Our Privacy Philosophy

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At Senior Care Connect Inc. (“Senior Care Connect”, “we” or “us”), we sincerely value the trust that you have placed in our business.  We have adopted this privacy policy (the “Policy”) to affirm our commitment to maintaining the accuracy, confidentiality, and security of personal information. 

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This Policy explains how we collect, use, disclose and safeguard the personal information that you or a third party provide.  Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Senior Care Connect’s collection, use and disclosure of personal information in accordance with this Policy. If you provide personal information to us about a third party (for example, an elderly family member who requires senior care) or authorize a third party to disclose personal information to us, you agree that you were authorized to do so.

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For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means.  The meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable provincial and federal privacy legislation.

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Our Privacy Principles

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Identifying Purposes and Obtaining Your Consent

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We identify the purposes for collecting personal information at or before the time it is collected.  We will not collect, use or disclose your personal information without your informed consent, unless required or permitted to do so by law. 

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At Senior Care Connect, we collect, use, and disclose personal information so we can: (i) allow caregivers to offer their services directly to customers and their family members; (ii) connect customers and their family members with caregivers; (iii) provide information to our employees, contractors, and affiliates in connection with their provision of services; (iv) send you newsletters or other communications to which you have subscribed or may be interested; (v) comply generally with privacy laws and all other applicable regulatory requirements; (vi) run and manage our business (including planning, quality improvement, processing payments, reporting, and resource allocation); (vii) understand the demographics, interests, usage patterns, and other characteristics of our customers and to track and analyze trends and patterns, including through the aggregation of personal information; (viii) administer surveys, contests, draws, and raffles; (ix) offer you tailored content; and (x) as otherwise set out in this Policy. We may also use your personal information to communicate with you.  

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Should we require your information to fulfill a purpose that is not identified in this Policy, we will obtain your consent before proceeding.

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Limiting the Collection, Use and Disclosure of Your Personal Information

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The information we collect

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We collect personal information by fair and lawful means and limit collection to that information which is necessary for the purposes identified in this Policy.  The type of personal information that we may ask for, including when you sign up as a member or subscribe for services, includes: (i) your name, mailing address, email address, and telephone number; (ii) with respect to the person for whom senior care would be provided, their name, gender, age, a description of medical concerns (for example, that the senior has difficulty walking, requires bathing, has cancer, has dementia, etc.), telephone number, mailing address, and email address; and (iii) other information that you share in your communications with us, our employees, or our contractors, including on or through our websites www.seniorcareconnect.ca and www.seniorcareconnect.co (collectively, the “Websites”).   

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The choice to provide us with your personal information, either directly or through a third party, is always yours.  However, your decision to withhold particular information may limit our ability to provide you with some of our products or services.

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When you order a police check through the Websites, you agree that the results of the police check can be disclosed from the third party service provider to us and that we can use the information disclosed in the police check to evaluate whether you will permit you to provide caregiving services.

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How your information is collected

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Personal information may be collected in a number of ways, including: in person, over the phone, by mail, by fax, over the Internet (including from our Websites, by email, or through any of our applications for mobile devices or other software that we provide), and from third parties who you have authorized to disclose personal information to us.

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We may collect usage information from users of our services, including through the use of cookies and beacons. Usage information collected from our Websites may include your device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, and frequency of use.

If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately. 

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Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or except where required or permitted by law.

 

We may monitor and record telephone calls

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For the purpose of maintaining quality service, telephone calls to our customer service lines may be recorded.  If your call is subject to a quality assurance program, you will be so advised prior to speaking with a representative. 

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Disclosure to third parties

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We will only disclose your personal information to third parties if you have so consented or if required or permitted by law.    

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The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements.  In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities.  Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so. 

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Your personal information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights or to investigate suspicion of unlawful activities.  We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property and safety of ourselves and others. 

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You also understand and agree that we may use your personal information and disclose your personal information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction.  These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets.  Our successors and assigns may collect, use and disclose your personal information for substantially the same purposes as those set out in this Policy.  In the event the transaction does not go through, we will require, by contract, the other party or parties to the transaction not to use or disclose your personal information in any manner whatsoever for any purpose, and to return or destroy such personal information. 

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When you provide personal information to Senior Care Connect through the Internet, the information is stored on our server hosted by a third party.

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If you use a credit or debit card for your purchase, your credit/debit card-related information is required to process your payment. We do not store your payment information. Your payment information will be provided directly to our third party payment provider.

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If you make post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Websites or other applications, your communications may be viewable by the public or our service providers.

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If you offer to provide caregiving services, then members of the public (including potential customers) will be able to see details about the services that you (or your employees/contractors) are offering to allow them to determine whether they wish to hire you.

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For example, they will be able to see (i) the areas that a caregiver serves; (ii) the types of services that a caregiver is offering; (iii) a caregiver’s availability; (iv) a caregiver’s name; (v) a caregiver’s years of experience; (vi) whether a caregiver has completed a police check with no cause for concern; (vii) a caregiver’s hourly rate; (viii) the languages that a caregiver speaks; (ix) details about a caregiver that a caregiver chooses to disclose (e.g. hobbies, background, etc.); and (x) why a caregiver decided to offer caregiving services. A caregiver’s email address and residential address will not be publicly disclosed. If a potential customer is interested in contacting a caregiver, we will message the caregiver on behalf of such customer. We will then connect the caregiver and the potential customer via email.

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If you are interested in purchasing caregiving services offered through the Websites, then we will disclose your email address to a caregiver from whom you are interested in purchasing caregiving services.

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We may share your personal information with our affiliates. We may combine information internally across our affiliates or our different products and services and may further combine information with demographic information, publicly available records and other third party information sources. We may use this information to provide you with a customized experience and to promote and develop our products and services or those of third parties.

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Except as specifically provided for in this Policy, we do not disclose any personal information to third parties.

 

Keeping your information accurate

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We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary.  If desired, you may verify the accuracy and completeness of your personal information in our records.

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Despite our best efforts, errors sometimes do occur.  Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis.  In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate. 

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Protecting Your Personal Information

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Access to your information within Senior Care Connect

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Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees or contractors with legitimate business reasons.  For example, in order for service providers to provide the selected services, they will need to access your information to verify your identity and to properly assist you.

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Our employees and contractors understand the importance of keeping your information private.  All employees and contractors are expected to maintain the confidentiality of personal information at all times and failure to do so will result in appropriate disciplinary measures including dismissal.

 

Disposal and Retention

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Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfil the purposes for which it was collected.

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Safeguarding your information

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To ensure that your personal information is protected, we utilize security safeguards that are on par with the industry standard.  We use modern technologies to ensure that your confidential information is not compromised. We keep electronic customer files in a secured environment with restricted access and use. 

 

Addressing Your Inquiries and Concerns

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We are happy to provide you with a copy of this Policy and to discuss any of its content with you.

 

Upon request, we will also inform you of: the type of personal information we have collected; how your personal information has been used; and any third parties to whom your personal information has been disclosed.

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Please direct all questions or enquiries about this Policy to:

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Privacy Officer, Senior Care Connect

169 Enterprise Blvd., Unit 300

Markham, ON, L6G 0E7

Email: info@SeniorCareConnect.ca

 

Updating this Privacy Policy

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Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner.  Senior Care Connect reserves the right to change, modify, add, or remove portions of this Policy at any time.  Please check this page periodically for any modifications.  To determine when this Policy was last updated, please refer to the modification date at the bottom of this Policy.

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Websites and Apps Governed by this Privacy Policy

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Our Websites and any applications available from our Websites or third party platforms (including the iTunes Store and Google Play) are governed by the provisions and practices stated in this Policy.  Our Websites and such applications may contain links to third party sites or applications that are not governed by this Policy.  Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Websites or such applications, and that we are not responsible for the privacy practices of third party sites or applications.  We therefore suggest that you closely examine the respective privacy policies of third party sites and applications to learn how they collect, use and disclose your personal information.

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Governing Law and Personal Information in Other Jurisdictions

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This Policy and all related matters are governed solely by the laws of Ontario and the applicable federal laws of Canada.

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Senior Care Connect may perform activities outside of Ontario and outside of Canada through third parties. Personal information provided to our payment processors may be stored outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions.  For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.

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Last revised Monday, May 3, 2021  

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32461848.6

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