What is Personal Information?
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:
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:
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:
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.
Further, your personal information may be disclosed:
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.
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.
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?
Brightsquid Privacy Officer
Brightsquid Secure Communications Corp
282, 3553-31st St. NW Calgary AB
T2L 2K7 CANADA