Last updated: Jan 2021

This is the main Privacy Policy for the Sigma HealthTech Inc (“Sigma”) and covers all related websites, applications, and services that do not have a separate policy. This Policy summarizes our personal information handling practices so that you may easily understand what information we collect and why, as well as how to access, update or correct your personal information.

Our products and services are intended for use by Canadian customers, and we follow the privacy principles of applicable Canadian law, the Privacy and Personal Health Information in Ontario, Personal Health Information Protection Act and the Personal Information Protection and Electronic Documents Act (PIPEDA).

We may update or amend this Policy from time to time. If you continue to use our products and services after we make changes, you are consenting to the updated policy. If there are significant changes in our information handling practices, we will provide you with notice and archive prior versions.

Our Privacy Policy is comprised of six key components which are outlined in more detail in this document:

1.  What Information We Collect and Why
2.  Sharing of Information
3.  Protecting Information
4.  Providing Access to Information and Keeping it Accurate
5.  Retention of Information
6.  Providing Notice and Responding to Questions

What Information We Collect And Why

Sigma collects personal information about you for the sole purpose of responding to your queries, and fulfilling the services you have requested and are enrolled in.

The following outlines the information we may collect and how it is used:

•  Contact Information

This includes information such as name, address, postal code, email address, telephone number, marital status, and language preference.

This is collected to communicate with you about the products and services requested by you and to verify your identity when you contact customer service. It may also be used to provide you with information about other Sigma products and services that may be of interest to you.

You may unsubscribe or opt-out from receiving notifications from us by following the instructions provided in each communication, or online in your product settings, where applicable.

You may not opt out of certain emails which are fundamental to the product in which you are enrolled. In some cases, you may opt out of non-fundamental emails, however, this may have an impact on the effectiveness of some programs to which you may be enrolled.

•  Birth Date

We will collect birth date only if you have registered to our secure messaging service. It is used to verify your identity when you are communicating with your service provider.

•  User ID and Password

You may create a user ID and password when you enroll in one of our services. This is used to verify your identity online so that you may access your account and use the service.

•  Security Question and Answer

When you enroll in one of our services, you may be asked to select a security question and provide a response. This is used to verify your identity online when you forget your password, or when contacting customer service.

•  Credit Card Information

We collect credit card information when you purchase our services. It is used for billing purposes and processing recurring payments or refunds, as required.
If you have enrolled in certain services, as such lost card protection, your credit card information may be requested to provide the service offered.

•  Health card number

We will collect health card number only if you have registered to our secure messaging service. It is used to verify your identity when you are communicating with your service provider.

•  Other Personally Identifiable Information

Some of our services allow you to store information you consider valuable. Depending on the services in which you have enrolled, we may use this personal information to provide you with additional services. You may cancel these additional services at any time.

•  Information Sent by Your Browser

Your browser automatically provides, and we automatically collect and store, certain information about your device (computer, tablet, smart phone,) and your activities. This may include, but are not limited to:

•  Preferences and settings, such as time zone, language, and character size;
•  Technical information, such as type of device, operating system or platform (Mac, Windows), and browser information (type, version);
•  General geographical location.

This information allows us to provide you with customized experiences while using our websites and enables us to develop better products and services compatible with the technology used by our visitors.
We use a third-party service provider to gather and analyze non-personalized information about your visit to our website. This aggregate information is used to help us evaluate and improve the content and functionality of the website.

•  Cookies

(a) “Session” Cookies are a randomly generated unique identification number assigned to your computer, and it expires when you close your browser. We use Session Cookies to collect information about how our sites are used, such as which pages were visited, which links were used, and the amount of time spent on each page. This provides us with statistics on site usage by our visitors, and allows us to improve the functionality of our websites and the services provided.

(b) “Persistent” Cookies do not expire when you close your browser, but stay on your computer until they are deleted. By using this unique identifier, we are able to identify and store your previous choices and preferences for use on subsequent visits to our website. This provides you with a customized experience when using our services.

If you wish, you may disable cookies in your browser, or delete them by clearing your browser history. While we do not require the use of cookies, some functionality may be disabled and your experience on our site may be degraded.
For more information about cookies, how they work, and what choices you can make through your browser settings, see http://www.allaboutcookies.org/

•  Audio or Video Recordings

When you call customer service, your call may be recorded. This is used to create a record of our interaction and may be used for coaching and training purposes.

If you visit one of our offices, video recordings may be used to monitor the security of our facilities.

•  Correspondence

When we communicate with each other, whether by email or postal mail, these are retained as confirmation of our communication.

•  Demographic Information

We collect certain preferences or customer service-related information, such as postal code, age, gender, and reasons for cancellation of a service. This is used to customize your experience with us, and help us develop better products and services.

Do Not Track

Some browsers give individuals the ability to indicate that they do not want to be tracked while browsing on the Internet. The “Do Not Track” feature sends a signal that informs online services that the user does not want certain information about their online activities to be collected over time and across websites or online services.

The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance would be measured, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated “Do Not Track” signals.

Sharing Information

Personal information is not shared outside of Sigma unless:

•  You have explicitly consented to it.
•  We are permitted or required to do so by law.
•  We have engaged an authorized service provider to carry out services on our behalf.

Our service providers are given only the information they need to perform their designated functions, and they are not authorized by us to use or disclose your personal information for any other purpose. To ensure the integrity and protection of your information, our service providers are contractually required to safeguard personal information in a manner consistent with our privacy and security policies.

Links to Other Websites

Our websites may contain links to non-Sigma websites. The information and privacy practices of these third-party sites are not governed by Sigma, and we recommend that you review their Terms of Use and Privacy practices before you provide any personal information.

Legal Disclosures

There are limited circumstances in which we, or our authorized service providers, may share or transfer your personal information. These would be to:

•  establish, exercise, or defend a legal claim,
•  investigate or prevent actual or suspected loss or harm to persons or property,
•  prevent or investigate a possible crime, such as fraud or identity theft,
•  comply with a search warrant, court order, subpoena, or other legally valid inquiry.

In the event we are required by law to disclose personal information, we will take reasonable steps to verify the lawful authority for the collection, and disclose only the information that is legally required.

Business Transactions

We may disclose personal information in connection with a proposed or actual sale, purchase, merger, reorganization, financing, liquidation, dissolution, or similar event for all or part of our business or assets. This confidential disclosure would be for the purpose of evaluating and/or completing the proposed transaction.

When we disclose information under these or similar circumstances, we will take appropriate steps to limit use and protect the confidentiality of your personal information.

Our assignees or successors may use and disclose your personal information for similar purposes as those described in this Privacy Policy in order to continue providing you with the services in which you have enrolled.

Protecting Information

We take all reasonable steps to protect the privacy and security of your personal information in a manner that is appropriate for the type of information in our custody. This includes multi-layered physical, technical, and administrative safeguards, including:

• Restricting access to view or process personal information to only authorized employees trained in our security procedures. Their access is restricted only to the information needed for their job.
•  Appropriate industry standard methods to secure electronic environments, including the use of multi-factor authentication, network firewalls, encryption, and restricted physical access to secure areas.

Security Standards

Our production environments and processes adhere to the security standards outlined in HIPAA, PHIPA, ISO 27001 for Information Security Management, and by the Payment Card Industry Data Security Standard (PCI-DSS) as managed by the PCI Security Standards Council.

Username and Passwords

Depending on the services you are enrolled in, you may have an online account protected by a username and password selected by you. It is recommended that you use a strong password that is not easily guessed, hacked, or used for another online account belonging to you.

It is your responsibility to protect your username and password so that only you may gain access to your personal information online. If you have concerns that the security of your account may have been compromised, contact our Customer Service department immediately.

Emails

Emails are generally not encrypted over the internet and it is not a safe method of sending sensitive information. For your protection, do not include personal or confidential information, such as account numbers, when sending email messages to us. If your request is urgent, or requires disclosure of confidential or personal information for resolution, please contact our Customer Service department by phone.

Preventing Email Fraud

We will NEVER send email messages to you requesting confidential information, such as passwords or account numbers.

From time to time, you may receive fraudulent emails claiming to be from a financial institution or other reputable business, requesting you to verify your personal and/or account information. These emails often contain a link that will direct you to a pop-up window or modified login page to enter your login ID and password. Do not act on any such emails.

Following any link to a counterfeit internet site can compromise your account. If you have concerns, contact by phone the business affected.

Data Storage Outside of Canada

Our websites and the data they contain are strictly hosted on servers located in Canada. Our call centres are also primarily located in Canada, although we may at times use supplemental facilities located in other countries.

To ensure the best service to you, we may contract with service providers outside of Canada, where your information may be processed and stored. When we transfer your personal information to another country, we will take appropriate measures to protect your personal information in a manner that is consistent with this Policy and our data security requirements.

By using our sites and participating in the related programs, you are consenting to the transfer of your personal information, in accordance with the terms of this Policy.

Providing Access to Information and Keeping it Accurate

The easiest way for you to access and review your account information is to visit your account profile on this website. Updates or corrections to your profile can be made by you at any time. If this site does not have a profile page, please contact Customer Service for assistance.

For access to information, or to make changes / corrections that require our assistance, we will take reasonable steps to verify your identity before granting access or making any changes.

Although we will respond to your requests for changes within a reasonable time, there are certain changes which we are unable to make on your behalf, for example errors in a credit report or on government ID. If applicable, these will be communicated to you.

We use appropriate security measures to protect your personal information from unauthorized access. If any of your personal information appears to have been altered without your knowledge, please advise us immediately.

Retention of Information

We retain the personal information you provide to us for as long as:

•  your account is active,
•  it is required to provide you with the products or services in which you are enrolled,
•  a reasonable period of time following cancellation of services, to allow for possible re-engagement,
•  reasonably required to comply with legal obligations, regulatory requirements, resolve disputes, or prevent fraud and abuse.

Providing Notice and Responding to Questions

We reserve the right, at our discretion, to update, change, add, or remove portions of this Policy at any time. The level of notice we will provide when we change this Policy will depend on the nature and impact of the change.

If the changes we make do not impact how we collect, use, or disclose personal information, we will replace this Policy with the revised Policy and change the “effective” date at the beginning of this document.

If we make material changes that affect how we collect, use, or disclose personal information, we will provide appropriate notice for at least 30 days before and after the new effective date, and highlight the changes in the Policy so they can be easily located.

Your continued use of our products and services following a change to this Policy will indicate your acceptance of the revised Policy.

We take our commitment to privacy seriously, and all of our employees and third-party service providers are responsible for ensuring the confidentiality of the information entrusted to us.

 

If you have questions or concerns that have not been resolved to your satisfaction, you may contact our Privacy Officer by email at privacy.canada@sigmahealthtech.com, or by mail at Sigma HealthTech, 2910 South Sheridan Way Oakville, ON L6J 7L9