Sayhut Privacy Statement.docx

Privacy Statement

Last Revised: 2023-12-10

Data Controller Contact Information:

Hassan Mir

Ottawa Heart Institute Research Corporation (OHIRC)
40 Ruskin Street

Ottawa, Ontario, K1Y4W7

hmir@ottawaheart.ca

Privacy Officer
Jennifer Lajeunesse
Email: jlajeunesse@ottawaheart.ca

The OHIRC team are committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Statement is to inform you about the types of Personal Information OHIRC (as follows, “we” or “us”) collects, uses and discloses in connection with the Sayhut Smartphone Applications (as follows, “Platform”). It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, and specifically the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Health Information Protection Act (Ontario) and the regulations thereunder. From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently.

The following topics will be covered in this Privacy Statement:

What is Personal Information?
How do we collect your Personal Information?
Where do we store your Personal Information?
How do we use your Personal Information?
To whom do we provide your Personal Information?
When and how do we obtain your consent?
How long will we utilize, disclose or retain your Personal Information?
How can you review your Personal Information that we have collected, utilized or disclosed?
How do you know that the Personal Information we have on you is accurate?
What if the Personal Information we have on you is inaccurate?
How fast will we respond to your written requests?
What safeguards have we implemented to protect your Personal Information?
How do you contact us regarding access to your Personal Information or our privacy practices

1. What is Personal Information?

“Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, contact information, and usernames.

2. How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means. In the current Platform, Personal Information is obtained directly from you or as otherwise required or permitted by law.

3. Where do we store your Personal Information?

We will keep the Personal Information that we collect within Amazon Web Services (AWS) data centres in Canada.

4. How do we use your Personal Information?

We generally use your Personal Information for the following purposes (the “Purposes”):

Facilitate and administer your access to the Platform and your use of the Sayhut Platform;
To track use to ensure optimal, streamlined experience;
To facilitate communications with third-party service providers with whom we have a contractual relationship such as, Physicians and research study team members;
To advise you about new programs and services that may be of interest to you;
To respond to your inquiries, complaints or requests;
To collect opinions and comments in regard to Sayhut operations;
such other uses as may be permitted or required by applicable law.

5. To whom do we provide your Personal Information?

Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing:

We may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as, Physicians, Research team members, and service providers that provide Platform support or data storage or processing.
We may also make disclosures of Personal Information to a potential acquiror in connection with a transaction involving the sale of some or all of the business of Sayhut (in which case the use of your personal information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law. In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

6. When and how do we obtain your consent?

By registering for the Platform, you are consenting for us to have access to your name, username, and email. We will be tracking your use of the Platform in an effort to optimize and streamline the application. This information will also be used in a research capacity to demonstrate usability and feasibility of the Sayhut Applications.

7. How long will we use, disclose or retain your Personal Information?

We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

8. How can you review your Personal Information that we have collected, used or disclosed?

If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.

9. How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

10. What if the Personal Information we have on you is inaccurate?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. We will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

11. How fast will we respond to your requests?

We will attempt to respond to each of your written requests no later than 30 days after receipt of such requests. We will attempt to your email requests within one business day.

12. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees, who are granted access to your Personal Information, are those with a business ‘need-to-know’ or whose duties reasonably require such information.

13. How do you contact us regarding access to your Personal Information or our privacy practices?

All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Statement or our privacy practices, should be forwarded to Hassan Mir (hmir@ottawaheart.ca) or our Privacy Officer Jennifer Lajeunesse (jlajeunesse@ottawaheart.ca)