YOUR PRIVACY IS IMPORTANT TO US. RESPECT FOR YOUR PRIVACY AND THE CONFIDENTIALITY OF YOUR INFORMATION IS A FUNDAMENTAL VALUE OF INFOTECH INC. (“INFOTECH”). THIS PRIVACY NOTICE DESCRIBES THE INFORMATION WE COLLECT ABOUT YOU (“YOUR DATA”) IN CONNECTION WITH YOUR USE OF OUR WELLNESS CHECKPOINT® HEALTH RISK ASSESSMENT SERVICE (THE “WC SERVICE”), AND HOW WE USE, RETAIN AND DISCLOSE YOUR DATA.

YOUR USE OF THE WC SERVICE IS ENTIRELY VOLUNTARY AND CONFIRMS YOUR AGREEMENT THAT WE MAY COLLECT, USE, RETAIN AND DISCLOSE YOUR DATA IN ACCORDANCE WITH THIS PRIVACY NOTICE.

The WC Service and this Privacy Notice have been designed to be compliant with and adhere to the principles, spirit and intent of all applicable data protection and privacy laws (the “Data Protection Laws“). While the detailed provisions of the Data Protection Laws may differ, whichever of them applies in your case will provide you with certain rights to ensure that any Personal Information (defined in Section 1.03 below) we collect in connection with your use of the WC Service is kept private and confidential, is accurate, is used only for the purposes disclosed to you when the information was being collected and is not disclosed to other parties without your consent, except in limited defined circumstances as provided herein.

Please note, we will process Your Data in Canada, where InfoTech is located, which means that Your Data may be subject to Canadian laws and in certain circumstances may be accessible by Canadian authorities.

Under the Data Protection Laws and in this Privacy Notice, “Personal Information” means any information about an identified or identifiable individual.

Depending on how you use the WC Service, we may or may not collect any Personal Information about you. If we do, we may have received it directly from you (for example, when you use the Wellness Checkpoint health risk assessment (the “Assessment“) or one of its related mobile applications (collectively, the “Mobile App“)) or from your Sponsor (defined in Section 2.01 below) or from a Third Party Provider (defined in Subsection 4.01 (e) below) at the request of your Sponsor. Your use of the WC Service confirms your agreement that your Sponsor and such Third Party Providers may provide Personal Information to us and that we may use it as described in this Privacy Notice. In some cases, while we do not have Personal Information about you, your Sponsor or a third party may.

The WC Service is made available for your use by your employer, benefits provider, insurer or other organization (the “Sponsor“) that has contracted with us or one of our partners (each, a “Contracting Partner“) for the delivery of the WC Service to you. You may also be entitled to use the WC Service because your Sponsor has elected to make it available to its employee’s or member’s spouses, domestic partners, family members or other designated third persons (“Eligible Users“).

Your Sponsor is the “data controller” for purposes of the Data Protection Laws.

Your Sponsor makes the WC Service available to you so that you can evaluate your risk of developing and/or managing the negative effects of chronic disease conditions such as heart disease, cancer and diabetes, to help you identify possible issues with respect to your emotional health, and to encourage you to make positive changes to reduce your risk in any areas of concern. Some Sponsors use anonymous group and aggregate data to allow them to better understand group health needs, deliver their health benefits coverage and inform future health programs. Your Sponsor may also want to offer you incentives, external services or professional resources to support you in making positive changes that can reduce your risks and improve your health.

Whatever the specifics, you should consult the “Terms of Use” displayed on the page where you read and accept the terms and conditions for use of the WC Service to see your Sponsor’s general statement about how the Personal Information which we might collect about you when we provide the WC Service will be collected, used, retained or disclosed. Collectively, the Terms of Use plus this Privacy Notice and the InfoTech Terms & Conditions set out how the Personal Information which we might collect about you will be collected, used, retained and disclosed.

Please note, we assume no liability or responsibility except as required by the Data Protection Laws for the privacy practices of your Sponsor or any other external organization to whom we disclose your Personal Information as provided in the Terms of Use or this Privacy Notice, and we encourage you to read their privacy statements.

1. You are under no obligation to provide any information (including Personal Information) to us at any time. However, if you should choose to withhold specific information, we may be unable to provide you the WC Service as configured by your Sponsor.
2. Except as described in the Terms of Use, this Privacy Notice or the Terms & Conditions, we will not collect, use, retain or disclose your Personal Information without your permission and all Personal Information which we collect is kept confidential to the best of our ability and in accordance with the Data Protection Laws.
3. We will collect, use, retain and disclose your Personal Information only as provided in the Terms of Use, this Privacy Notice and the Terms & Conditions, including to:
   1. generally, provide the WC Service as configured by your Sponsor;
   2. administer your account with us;
   3. identify you when you sign-in;
   4. track your program progress, as well as provide you with information that you may find helpful and/or have requested (such as reminders and notifications);
   5. direct you to programs, content, services and events that may be relevant or helpful to you;
   6. communicate with you in a fashion you have agreed to;
   7. administer the Assessment in order to evaluate your risk of developing and/or managing the negative effects of chronic disease conditions such as heart disease, cancer and diabetes, or to make positive changes to reduce your risk and, where appropriate, seek professional help dealing with issues related to your emotional health and your ability to cope with the pressures and demands of your job;
   8. in an aggregated and anonymized format, help your Sponsor better understand group health needs and select and monitor the types of programs they should offer their Eligible Users; and
   9. analyze on an anonymous, aggregated data basis the use of the WC Service and the people visiting in order to improve our content and services including research into our user’s demographics, and provide information which you have requested from us.
4. In general, we will use and disclose your Personal Information to deliver the WC Service to you and this may involve, at times, disclosing your Personal Information to agents or contractors that work on our behalf and assist us in providing and supporting the services we offer through the WC Service including processing transactions, fulfilling requests, analyzing data, or helping us to communicate with our users (“Contracting Partners“). We may also disclose your Personal Information if you have expressly consented to this (for example, by agreeing to the Terms of Use).
5. Subject always to the Terms of Use and applicable Data Protection Laws, we may also disclose your Personal Information to your Sponsor, our Contracting Partners or other consultants, service providers or vendors of health, wellness or related services with whom your Sponsor or our Contracting Partners contract (“Third Party Providers“), for the following general purposes:
   1. to coordinate (x) enrollment in, (y) enhancement of your experience, and (z) education about health, wellness or related services provided by your Sponsor, our Contracting Partners or a Third Party Provider;
   2. to allow you to use the services provided by your Sponsor, our Contracting Partners or such Third Party Provider;
   3. to ensure that you receive appropriate rewards for participation in the WC Service and other services provided by your Sponsor, our Contracting Partners or a Third Party Provider;
   4. to evaluate the overall quality and effectiveness of the program(s) in which you may participate; and
   5. to assess your eligibility for other programs that your Sponsor, our Contracting Partner or a Third Party Provider may offer.

   Your Sponsor, our Contracting Partners and Third Party Providers may be located in countries which have not been declared to be “adequate” pursuant to Data Protection Laws applicable to you.

6. We may disclose your Personal Information (a) if legally entitled or required to do so (for example if required by law or by a court order or other judicial or administrative proceeding, (b) as otherwise required under any applicable law, rule, or regulation, and (c) if we believe, in good faith, that such disclosure is necessary to protect or defend our rights or those of others or to assist in the investigation or prevention of illegal activity.
7. If you have agreed to receive them, we may send you push notifications on your device from time-to-time in order to provide you with prompts, reminders and notifications. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user and device identification information. We may also (but only if you have agreed to receive them) send you e-mails or other communications with prompts, reminders and notifications, information and offers about the WC Service. You can opt out of any of such communications at any time by updating the ‘User Settings’ section of the Assessment or the Mobile App.
8. When you use the WC Service we may automatically collect additional information such as the type of internet browser or mobile device you use, your IP address (the unique address that identifies your device on the internet) and the operating system of your device which is automatically recognized by our web server. We use this information to derive a broad, non-specific understanding of the locations from which you are accessing the WC Service, to analyze trends, administer the WC Service, track users’ movements within the WC Service, and to gather demographic information about our user base as a whole and to personalize the WC Service to user’s preferences.
9. Without limiting Section 7.01 below, we will retain your Personal Information for as long as required by your Sponsor. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
10. In the event that we undergo re-organization or are sold to a third party, any Personal Information we hold about you may be transferred to that re-organized entity or third party in accordance with applicable law, including without limitation the Data Protection Laws. You acknowledge that such acquisitions may occur, and that any acquirer of InfoTech or its assets may continue to use your Personal Information as set forth in this Privacy Notice.

We may create “Anonymous Information” records from your Personal Information records by excluding any information (“Identifying Information“) that could link the Anonymous Information back to you. We reserve the right, subject to applicable law, to use and disclose any Anonymous Information at our discretion, subject to and in accordance with any applicable Data Protection Laws. For example, we may use Anonymous Information to compile population health benchmarks, analyze and understand demographics trends, customer behavior patterns and desires, and develop information that may enrich the content and quality of our programs or we may share Anonymous Information with other organizations for purposes of research and program analysis.

We use Analytics to allow us to better understand the utilization of the WC Service. This means that we may record information such as how often you use the application, the events that occur within the application, aggregated usage, metrics, performance data, crash reports, and where the application was downloaded from. We do not link the information we store from our analytics to any personally identifiable information you submit within Wellness Checkpoint or the Mobile App.

We may use a third-party vendor to help us manage some of our email communications with you. Although we may supply this vendor with email addresses of those we wish them to contact, your email address is never used for any purpose other than to communicate with you on our or your Sponsor’s behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor’s servers (although this process will be invisible to you) which will register that you have clicked on that link, and have visited the WC Service. We never share any Personal Information, other than your email address, with our third-party email vendor. You can opt out of any of such communications at any time by updating the ‘User Settings’ section of the Assessment or the Mobile App.

In delivering the WC Service, we may use technologies such as cookies, beacons, tags, scripts and other similar technologies to help administer the WC Service and enhance your user experience, enable you to sign in, identify the total number of users, measure traffic patterns for trending purposes, personalize or customize content so that a user’s preferences can be “remembered” when they return to the WC Service, and to better manage content, as well as to collect information about user’s access to the WC Service.

Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. Most of the WC Service uses last only for the duration of your session on the WC Service and expire when you close your browser. Other cookies are used to remember you when you return to the WC Service and will last for longer.

Most computer and some mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting sites such as www.allaboutcookies.org which includes useful additional information on cookies and how to block cookies using different types of browsers. Please note that by blocking or deleting cookies you may not be able to take full advantage of the WC Service.

For further information about how we use cookies, please see our Cookies Notice.

InfoTech has reasonable security standards and has taken appropriate technical and organizational measures to protect our systems and the information stored on our servers against loss, unauthorized access and misuse. We appropriately manage our server environment and firewall infrastructure. Our security practices are reviewed on a regular basis and we employ current technologies to ensure that Your Data is protected.

However, no company, including InfoTech, can fully eliminate security risks associated with Personal Information. You are responsible for keeping your password and username confidential and secure from unauthorized persons, and you are responsible for any and all activities that occur under your user account.

Applicable Data Protection Laws may give you the right to control our use and processing of your Personal Information. These may include the right (i) to request access to and a copy of your Personal Information, (ii) to object to or withdraw consent to processing of your Personal Information, or to request rectification or erasure of your Personal Information; (iii) to restrict processing of your Personal Information; and (iv) to data portability. Where we are using your Personal Information with your consent, you also have the right (subject to applicable Data Protection Laws) to withdraw your consent at any time, though this will not affect our uses of your Personal Information prior to the withdrawal of your consent.

To exercise any of your rights, please contact us at privacyofficer@wellnesscheckpoint.com. We will consider and act upon any such requests in accordance with applicable Data Protection Laws, and may ask you to verify your identity in order to help us respond efficiently to your request.

You also have the right to raise questions or complaints with your applicable national data protection authority at any time.

This Privacy Notice is subject to change from time to time. We will post any revised version of this Privacy Notice on the InfoTech website at http://wellnesscheckpoint.com/wcserviceprivacy/. Any amended Privacy Notice will be effective the earlier of the time you expressly accept such amended Privacy Notice by using the WC Service and seven (7) calendar days after posting for existing users.

Any changes to this Privacy Notice may affect our use or disclosure of Personal Information collected prior to the changes. Continued use of the WC Service following notice of such changes will indicate your acknowledgement and acceptance of such changes.

The WC Service may link to and be linked to by a site or sites maintained by your Sponsor. It may also contain links to other sites maintained by a Contracting Partner or a Third Party Provider available to the public or to providers of services to your Sponsor. We do not disclose your Personal Information to any site outside the WC Service, except as described in Part 4 – above or as set out in your Terms of Use, we are not responsible or liable for the practices of such other sites, including their privacy or security practices. You should read the privacy policies of each site you visit to determine what information that site may be collecting, using or disclosing about you.

If you have any questions or concerns about this Privacy Notice or the WC Service, you can address them to InfoTech’s Privacy Officer:

Privacy Officer
Phone: 204 788 1500

privacyofficer@wellnesscheckpoint.com

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“Wellness Checkpoint” is a registered trademark of InfoTech Inc.