Privacy Policy
We are iTacit Healthcare Inc. (“iTacit”, or “we”, “our”, “us”), and we are committed to providing transparency with respect to our practices in handling personal information. As a service provider of software solutions (including our Platform and App) used by our customer organizations across Canada and the US to manage their employees and workforce matters, we process information, including personal information, on behalf of these customer organizations. While our customers use our solutions to input, manage and understand information about their own organizations and employees, we do not use such customer or employee inputted personal information for our own purposes. Ultimately, our customers are responsible for the information about their employees and organizations that they input and manage through our App and Platform, and any questions relating to such information should be directed to the relevant organization, directly.
This Privacy Policy outlines iTacit’s practices relating to the personal information that we collect, use and disclose for our own purposes (for example, log-in information relating to a customer account), and also how we protect all information that is in our custody. When you subscribe to and use our products or services, you agree to be bound by this Privacy Policy.
When used in this Privacy Policy “personal information” means any information about an identifiable individual. This may include, for example, your name, contact information, email address, information relating to your account with us, including your identity and the services you use, IP address and billing records. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.
Collection of Personal Information
iTacit collects and uses personal information from or about our customers as outlined, below. Note that we do not collect for our own purposes information that our customers or their employees/users may upload or post through our Platform or App or through use of our services, such as internally generated messages, polls, videos, documents and other material and information, which may include personal information (“Customer-Generated Information”). iTacit processes all such Customer-Generated Information on behalf of the customer.
Your Account. To register for an account on our Platform or through the App, we collect a user’s name, email address, a unique login name (such as an email address) and a password. All other information a user provides to set up an account (for example, a street address, phone number etc.), is optional. We also keep track of the number of active users a customer organization has using our Platform or App (without any identifying information about individual users) or in order to ensure we charge appropriate ‘per active user’ fees to the customer.
We also collect personal information including your address, city, company name, country, email address, name, phone number, job role, province, state, and ZIP/Postal code, if you fill in a contact form within our Platform or App.
Technical information. When you use our Platform or App, we may collect certain technical information about your device or your online behaviour using electronic means such as cookies. This information may include information about your visit to our Platform or App, including the IP address of your computer or mobile device and which browser you used to access the Platform/App, the time you accessed or used our Platform or App, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched, the pages you viewed, information you entered, etc. This data is used to measure and improve the effectiveness of our Platform or App, or enhance the experience for our customers. We treat this information as personal information when it is associated with your account or contact information.
IP geolocation.
In the event that you download and/or use our Platform or App, we may require and collect, directly from you, information necessary to authenticate you. We may also record your IP geolocation, allowing us to block the access to unauthorized users.
Cookies.
Cookies are information files that your web browser places on your computer or other device when you visit a website or use an app. Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. Cookies allow us to customize your user interface to speed up the navigation process and to make the Platform and App experience more efficient. If your browser is configured to reject cookies, you may not be able to use the features of our site.
Use of Personal Information
We make every effort to identify the purposes for which we will collect personal information at or before the time the information is collected. We will use your personal information only for the purposes disclosed at the time of collection or as otherwise set out in this Privacy Policy, unless we have your consent for another use, or unless such other use is authorized or required by law. We collect most of the personal information about you directly from you, with your consent.
iTacit generally collects personal information for the following purposes:
- to establish, develop and preserve our business relationship respectively with our customers and other individuals we deal with;
- to create, establish and administer customers’ accounts and to respond to customer inquiries;
- to provide the services and products we offer and ensure that all related transactions are supported and implemented;
- to establish or verify the credentials of customers;
- to authenticate the identity and preserve the privacy of customers contacting iTacit by telephone, electronic means or otherwise;
- for internal training and quality assurance purposes;
- as necessary, to establish or verify the credit of persons that use, or intend to use, one or more of the products or services offered by iTacit;
- to manage our business and ensure the efficiency, reliability and security of our systems;
- to meet legal and regulatory requirements and allow iTacit to meet contractual requirements relating to the services provided to customers;
- to ensure our records are accurate and to protect customers and iTacit from error and fraud;
- to understand and assess the interests, wants and changing needs of customers with a view to improving our products and services and developing new ones; and
- to provide personalized services as well as product recommendations to customers.
When possible, rather than using personal information, we will anonymize and/or aggregate personal information so that it no longer identifies an individual, and use it for the purposes mentioned above or any legal purpose.
Unless required or authorized by law, iTacit will not collect or use personal information for any other or new purpose without obtaining further consent.
We do not knowingly collect information from children, and we do not target our Platform or App to collect information to children.
Consent to the Collection, Use and Disclosure of Personal Information
We obtain consent for the collection, use, or disclosure of personal information through various means: orally or through written documents, including agreements, forms, as well as printed or electronic communications. The form of consent sought by iTacit will vary according to the sensitivity of the personal information, the reasonable expectations of the individuals and any requirements or standards established by law.
In general, by subscribing to iTacit products and services and/or submitting information to us in connection with using iTacit Platform or App, you are providing your consent to the collection, use, and disclosure of personal information as set out in this Privacy Policy, and, as applicable, in any agreement you may enter into with us. Moreover, by visiting, interacting with and/or using our Platform or App, you agree to benefit from, and be bound by, the terms and conditions of this Privacy Policy.
Right to Withdraw Consent
You can withdraw your consent to our use of your personal information at any time. If you do so, we may not be able to provide you with all of our services. We may nonetheless keep certain information if we have a legal basis to do so. For example, we may keep information if we need to do so to comply with a legal obligation, to resolve disputes and to enforce our agreements.
Sharing or Disclosure of Personal Information
Personal information may be made available by iTacit to third parties to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. We will NOT sell, rent or trade your personal information to any third party. However, we may share your personal information when authorized by law or as follows:
- To third party service providers. We may hire service providers, which may be affiliates or third parties, to perform services on our behalf. Some examples are service providers that process payments, host and provide back-end infrastructure of our App and Platform, manage our email and database, and provide spam protection. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. iTacit will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by iTacit itself.
- The payment processors (that collect and use credit card and other payment information) used by iTacit are:
o Stripe (Stripe Inc)
- Stripe is a payment service provided by Stripe Inc. Place of processing: US – Privacy Policy.
- As permitted or required by law. From time to time, iTacit may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
- Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
Privacy Policies of Third Parties. This Privacy Policy only addresses the use and disclosure of personal information by iTacit. In addition to third party service providers, other websites that may be accessible through our Platform or App have their own privacy policies and data collection, use and disclosure practices. Similarly, our customers have their own privacy policies with respect to their own collection, use and disclosure of personal information. We encourage you to familiarize yourself with the privacy statements provided by such third parties.
Analytics. The services contained in this section enable iTacit to monitor and analyze Platform and App traffic and use, and can be used to keep track of user behavior. In each case, a link to the service provider’s privacy policy is included, and explains how each collects, uses and discloses personal information.
HubSpot Analytics is an analytics service provided by HubSpot, Inc. Personal information collected: cookies and usage data. Place of processing: US – Privacy Policy
- Google Analytics (Google Inc.) – GA4
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this application, to prepare reports on its activities, and to share the reports with other Google services. The Google Analytics: GA4 Configuration tag initializes Google Analytics for your Google Analytics 4 property on a particular page. It handles behavior such as setting of Google Analytics cookies, sending automatic and enhanced measurement events, and declaring common settings.
Google may use the data collected to contextualize and personalize the ads of its own advertising network. Personal information collected: cookies and usage data. Place of processing: US – Privacy Policy
Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this application. Personal information collected: cookies and usage Data. Place of processing: US – Privacy Policy.
Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this application. Personal information collected: cookies and usage data. Place of processing: US – Privacy Policy. Privacy Shield participant.
We may also use the following tools:
- Lead Forensics
- Facebook Pixel
- LinkedIn Tags
- Yandex Metrica
- ZoomInfo
- Poptin Conversions
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733.
You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
Interest-Based Advertising
To opt-out of interest-based advertising, and to find information about how to block or limit cookies, visit AdChoices, the Canadian self-regulatory program for online interest-based advertising, administered by the Digital Advertising Alliance of Canada (“DAAC”).
Personal Information Stored and Processed in Canada
- iTacit maintains its services in Canada, and all data processed on behalf of our customers is processed and stored in Canada.
- For customers/website visitors, some service providers (for example, payment processors) may process information for iTacit outside of Canada.
- The storage locations are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the information we collect under this Privacy Policy is processed according to the provisions of this statement and the requirements of applicable law where the data is located.
Security of Personal Information
We use reasonable security measures to protect your personal information against unauthorized access, use, loss and disclosure. iTacit has implemented security measures that contain administrative, technical and physical controls that are designed to safeguard your personal information. For example, we store the personal information you provide on computer systems that have limited access and are in controlled facilities. When we transmit any data (such as messages, attachments, etc.) over the Internet, we protect it through the use of encryption.
Retention
We only retain your personal information for the time period necessary to fulfill the purpose for which it was collected and in accordance with applicable law.
- iTacit retains personal information for as long as necessary to provide the services and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified purpose will be returned to our customer or destroyed.
- Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria we use to determine the retention periods include:
- How long is the personal information needed to provide the services and operate our business? This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.
- Do users provide, create, or maintain the information with the expectation we will retain it until they affirmatively remove it? Examples include your login credentials. In such cases, we maintain the data until you ask us to delete or to cease using it, or until our retention policy settings are fulfilled.
- Is iTacit subject to a legal, contractual, or similar obligation to retain the data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.
Canada’s Anti Spam Law (“CASL”)
We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.
Access and Correction
Individuals have the right to access their personal information and to have it corrected. iTacit respects individuals’ right to access and correct their personal information. If you have an online account with us, you can log in at any time to access and update the personal information you have provided to us. In order to facilitate a request to correct or update information, we may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by iTacit.
If you are an employee of a customer, requests for access to and correction of your personal information or Customer-Generated Information should be directed to your employer, who controls the information. If you need assistance with the access or correction of personal information, please contact us using the contact information detailed below.
- How to Contact Us
If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that we have about you or your organization’s employees, please contact our Privacy Officer at: info@itacit.com or by mail at:
iTacit Healthcare Inc.
401 Bishop Drive, Suite 102
Fredericton, NB E3C 2M6