2022-07-21_skoyanagi_Canada Privacy Statement June 2022.docx

Canada Privacy Statement

This Canada Privacy Statement describes the personal information HCA Home Care Assistance Canada, Inc. and its affiliated entities operating in Canada (collectively, “HCA”) collect online and offline, and how we use and disclose this information. By using our Services or by choosing to give us personal information, you signify your consent to this Privacy Statement. This statement does not apply to (i) HCA personnel or job applicants seeking employment opportunities at HCA or (ii) personnel working on behalf of business partners with whom we are conducting business.

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), email address, and other similar identifiers

Additional Data such as: signature, physical characteristics or description, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information

Personal Classifications: personal characteristics such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical genetic information, disability, citizenship status, and veteran status

Commercial Information: commercial information, including records of account and payment history with HCA

Online Activity: Internet and other electronic network activity information, including, but not limited to websites, applications or advertisements

Geolocation Data

Sensory Information: audio, electronic, visual, and similar information

Employment Information: professional or employment-related information

Inferences: information about you reflecting your preferences, characteristics, behavior, or abilities

We may use the categories of personal information listed above for the purposes described in this Privacy Statement. In addition, we may use these categories of personal information for certain purposes permitted or required by applicable law.

Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this Privacy Statement. For the personal information collected during that time frame, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the  information, (c) the categories of personal information we may have shared, and (d) the categories of personal information we may have disclosed for a business purpose.

Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Use of Personal Information for Advertising

We may allow our online advertising providers to collect your personal information via cookies and analytics scripts and other technologies placed on our website to provide an enhanced ability to serve you content and advertisements that may be of interest to you. The categories of personal information that may have been collected in this manner include Identifiers, Online Activity and Inferences. You have the right to opt out of this collection of your information by our online advertising providers by submitting a request to us via email or phone call, or using the options we provide on our website.

Security

We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to help protect Personal Information that we control. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you, or such purposes required or permitted by law.

Even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

International Transfers

Personal Information that we collect may be stored and processed in Canada, the United States or any other country in which we or our service providers maintain facilities. Personal Information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

By providing us with Personal Information, you consent to any such transfer of information outside of your country. If you have any questions about our use of service providers outside of Canada, you may contact us using the information below.

Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below:

Access: You have the right to request that we disclose to you the personal information we have collected, used, or disclosed about you.

Setting your preferences: You have the right to opt-out of the use of your personal information for marketing purposes.

Correction: You have an ability to request correction of your personal information if you believe it is inaccurate.

How to Submit a Request

To submit a request, or if you have any questions or would like to submit a complaint, email us at hcaprivacy@thekey.com, or call us at (888) 601-8638.

To opt-out of the use of your personal information for marketing email us at hcaprivacy@thekey.com.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting  you access to your personal information or complying with your request. If you request access to or correction  of your personal information, we may require you to  provide certain information to help us identify you. In  addition, if you ask us to provide you with specific  pieces of personal information, we will require you to  sign a declaration that you are  the consumer whose personal information is the  subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf

we may require you to provide the authorized agent written permission to do so, and

for access and correction requests, we may require you to verify your own identity directly with us (as described above).

Please note that in some cases, we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons.

Additional Information

We will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under any applicable Canadian privacy law. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact hcaprivacy@thekey.com to request this Statement in an alternative format.

Purposes | Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing  payments, providing advertising or marketing services, providing  analytics services, or providing similar services | Identifiers; Additional Data; Personal Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance | Identifiers; Additional Data; Personal  Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction | Identifiers; Additional Data; Commercial Information; Online Activity; Sensory Information; and Inferences

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, 
and prosecuting those responsible for that activity | Identifiers; Additional Data; Commercial Information

Debugging to identify and repair errors that impair existing intended functionality | Identifiers; Additional Data; Commercial Information

Undertaking internal research for technological development and demonstration | Identifiers; Additional Data; Personal  Classifications; Commercial Information; Online Activity; Employment Information; and Inferences

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, 
and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, 
or controlled by us | Identifiers; Additional Data; Personal  Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences

Categories of Sources of Data Collection | Categories of Personal Information

Directly from you or your device, such as through your use of our  website, when you send us an email, visit or stay in our affiliated  Communities, or otherwise communicate or interact with us | Identifiers; Additional Data; Personal Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences

Individuals, such as your family members or friends who may inquire about our services or other individuals who may refer you to us | Identifiers; Additional; Personal Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
Note, if you provide us with personal information of another person you must have their consent to do so.

Vendors to whom you have provided your information | Identifiers; Additional Data; Personal Classifications; Commercial Information; Online Activity; Employment Information; and Inferences

Advertising and social networks | Identifiers; Additional Data; Personal Classifications; Commercial Information; Online Activity; and Inferences

Categories of Third Parties | Categories of Personal Information

Our corporate affiliates | Identifiers; Additional Data ; Personal Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Vendors who provide services on our behalf | Identifiers; Additional Data; Personal Classifications; Commercial Information; Online Activity; Sensory Information; and Inferences

Professional Services organizations, such as auditors and law firms | Identifiers; Additional Data; Personal Classifications

Advertising and social networks | Identifiers; Additional Data; Personal Classifications; Commercial Information; Online Activity; and Inferences