Policy Updated: November 2018
The governing legislation ensures citizens’ right to privacy. Thus we have a clear obligation to inform clients and service provider(s) of what personal information is collected and for what purposes: to store the information securely, to be clear about who has access to that information and to inform them of what information will be shared in what circumstances.
Synergy Gateway Inc. has developed our privacy statement to clearly demonstrate our organization’s commitment to the privacy of our visitors and users. The following discloses our information gathering and dissemination practices for this website.
1.1 We are committed to safeguarding the privacy of our website(s) and the applications/softwares that we deploy collectively referred to as “sites” throughout this document.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our sites; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our sites incorporates privacy controls and certain applications require informed consent, which affect how we will process your personal data. By using the privacy controls and informed consent, you can specify whether you would like to receive communications and limit the publication of your information. In all cases where personal information is collected, it is never shared outside of limitations of your informed consent.
1.5 In this policy, “we”, “us” and “our” refer to Synergy Gateway Inc. For more information about us, see Section 8. The sites covered by this policy are the following: www.synergygateway.com, Verified Application (specific login page site not disclosed for this publication), myvirtualdoctor (specific login page site not disclosed for this publication) and Virtual Doctor (specific login page site not disclosed for this publication)
2.0 How we use your personal data
2.1 In this Section 2 we have set out:
2.1.1 general information on how we collect information on this website
2.1.2 the general categories of personal data that we may process;
2.1.3 in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
2.1.4 the purposes for which we may process personal data; and
2.1.5 the legal bases of the processing.
2.2 The personal information we collect can be divided into two main categories: information you give us, and information we collect automatically.
Information You Give Us:
We request to collect information from you when you are engaged in an of the following activities on our sites:
- Login and/or Sign in to any of our websites, applications or services
- Create an account for any of our websites, applications or services
- Demo Request
- General Inquiry
- Synergy Services Inquiry
- Booking appointments for services
- Registering for information
- Appointment Management
- Video Conferencing
- Content Downloads
- Contact Us Inquiry
- Quotation Request
You can choose whether or not to disclose your personal data while engaging in these activities. However, if you do not provide the information we have deemed mandatory, you will not be able to take full advantage of the sites and their functions or content.
When you submit data on our sites, you will be consenting to Synergy Gateway Inc. processing the categories of personal data that you have provided. The categories of personal data that we collect are as follows:
We may process your contact data (“contact data”). The contact data may include your first name, last name, email address, and phone number, mailing address, school, program, course, year, semester/term. The contact data may be processed for the purposes of communicating with you, operating our sites, providing our services, processing requests, record-keeping, and marketing and sales purposes. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our site, business and services we provide and communications with users.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters, and/or receiving service updates and notifications, and/or downloading content, confirmation of event or service registration, changes to any current or future registrations, notifications if you change your communication preferences, removing you from our mailing list upon your request, and adding you or deleting you from our marketing database (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications, and/or information on relevant services, and/or newsletters, and/or content. The legal basis for this processing is consent.
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our sites will generate the metadata associated with communications made using the sites contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our site, business and services we provide and communications with users.
We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
We may process “health data”. We collect this data when you are registering for services that require you to provide personal health data such as Verified, myvirtualdoctor and Virtual Doctor. This data is collected through your informed consent and is only used under the limitations of that consent. The data collected is dictated by your (school/organizations) specific requirements for Synergy Gateway to administer and provide services to you. The Health Data is shared with your informed consent to the parties deemed appropriate and necessary for the purposes for which the health data was collected. The legal basis for this processing is consent OR if processing is necessary in order to protect the vital interests of the data subject or of another natural person.
Information We Collect Automatically:
We request and/or request to collect information from you when you are engaged in an of the following activities on our sites:
A. Visiting our website:
We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and site navigation paths, as well as information about the timing, frequency and pattern of your service use.
The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
Synergy Gateway Inc. does not purchase marketing lists from third-parties.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.0 Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, divisions, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. In addition, we may share your information with those identified through your informed consent for any of the services you have registered for and participate in with Synergy Gateway Inc. Information about our group of companies can be found in section 8.
3.2 We use several third-party services to process the data we collect. We may process the following data categories: Contact Data, Usage Data, Notification Data, Inquiry Data, Correspondence Data, using our suppliers, partners or subcontractors, namely Zoom, Heroku, Sparkpost, Setster, Ontario Telehealth Network, Ministry of Health of Ontario, Telus Health, QHR Technologies, Gallivan Student Health and Wellness insofar as reasonably necessary for the purposes specified in section 2 for each respective category. The Personal Data will only be processed for the aforementioned purposes. Health Data will never be processed by our processors unless it is required by them and you have agreed to an informed consent for its use. We have entered into an agreement with each of our processors to ensure that they comply with the general data protection requirements and protect your Personal Data in accordance with the highest standards.
3.3 We use a third-party service to process some of the data we collect. We may process the following data category: Usage Data, using our supplier: Google Analytics, insofar as reasonably necessary for the purposes specified in section 2 for. The Personal Data will only be processed for the aforementioned purpose. We have entered into an agreement with each of our processors to ensure that they comply with the general data protection requirements and protect your Personal Data in accordance with the highest standards.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.0 International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 Synergy Gateway Inc. has a single office in Canada. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. According to the European Commission, Canada offers adequate protections for the transfer of data. Data transferred to Canada will be covered by the adequacy decision. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4.3 The hosting facilities for our sites are situated in Canada. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of Canada. Transfers to Canada will be protected by the adequacy decision.
4.4 Synergy Gateway Inc. uses the following partners and subcontractors to assist some data processing: Zoom, Heroku, Sparkpost, Setster, Ontario Telehealth Network, Ministry of Health of Ontario, Telus Health, QHR Technologies and Gallivan Student Health and Wellness. These partners/subcontractors are situated in the United States and/or Canada. The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of Canada. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission OR the EU-U.S. Swiss-U.S. Privacy Shield Framework. Transfers to Canada will be protected by the adequacy decision.
4.5 You acknowledge that personal data that you submit for publication through our sites or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5.0 Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes for which it was obtained or agreed to through your informed consent.
5.3 We will retain your personal data as follows:
- Usage Data will be retained for a maximum period of 26 months following the date of collection.
- Contact Data will be retained for a maximum period of 5 years following the date of collection.
- Notification Data will be retained for a maximum period of 5 years following the date of collection.
- Correspondence Data will be retained for a maximum period of 5 years following the date of collection.
- Inquiry Data will be retained for a maximum period of 5 years following the date of collection.
- Job Application Data will be retained for a minimum period of the job application process following the application date, and for a maximum period of 5 years following application rejection date. If the job applicant is successful, the data will be subject to the Synergy Gateway Inc. Human Resources Policy.
- Health Data will be retained in perpetuity until the user specifically request for his/her data to be purged and deleted in its entirety, unless otherwise required by law and/or healthcare regulations in Canada.
Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our sites.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or through a notification on our sites.
7.0 Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
7.2.1 The right to access: The Right of Access. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.2.2 The right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.2.3 The right to erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.2.4 The right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.2.5 The right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.2.6 The right to object to processing for marketing purposes: You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.2.7 The right to complain to a supervisory authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.2.8 The right to withdraw consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.2.9 The right to data portability: To the extent that the legal basis for our processing of your personal data is:
18.104.22.168 Informed consent; or
22.214.171.124 that the processing is necessary for the performance of a contract/agreement to which you are party or disclosed as users or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.3 How to Exercise Your Rights. You may exercise any of your rights in relation to your personal data by written notice to us sent to: firstname.lastname@example.org.
8.0 Our details
8.1 This website and any of our affiliated sites or applications are owned and operated by Synergy Gateway Inc.
8.2 We are registered in:
8.2.1 Canada as Synergy Gateway Inc., A Provincially Incorporated Corporation located at 202-29 Gervais Drive, Toronto, Ontario, M3C 1Y9, Canada
8.3 Our principal place of business is at 202-29 Gervais Drive, Toronto, Ontario, M3C 1Y9, Canada
8.4 You can contact us:
8.4.1 by post, to 202-29 Gervais Drive, Toronto, Ontario, M3C 1Y9, Canada;
8.4.2 using our website contact form;
8.4.3 by email, using email@example.com
9.0 Data protection officer
9.1 Our data protection officer’s contact details are:
9.1.1 Email: firstname.lastname@example.org
9.1.2 Mail: Attn: Privacy Officer, 202-29 Gervais Drive, Toronto, Ontario, M3C 1Y9, Canada
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