CANADA HEALTHLABS PRIVACY POLICY


 
Canada HealthLabs (CHL) is responsible to safeguard personal information you have voluntarily disclosed to CHL and use the information only for the purposes for which the information was collected.

This privacy policy explains how CHL processes Personal Information (defined below), collected both through the CHL website and for its research studies. For simplicity and the purposes of this policy, “Study Participant” means a person who has given any Personal Information to CHL as part of the enrollment process for an CHL research study, whether or not such individual fully enrolls or actively participates in the research study, and “Visitor” means an individual who visits www.CHLtest.com and/or www.canadahealthlabs.ca (together or individually herein referred to as the “CHL website” as applicable).

Personal information

Personal Information provided to CHL for research studies and information gathered by visiting the CHL website are treated as confidential information. All such information is stored securely and is accessed by authorized personnel only. CHL implements and maintains appropriate technical, security and organizational measures to protect Personal Information against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

The information you provide to CHL is considered “Personal Information” (as that term is defined in the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA)), if it is possible to relate it back to you through your name, address, e-mail address, telephone number and includes any other information that can identify you. The term “Personal Information”, as used in this privacy policy, also includes any “Personal Health Information” (as that term is defined in Ontario’s Personal Health Information Protection Act (PHIPA)) that you may provide, or which may be obtained, during the course of your participating any research study, as applicable. CHL is required to and does comply with all applicable privacy laws, including PIPEDA and PHIPA in connection with the collection and processing of Personal Information and Personal Health Information.

If information cannot identify an individual it is considered anonymous information. This would include laboratory results identified by alpha-numeric code or identifier instead of the individual’s name, address or other contact information). CHL primarily works with anonymous information. This privacy statement does not apply to anonymous information.

Consent to provide Personal information

a) Collection of information from Visitors to the CHL Website

If you are a Visitor to the CHL Website then this section is for you.

By visiting the CHL Website, you consent to the collection and use of your Personal Information as described herein. If you do not agree with the terms set out therein, please do not continue to visit the CHL Website.

CHL collects, records, analyzes and otherwise processes Personal Information of Visitors. CHL may record your IP address and use cookies. CHL may use information collected by way of pageview activity.

CHL uses the collected data to communicate with Visitors, to customize content for Visitors, to show ads to support enrollment in research studies, and to improve its website by analyzing how Visitors navigate the CHL Website.

CHL may also share such information with its service providers in order to provide a requested service or transaction or in order to analyze the Visitor behavior on its website.

Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the CHL Website, you agree to the placement of cookies on your computer or device. If you choose to not accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes.

Please be aware that while visiting the CHL Website, Visitors may follow links to other sites that are beyond the sphere of influence of CHL. CHL is not responsible for these links or any sites to which they lead.

b) Collection of Personal Information from individuals for research study purposes.

CHL only collects Personal Information from you according to this policy, applicable laws or after you give CHL your consent. If you registered to participate in one of the research studies, you will have signed an informed consent form, whether or not you fully enrolled in the Study. CHL collects the Personal Information to conduct its research studies as outlined in the online informed consent form that you signed (electronically).

Providing CHL with your Personal Information is entirely voluntary. However, your Personal Information is required for you to enroll and participate in the research studies. If you do not agree with the use and disclosure of your information as provided in this policy or the informed consent form, please do not provide us with your Personal Information. In that event, you will not be entitled to participate in the research studies. In the event of a conflict between this policy and the informed consent that you signed, the informed consent will always govern.

You may withdraw your consent for CHL to use your Personal Information, however if you are participating in a research study, any withdrawal of consent is subject to the original informed consent. Your withdrawal of consent will apply as of the date CHL receives the withdrawal request, and will mean you will not be able to continue as a study participant. Upon receipt of such request, you will be withdrawn from the study. Your withdrawal of consent is not retroactive. CHL is obligated to retain certain information and data obtained from those who participate in its research studies as prescribed by law or regulation, including all information you have provided or that has been obtained during the course of the research study. For clarity, no Personal Information is ever made public or published.

If you start the registration process to enroll in a research study and do not complete the enrollment, upon your written request to CHL, CHL will delete your name and contact information from its records within 14 days of the request. Other information and data will be retained for study purposes in anonymized form.

CHL does not knowingly collect Personal Information from anyone under the age of 18, and does not permit individuals under the age of 18 to participate in its research studies. Any information that is collected is not used if CHL discovers that it has been provided by a person under the age of 18.

CHL does not trade or sell your Personal Information.

Safeguarding your personal information

CHL keeps your Personal Information in electronic format only, and as provided above, retains it as necessary for the reason it was collected and as required by law.

The Personal Information you provide to CHL is protected by strict security measures. Records are electronically and maintained on a secure network. The disposal of records containing Personal Information is conducted in a secure manner.

CHL takes steps to protect your Personal Information from theft, loss and unauthorized access, copying, modification, use, disclosure and disposal. We also take steps to ensure that those who provide services for CHL protect your privacy and only use your Personal Information for authorized purposes. CHL conducts audits and complete investigations to monitor and manage our privacy compliance.

All Personal Information provided to CHL is processed and stored in Canada at all times and protected from disclosure in accordance with industry standards. CHL has contracted with VERTO HEALTH INC. (“Verto”) for these services. Verto has a comprehensive Corporate Information Technology and Information Security Policy alongside its publicly posted Privacy Policy (https://goverto.com/privacy_policy.html) which outlines the way Verto manages information and protects the privacy of its clients and customers. As a non-diagnostic, non-invasive digital tool, Verto products are exempt from Software as a Medical Device (SaMD) regulations set by Health Canada and by the American FDA. Based on its existing controls, Verto is currently fully compliant with PIPEDA, PHIPA and HIPAA regulations.

Correcting your personal information

If you are a Study Participant and wish to change your contact information, please contact your Research Coordinator directly at the number provided in the informed consent form and include the information you would like corrected. CHL requests that you maintain your Personal Information accurate, complete and up-to-date for the duration of the Study.

If you have registered for a research study and decided to not complete the enrolment process, and would like to delete your name and contact information, please email CHL’s privacy officer at the email address below with your request.

Changes to our privacy practices

If CHL changes its privacy practices, including this privacy policy, a notice of change will be posted on the CHL website. Changes will apply to all Personal Information held by CHL, regardless of when it was collected, subject to any informed consent that you may have signed.

Questions or comments If you have questions or comments about how CHL collects, uses or disposes of your Personal Information please contact the CHL privacy officer at: privacy@canadahealthlabs.ca.

Or:
Canada HealthLabs
120 Adelaide St. W.
Suite 2150, Toronto, Ontario M5H 1T1

CHL will respond to you within 30 days after we have received the request.