Privacy

Maintaining the privacy and protection of your information is our top priority.

Protecting your Information

We meet or exceed all requirements under the HIPAA Privacy Rule in the USA, as well as Canada's PIPEDA, PIPA, and FOIPPA legislation. All information in ePACT is stored in Canada, on secure servers in Toronto and Vancouver.

External Audits

We work with 3rd party auditors to review and assess our privacy and security policies and practices. Organizations interested in using ePACT can request a copy of our independently prepared Privacy Impact Assessment.

Anti-Spam Compliance

ePACT is fully compliant with Canadian Anti-Spam Legislation (CASL). We help organizations using our system make sure that they are too, by sending messages only to those people who have provided consent.

The following outlines ePACT's Privacy Policy. Please also see our Security page for details on how we keep your data safe.

About the ePACT Service

ePACT Network Ltd ("ePACT"/"we"/ "us") provides a communication network and emergency preparedness resource centre service which enables registered users (both organizational users and end users, collectively "ePACT Users") to build support networks of relatives, friends and organizations, store and exchange critical information, and access communication tools for greater interaction and preparation in the event of an emergency (the “Service”). The Service is described in greater detail in our Terms of Use. This Privacy Policy describes how we collect, store, use and disclose information about ePACT Users through the Service.

What type of information does ePACT collect?

ePACT collects information in the following ways: 1) information you supply about yourself and others when registering or using the Service, including your child(ren), guardians’ and emergency contacts’ contact information; 2) information others share about you or other ePACT Users (eg. health records provided by organizations like schools).

By using the Service (whether through the ePACT website or our mobile applications), ePACT Users consent to the collection and use of information as described above. ePACT Users consent to the use by ePACT of their personal information for the purposes outlined in ePACT’s Terms of Use. ePACT will restrict use of personal information to those purposes unless otherwise agreed between the ePACT User and ePACT. By sharing contact information about another individual with ePACT, the ePACT User represents that they have the consent of that individual to share such information as indicated below under Purpose of Use.

Personal Information & Collection

We collect personal information provided by individual ePACT Users of the Service and store it on their behalf. This information may include names, addresses, telephone numbers, email addresses, emergency contacts, medical alerts and photographs. At your discretion, you can share this information with other users including individuals, such as family members and emergency contacts, and organizations such as schools, daycares or businesses you connect with through the Service. You may correct and update your personal information at any time through the website or our mobile apps. We rely on you to ensure the information you provide to us is accurate and up to date.

a) Registration information

When you sign up for the Service, whether as an organizational user or as an end user, you will be required to provide your full name and email address and any other information listed as mandatory when you register.

b) Information you choose to store and share

Your information also includes the information you choose to store and share on the Service, such as your contact information, children's information, and information about emergency contacts and alternate guardians.

By providing information about other individuals, you represent to us that you have the consent of those individuals and authority to provide those persons’ information for the purposes of the Service. If we contact those individuals , we will invite them to opt in to receive further communications and/or to join the Service. If they elect not to participate, we will remove their personal information from our databases and notify you of this result.

c) Information Others Share About You

We may receive additional information about you from other ePACT Users, such as requests to add you to their support network, or that you act as an alternative guardian. Related information regarding those relationships and medical information which may be held by other ePACT Users (eg. From organizations with which you are affiliated) may also be received.

d) Information Obtained Automatically - Cookies

A cookie is a small data file that websites commonly send to browsers. A cookie file contains information that can identify users. We use cookies to track traffic patterns and add functionality to the website. Cookies don't identify people personally, but rather identify an individual’s computer when they visit our site (which could potentially enable your identification). A cookie cannot read data off hard disks or read cookie files created by other sites. ePACT will not use this computer identification to further identify individual users. A browser can be set to warn the computer user before accepting cookies. In this case, the computer user will receive the warning message with each cookie. The computer user may choose to refuse cookies by turning them off in their browser. Users do not need to have cookies turned on to use the majority of the ePACT website, however you may need to turn them on in certain areas of the site to perform certain functions.

Purpose of Use

The purpose for which personal information may be used by ePACT and administrators authorized on behalf of organizational users is to ensure that each individual end user (to whom the personal information relates) receives timely and effective assistance in the event of an emergency, which uses may include:

  • Disclosing information to medical personnel attending to the individual
  • Providing medical assistance to the individual
  • Contacting the individual’s family or emergency contacts, and
  • Any other action taken to ensure the health and safety of the individual

Emergencies may include:

  • Any event that presents a reasonable health or safety risk to the individual exclusively or as part of a collective
  • A sudden decline in the physical or psychological wellbeing of the individual rendering them in need of some assistance to ensure their health and safety, and
  • Any other circumstances under which a reasonable person would conclude that the use of the personal information is necessary to the health and safety of the individual.

We use aggregated, anonymized information collected through the Service only (eg. demographic information about our users) to improve our Services and for other analytical purposes.

Disclosures

We have put in place contractual and other organizational safeguards with our agents (see further agent information below) to ensure a proper level of protection of your personal information (see further Security information below). In addition to these measures, we will not disclose or transfer your personal information to third parties (who don’t require such information for the Service) without your permission, except as specified in this Privacy Policy (see further Important Exceptions below).

As at the date of this Privacy Policy, we share personal information about you in respect of the Service only with our service providers who require access in order to provide services on our behalf. For example, we use third parties to transmit emails and SMS (text message) notifications that you have subscribed to through the ePACT site. Such third parties may receive your mobile telephone number and/or email address (as applicable), solely for the purpose of transmitting those notifications. Our servers are located in Canada, however, your personal information may be available to the Canadian government or its agencies under a lawful order, irrespective of the safeguards we have put in place for its protection.

From time to time we may employ third parties to help us improve the ePACT website and/or the Service. These third parties may have limited access to databases of personal information solely for the purpose of helping us to improve the website and/or the Service. They are also subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

Important Exceptions: We may disclose your personal information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose personal information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your personal information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock (including any due diligence exercise carried out in relation to the same), provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Closing Your Account/Deletion of Personal Information/Access to Information

When you delete an account, it is permanently deleted from the Service. Deleted accounts are removed from the Service immediately and your account (including all information held within your account) is no longer accessible by you or anyone with whom it was shared. However, because ePACT maintains information back-ups to ensure the safety of our users' information, your information may remain in backup copies and logs for up to one month. ePACT will also maintain and store your personal information in Canada for the duration of our services to you.

You should only delete your account if you wish to permanently.

To delete your account, contact us at help@epactnetwork.com. Provide your first and last name and email address associated with your ePACT account. We will confirm your account deletion and your records will be removed from the system within two business days.

You can update your personal information and your emergency contacts at any time using the features of the Service.

Requests for access to Personal Information.

You have the right to access your personal information that ePACT retains for verification purposes. Upon receipt of your written request, we will provide you with a copy of your personal information. Access to personal information is not permitted without written consent. If a request for personal information is denied, we will provide reasons for the denial to you upon request. Formal requests made for personal information under the Personal Information Protection and Electronic Documents Act (Canada) or equivalent provincial legislation (eg. Freedom of Information and Protection of Privacy Act) will be processed in accordance with the provisions of the legislation. 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 provide mechanisms to update, correct, delete or add to your personal information as appropriate. The amended personal information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate information about you enables us to give you the best possible service.

Security

What safeguards are in place?
ePACT protects your personal information by making reasonable security arrangements against such risks as unauthorized access, collection, use, disclosure or disposal. Security measures have been integrated into the design, implementation and day-to-day operating practices as part of ePACT's commitment to the protection of personal information it holds. For more information please see our Security page.

Other

Updates
Privacy policy updates will be reflected on this page so that visitors to the site and users of the Service are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Users of the Service will be notified via the email address associated with their account, and upon login to the ePACT website or mobile app ePACT reserves the right to update this privacy policy at any time.

Compliance with Privacy Laws
ePACT complies with applicable laws and regulations of the relevant jurisdiction within which ePACT operates at any given time. Personal information is collected, used and disclosed in accordance with this policy and all applicable privacy protection laws as required by each jurisdiction.

As an ePACT end user and/or organization administrator responsible for individual User information within your organization’s network, you are also bound by the applicable laws of the relevant jurisdiction and must only collect, use and disclose personal information to which access is provided through ePACT in accordance with those laws in addition to ePACT’s Terms of Use, Privacy Policy and Code of Conduct.

Privacy Compliance Officer

ePACT has appointed a knowledgeable individual within its organization to be responsible for privacy compliance.

If you have any questions concerning the collection, use or disclosure of personal information of ePACT’s Privacy Policy, please contact privacy@epactnetwork.com

Compliance with Privacy Laws
ePACT complies with applicable laws and regulations of the relevant jurisdiction within which ePACT operates at any given time. Personal information is collected, used and disclosed in accordance with this policy and all applicable privacy protection laws as required by each jurisdiction.

As an ePACT end user and/or organization administrator responsible for individual User information within your organization’s network, you are also bound by the applicable laws of the relevant jurisdiction and must only collect, use and disclose personal information to which access is provided through ePACT in accordance with those laws in addition to ePACT’s Terms of Use, Privacy Policy and Code of Conduct.

Privacy Compliance Officer
ePACT has appointed a knowledgeable individual within its organization to be responsible for privacy compliance.

If you have any questions concerning the collection, use or disclosure of personal information of ePACT’s Privacy Policy, please contact privacy@epactnetwork.com Last Updated August 21, 2014


Last updated August 21, 2014

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