Brightshare Privacy Policy

At Brightsquid Secure Communications Corp. ("Brightsquid") we are committed to maintaining the privacy, confidentiality and security of your personal information.  This Privacy Policy describes the personal information that Brightsquid collects from or about you, how we use and to whom we disclose that information when you use Brightshare. 

This Privacy Policy applies to the identifiable information of all organizations and individuals using Brightshare.  For more information about Brightsquid’s other privacy practices please contact our Privacy Officer (contact details provided below).    

BY USING BRIGHTSHARE, YOU ARE CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY AND, WHERE YOUR INTERACT WITH THE PERSONAL INFORMATION OF OTHERS IN BRIGHTSHARE (SUCH AS THE PERSONAL INFORMATION OF A FAMILY MEMBER OR PATIENT), YOU REPRESENT THAT YOU HAVE THEIR CONSENT TO DO SO. IF YOU DO NOT CONSENT OR DO NOT HAVE SUCH CONSENT, PLEASE DO NOT USE BRIGHTSHARE.

Privacy Policy Effective for Canada

It is Brightsquid's policy to comply with the privacy legislation within each jurisdiction in which we operate.  Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another.  This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws. 

This Privacy Policy has a limited scope and application.  Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.  If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information. 

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual.

 

What Personal Information do we Collect?

We collect and maintain different types of personal information in respect of the individuals with whom we interact.  This includes:

  • personal contact and identification information, such as your name, age and gender;
  • information about your health, should you opt-in to share that information, including information from your mobile device health app (e.g. heart rate, blood pressure, body temperature, respiration rate, blood oxygen, body measurements), self-reported symptoms (e.g., cough, fever, runny nose, etc), self-reported medical conditions (e.g., asthma, diabetes, high blood pressure, etc), and other summary information (e.g., daily number of close contacts, daily assessment for exposure risks);
  • information concerning the use, operation and development of Brightshare; and
  • relationship information, including information related to your agreements, consents, preferences, feed-back and information requested by or provided to you.
  • information about your mobile device’s location, when tracked and consented to. The specific types of location data we collect from your device when you consent to location sharing are GPS coordinates indicating locations you have visited recently.  On the mobile device, Brightshare determines your location with varying degrees of accuracy by:
    • GPS
    • IP address
    • Sensor data from your device
    • Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices

 

As a general rule, Brightshare collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions).

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise.  Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. 

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect Personal Information?

Brightshare collects personal information to enable us to manage, maintain, and develop our business and operations, including:

  • to offer features like showing COVID outbreaks near locations you have visited, and more accurately calculating your risk of exposure.
  • to operate Brightshare, including the support, maintenance and development of same;
  • to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
  • to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
  • to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
  • to be able to comply with your requests (for example, if you prefer to be contacted at a business or personal email address or telephone number and advise us of your preference, we will use this information to contact you through those means);
  • to protect us against error, fraud, and inappropriate access;
  • to enable us to comply with applicable law or regulatory requirements; and
  • any other reasonable purpose to which you consent.

 

How does Brightshare use Personal Information?

In response to the COVID-19 pandemic, Brightshare assists in COVID-19 contact tracing, self-assessment, and self-monitoring.  The University of Calgary may fuse COVID-19 related data provided by you with data collected from public sources to provide you with personalized information on your risk of COVID-19 infection, in order to provide guidance for self-monitoring and self-care, and to seek deeper understanding of the COVID-19 epidemic.

Brightshare and the University of Calgary use only anonymized and aggregated data (without any personal identifiers).  A sample of the anonymized data may be moved to University of Calgary servers for future research related to COVID-19 and similar epidemics

You are responsible for and control who you authorize to access the personal information managed by you through Brightshare.

You acknowledge and agree that access to and use of Brightshare (and any of its related services) is provided via the Internet.  Information stored in Brightshare is stored in Canada, but may be accessible in other jurisdictions via Brightshare.

 

YOU MUST NOT USE BRIGHTSHARE FOR EMERGENCY MEDICAL NEEDS. IF YOU BELIEVE THAT YOU ARE DEALING WITH A MEDICAL EMERGENCY, CALL 911 (OR YOUR LOCAL EMERGENCY NUMBER) IMMEDIATELY OR ATTEND YOUR NEAREST EMERGENCY ROOM.

 

How Do We Use and Disclose Your Personal Information?

We may use and disclose your personal information:

  • for the purposes described in this Privacy Policy; or
  • for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so. 

We may use de-identified information created by us from your personal information without restriction.

When do we Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist Brightsquid in the provision of services to you; and third parties whose services we use to conduct our business.

For example, Amazon Web Services may provide certain information technology and data processing services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Brightsquid through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • to protect the rights and property of Brightsquid;
  • during emergency situations or where necessary to protect the safety of a person or group of persons;
  • where the personal information is publicly available; or
  • with your consent.

Special Considerations for COVID-19

Due to the COVID-19 pandemic, Brightsquid has released mobile apps with features created specifically for the COVID-19 response, which only access personal and sensitive data required to directly support the public health emergency. These apps will only use the data collected to support COVID-19-related efforts and related research. Included in these apps will be manual contact tracing, which allows users to manually keep track of their close contacts and potential exposures. This tracing is completely voluntary, and manually input by the user. This means Brightshare apps do not make use of automatic exposure tracking via Bluetooth, and all contact tracing information is simply recorded by the user for their own use. This functionality will be removed as per the requirements of the iOS App Store and Google Play once the COVID-19 pandemic has ended. Other functionality specific to COVID-19 will also be removed at that point in time, and any data related to that functionality will no longer be collected.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so.  Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express.  Express consent can be given orally, electronically or in writing.  Implied consent is consent that can reasonably be inferred from your action or inaction.  For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information.  In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information.  If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements. 

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below.  All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

How is Your Personal Information Protected?

Brightsquid endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question.  These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control. 

 

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current.  If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see your personal information.  If you want to review, verify or correct your personal information, please contact our Privacy Officer.  Please note that any such communication must be in writing. 

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you.  We may charge you a fee to access your personal information; however, we will advise you of any fee in advance.  If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute.  There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you.  In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

 

Inquiries or Concerns? 

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer, in writing or by e-mail.  We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.  If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

 

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy.  The contact information for our Privacy Officer is as follows: 

 

Brightsquid Privacy Officer

Brightsquid Secure Communications Corp

282, 3553-31st St. NW Calgary AB

T2L 2K7 CANADA

privacy@brightsquid.com

(800)238-6503x301

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information.  We will post any revised version of this Privacy Policy on our website https://brightsquid.com/ and we encourage you to refer back to it on a regular basis.  This Privacy Policy was last updated on June 1, 2021. 

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer.  This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation'.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Brightsquid any obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable.  Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.