that identifies you personally.

Choices about marketing

1. We offer you choices regarding the collection, use, and sharing of your Personal Information.
2. We will periodically send you free newsletters and e-mails, SMSs or other marketing communications that directly promote the use of our Website or Services (unless you have previously requested not to receive such communications from us). As we indicated herein, when you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to opt-out by following the unsubscribe instructions provided in the e-mail you receive, or by contacting us directly (please see contact information below). Our electronic marketing activities will comply with the requirements of all relevant anti-spam legislation.
3. Even if you request not to receive direct marketing communications from us, we may send you Service related communications, including notices of any updates to our Terms of Use Agreement or this Privacy Policy.

9.3 Deletion of Personal Information

1. You may request deletion of your Personal Information by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
2. If we no longer need your Personal Information for any purpose for which it may be used or disclosed under privacy legislation, and the information is not otherwise required to be kept under Canadian law or court order, we will take reasonable steps to destroy or permanently de-identify the information.
3. When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud protection or similar purposes if this is permitted pursuant to Canadian law or court order.
4. If we have already disclosed some of your Personal Information to third parties, we cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

Security of your Personal Information

Connex is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorised access, use, and disclosure.

Any information which we hold about you is stored on secure servers that are protected in controlled facilities. We also require you to enter a password to access your Account information. Please do not disclose your Account password to anyone who you do not wish to access your Account. We will assume all activity taking place on your Account is either being conducted by you or is authorised by you.

Please notify us immediately if you become aware of any actual or suspected unauthorised use of your Account, or any breach of security relating to your Account.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, so while Connex uses reasonable efforts to protect your Personal Information, we cannot guarantee its absolute security.

In addition, our employees and contractors who provide services related to our information systems are obliged to respect the confidentiality and privacy of any Personal Information held by Connex.

Access to your Personal Information

You can request access to the Personal Information we hold about you by contacting us using the details below.

We will generally allow you to access the Personal Information we hold about you if you request it, but we may refuse access if we are permitted or required by law to do so.

We will process requests for access to Personal Information within a reasonable time, and we may charge you reasonable costs associated with providing access (for example, to cover the costs of verifying the request and retrieving the information).

If we refuse to provide you with access to your Personal Information, we will generally provide reasons for the refusal.

Correction of your Personal Information

We take reasonable steps to ensure the Personal Information we hold about you is accurate, complete and up to date.

Please advise us if you think any of the information, we hold about you is incorrect, incomplete or out of date. You may also change or update your Personal Information by logging into your Account and editing your Profile.

If you ask us to correct your Personal Information, we will take reasonable steps to validate and correct the information, or we will provide reasons for not doing so. If we do not correct your Personal Information, you may make a statement about the requested change and we will take reasonable steps to attach this to the Personal Information in question.

Complaints

If you have any complaints about our dealings with your Personal Information, including any breaches by us of any privacy legislation, you are able to submit that complaint by contacting us using the details below. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and information.

Complaints will be referred for investigation by our Privacy Officer and a response will be provided to you within a reasonable time (usually no longer than 30 days). We may seek further information from you in order to provide you with a full and complete response.

If you are not satisfied with the outcome of our investigation, you can contact us to raise your concerns, or you may wish to contact the Office of the Information and Privacy Commissioner of Ontario (www.ipc.on.ca) by telephone at (416) 326-3333, by email to info@ipc.on.ca, or by mail addressed to: 2 Bloor Street East, Suite 1400 Toronto, ON M4W 1A8.

Changes to this Privacy Policy

We may update this Policy from time to time. We will post the updated Policy on our Website, so please check regularly for any updates. The updated Policy will take effect from the date of posting.

Your continued use of our Website or Services, or provision of further Personal Information to us after this Policy has been updated, will constitute your acceptance of the amended Policy.

Contact Information

Connex welcomes your comments or questions regarding the Website, our Services, or this Policy.

Please contact us using the following details.

• Email: support@connexhealth.ca
• Telephone: 647-273-2000
• Mail: 739 D’Arcy St Cobourg, ON K9A0H6

This version of the Privacy Policy has been last updated on November 18, 2019.

The Connex Website provides a platform where care workers can offer home care services to Client Members. We have made a commitment to protect vulnerable people and make sure that they are not placed at unreasonable risk by using our service.

Accordingly, Connex conducts police checks on all of its Service Provider Members. As a result of our commitment to providing a safe environment for all Users, we require all Service Member Providers using the Website:

• Provide : https://secure.tritoncanada.ca/Eiv/InitiateEiv?id=ed2307f4-0494-a92e-ea36-bfb5ad4157b2&language=en

• Notify us immediately if they are charged with, or are convicted of any criminal offence by emailing support@connexhealth.ca

Our responsibilities

All Connex authorised personnel:

1. Are responsible for the management and protection of police history information at all times.
2. Must not retain or reproduce police history information.
3. Assess what information needs to be disclosed on a case by case basis against the inherent and / or essential requirements of the position.
4. Act as the point of contact for the Service Provider Members and Connex employees for matters relating to police checks, this policy and associated procedures and guidelines.

We will keep a copy of the police check supplied by a Service Provider Member for three years.

What we will do with the information

In reviewing a police check, we will always comply with all relevant legislation of Ontario and Canada, or any state and territory or local authority, in particular legislation which prevents discrimination on the basis of criminal records.

We can only use the information in a police check to screen Service Provider Members who are offering or want to offer their services via the Website or employees of Connex that have access to vulnerable people.

The following items will need to be assessed as “disclosable outcomes”:

• Record of court convictions
• Findings of guilt

If you have one of these on your Police Record Check we are required to assess your application in accordance with all privacy laws and take into consideration relevant Human Rights and Equal Opportunity legislation.

If requested, we may provide a copy of your Police Check to any clients or providers who engage you on Connex.

Confidentiality and discrimination

We must not discriminate on the grounds of a criminal record when making a decision. It is not an act of discrimination to find a care worker unsuitable if a criminal record means that person is unsuitable to perform the inherent or essential requirements of providing home care services to vulnerable people.

We will maintain complete confidentiality and protect care workers’ identities at all times and ensure the information about any criminal record is always used solely for the purposes in which it is intended.

How we assess the information

Having a disclosable outcome does not automatically exclude you from offering services on the Connex Website. When assessing the relevance of your police history information, we will consider:

1. the relevance of the police history information to the inherent requirements of the work you will be required to do
2. the seriousness of the conviction or offence
3. the severity of any penalty imposed
4. whether the offence has been decriminalised or removed from the statutes
5. the age of the applicant when the offence occurred
6. the period of time that has elapsed since the offence took place
7. whether the applicant had a pattern of offences
8. the circumstances in which the offence took place – for example, domestic situation
9. whether the applicant’s circumstances have changed since the offence was committed, for example, previous drug use
10. the attitude of the applicant to their previous offending behaviour.

Things on your police history which would exclude you from being a Service provider Member

Service Provider Members will however be excluded from providing home care services via the Connex Website if their disclosable court outcomes include a finding of guilt or conviction for any of the following offences:

1. murder or sexual assault
2. any other form of assault
3. any offence involving harm or exploitation of vulnerable people
4. any serious alcohol or drug related offences that indicate a pattern of dependence
5. drug trafficking
6. any offence involving serious dishonesty, or multiple offences involving dishonesty
7. terrorism

Definitions

‘Authorised Personnel (AP)’

Designated Human Resources staff of Connex who are authorised to handle Police History Information (PHI) and other data relevant to care workers.

’Disclosable outcome’

Record of court convictions and findings of guilt, to which provisions of relevant spent convictions / non-disclosable legislation and / or information release policies have been applied.

‘Police History Information (PHI)’

Information relating to disclosable court outcomes or other Information regarding the name provided to Canadian Criminal Intelligence Commission and included within a police check.

PHI is only released subject to relevant spent convictions / non-disclosure legislation and / or information release policies.

For more information

Please see:

1. ConnexHealth Privacy Policy
2. ConnexHealth Terms and Agreement Policy
3. ConnexHealth Terms of Use Policy
4. ConnexHealth Cancellation Policy
5. ConnexHealth Code of Conduct Policy
6. Privacy Act (Canada)
7. Freedom of Information Act (Canada)
8. Canadian Human Rights Act

Feedback

These policies will be updated throughout the year as required.

Your thoughts, comments and suggestions are welcome. Please direct any feedback to mysupport@connexmatch.ca