Your private information will not be sold by Brightsquid to any third party for any use.
Applicable Privacy Legislation
What is Personal Information?
What Personal Information do we Collect?
We collect personal information when people use our services.
For patient users this may include:
For professional users this may include:
As a general rule, Brightsquid 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).
When acting as an Information Manager for healthcare clinics, Brightsquid may receive your personal information from healthcare providers for the purpose of inviting you to the Solution, creating an account so you can communicate with the provider or clinic, and for identity validation.
With respect to health information shared with your healthcare practitioner through the Solution, we note that each healthcare practitioner is independent of Brightsquid and is responsible for obtaining and managing your consent in relation to their collection and use of your information.
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.
When required by applicable law or regulatory requirements, we may collect, use, or disclose information about you without your knowledge or consent.
Why Do We Collect Personal Information?
The Solution (and its related services) generally enables the exchange of sensitive information between users. Brightsquid collects personal information to enable us to manage, maintain, and develop the Solution, our business and operations, including:
A more detailed description of the data usage and sharing associated with the specific features, modules, applications and/or services of or related to the Solution for which you may subscribe or use are available on request.
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 when we are required by applicable law or regulatory requirements to do so.
We may use de-identified aggregated information, as needed, to monitor and improve the Solution.
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.
This may include 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. In these cases, your information will not be used for purposes unrelated to your use of the Solution. All third parties are vetted and are contractually obligated to uphold the terms of this policy.
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.
To support necessary recipient identity verification, we will display the following basic personal information to professionals who want to message you so that they know they are delivering information to the correct person:
Health Professionals will only see the above information if:
Expanded personal information including:
is visible to identity verified Health Professional users if:
The Solution is used by a wide variety of Health Professionals. As such, health providers within your circle of care may need to send communications to your existing Brightsquid Account. In these cases, Professional users can see your basic personal information only after entering your COMPLETE email address into the Patient Directory search. The Patient Directory is only available to verified professional users and will only display patient contacts that have either:
For professional users, Name, Job Title, and associated Organization contact information (Organization name, phone number, and address) will be displayed in the professional directory to validate recipient identity and expedite delivery to the most appropriate recipient.
Further, your personal information may be disclosed:
Your Consent is Important to Us
Brightsquid practices privacy by design and privacy by default in the design, development and operation of the Solution and our services. We strive to collect the minimum amount of personal information necessary and to retain it no longer than necessary to meet our contractual obligations or as required by law.
Accordingly, 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 express, deemed (using an opt-out mechanism), or implied. Express consent will generally be through an overt opt-in process, and 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 for services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of those services 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 protection of personal information is of paramount concern to Brightsquid, and Brightsquid is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws. Correspondingly, 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 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 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. We generally retain your information as long as reasonably necessary to provide you with the Solution and related services or to comply with applicable law.
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
3655 36 St. NW Calgary AB
T2L 1Y8 CANADA