Retirement communities are responsible for their own privacy practices when using the Platform, including getting consent to collect, use and disclose Residents’ and Family Members’ Personal Information and/or personal health information as may be required by law.
2. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
2.1. Recreation Staff Information
In order to use the Platform, Recreation Staff must have a valid Welbi account to log into Welbi (“Account”). When Recreation Staff register for Welbi, Welbi collects each of their:
- first and last names;
- email address;
- phone number;
- Retirement Community information, including phone number, address, organizational preferences, facilitators, recreational program activities and/or types, Retirement Community Logo; and
- billing information, including credit card details and billing address.
Welbi uses this Personal Information to uniquely identify each Recreation Staff member as a user, authenticate their Account access, and provide Recreation Staff with access to the Platform and Services. Welbi also uses this Personal Information for record keeping and data analytics. Welbi uses billing information to process payments for subscription fees in respect of any paid subscriptions to the Services.
Welbi administers surveys and collects responses from Recreation Staff to improve the Recreation Staff experience, the Platform, and the Services.
2.2 Residents’ and Family Members’ Information
Welbi collects Residents’ and Family Members’ names and emails from Recreation Staff to allow the Recreation Staff to invite Residents and Family Members to use Welbi. Upon Residents’ Account creation, Welbi collects the following Personal Information of Residents and Family Members:
- Residents’ contact and identification information, including first and last name, phone number, address, email address, photograph
- Residents’ demographic information, including date of birth, gender, marital status, languages spoken, level of education, religious affiliation, occupational history, status as a veteran of the armed forces, previous places of residence;
- Residents’ physical and psychographic information, including physical assessments, emotional assessments, intellectual assessments, social assessments, spiritual assessments, community assessments, recreation assessments;
- Residents’ personal preferences, including hobbies, musical preferences, event type preferences, and event time preferences;
- Residents’ activity attendance information, including which activities Residents have attended or not attended, Residents’ engagement level at activities, Residents’ level of satisfaction with activities, comments, and progress notes;
- Family Members’ contact information, including first and last name(s), phone number, email address, relationship to Resident.
The Personal Information above is collected from Recreation Staff or Residents directly. It is stored on behalf of Recreation Staff and Residents to maintain Residents’ records, produce data analytics, and to provide the Services.
Welbi administers surveys and collects responses from Residents in order to improve Residents’ experience, the Platform, and the Services.
2.3 Welbi Platform Usage Data
The Platform tracks certain information about usage of the software Platform, including the entry of Resident information and Platform usage (i.e. time spent on platform, frequency of logins, etc.) (“Usage Data”). Welbi uses Usage Data in order to diagnose technical issues with the Platform, monitor and improve Platform efficiency, monitor and create logs for security purposes, and to inform product development and Platform improvement. Aggregated and anonymized Usage Data may be used for marketing purposes to allow Welbi and its partners to provide customized advertising and recommendations.
2.4 Website Data
Welbi may also collect certain information from users of the Website through web forms that collect your first name, last name, email address, phone number, and may also collect Internet addresses, time spent logged into the website, and other usage data (“Website Data”). This information is logged to respond to user queries, provide ongoing email updates, and to continually improve the quality of the Services.
The Welbi Website uses "cookies" to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your e-mail address or identity. We may use "persistent cookies" to save your registration ID and login password for future logins to our service or XSRF tokens for cross site scripting protection. We may use "session cookies" to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. You can change your browser options to stop accepting cookies or to prompt for your permission before accepting cookies. Choosing to decline cookies may affect your access to our products and services. The Welbi Website may include links to third-party Web sites. These third-party Web sites may assign different cookies to you. Those cookies may be used to track your involvement with the advertising site. You may choose not to accept these cookies. Welbi does not control these parties, and you should review their privacy policies to learn more about what, why and how they collect and use personal information.
3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Welbi stores its Platform data, including Personal Information, using cloud services on servers located in Canada. By submitting Personal Information, you agree to this transfer, storing or processing of your Personal Information in Canada by our service providers (including those mentioned in Section 4.1). You acknowledge and agree that your Personal Information may be accessible to Canadian law enforcement and governmental agencies under lawful access regimes or court order.
4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1. Service Providers and Business Partners
We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Platform and related Services. In particular, Welbi uses cloud services provided by Amazon Web Services Inc., which may be replaced or supplemented by Welbi from time to time (“Service Providers”). Unless we tell you differently, such Service Providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of software licensing, maintenance services, database management, Web analytics and general improvement of the Platform and related Services.
4.2. Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
4.3. With Your Consent
6. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service. All requests to delete your Personal Information must be directed to Welbi’s Privacy Officer, whose contact information is listed in Section 8, below.
8. ADDITIONAL INFORMATION
Attn: Privacy Officer
Welbi Technologies Inc.
7 Bayview Road
Ottawa, Ontario K1Y 2C5
Last Updated: March 17, 2019