METICULON CONSULTING INC. PRIVACY POLICY
Introduction
Meticulon Consulting Inc. (“Meticulon”, “we” and/or “our”) provides assessment consulting services and software (the “Platform”) to enable Account Hosts to connect individuals with diverse abilities (the “Users”) with individuals the User authorizes (collectively, their “Network”) to facilitate access to social and employment opportunities across Canada (the “Services”).
In this Policy, “Personal Information” means information about an identifiable individual.
At Meticulon, we understand the responsibility that comes along with hosting your Personal Information. We have established this privacy policy (the “Policy”) to describe the various ways we host your Personal Information on the Platform.
Meticulon confirms that its role is solely to facilitate the Platform that hosts Personal Information. The Account Host assumes full responsibility for reviewing, accessing, managing and safeguarding all Personal Information hosted on the Platform and within accounts overseen by them. Furthermore, your Account Host shall ensure that such Personal Information is accessible only to authorized personnel and those within one’s Network.
The Personal Information hosted on our Platform is only used for limited, necessary purposes for your benefit. Meticulon is committed to protecting the privacy of all Personal Information which has been provided to us and we will work with each Account Host to manage Personal Information in accordance with applicable Canadian privacy legislation and any other applicable provincial or federal legislation.
This Policy describes the limited ways we may collect and use your Personal Information collected through the Services, where applicable, and what information the Account Host is responsible for managing on the Platform. This includes Personal Information collected, used, processed and disclosed through:
· Meticulon’s Platform
· Meticulon’s assessment Services
· Providing support for our Services
What Platform Does Meticulon Offer?
Meticulon provides a software and hosting Platform to align Users with coaches, resource providers, family, caregivers, employers, and other individuals authorized by each User (their “Network”). On the Platform, Users and their Network are able to access and share information with each other, including Personal Information. The Personal Information collected, used and disclosed through the Platform is managed by the Account Host in the course of providing assessments and ongoing coaching to Users, and may be provided directly by a User onto the Platform. Meticulon assists the Account Host and Users by providing the software and data hosting to enable them to use the Platform.
Personal Information Collected by the Account Host
In the course of using the Meticulon Platform, the Account Host will collect, use and/or disclose Personal Information about the Users.
We rely on Account Hosts to have the authority to use the Meticulon Platform to collect, use, process, store, and disclose Users’ Personal Information.
This Policy is not about the collection, use, and/or disclosure of Personal Information by the Account Host. If you would like to know more about how the Account Host that oversees your use and handles your Personal Information, or if you have any concerns about it, you should ask them about their policies and practices.
What Personal Information Does Meticulon Collect and Use in Providing the Services?
Meticulon provides a Platform to for Users and Account Hosts to collect, use, process, store, and disclose Users’ Personal Information. Below, we have described what types of Personal Information may be collected on the Platform.
We collect limited information that you provide to Meticulon through the use of the Platform. This includes your contact information, account and profile information collected when an
Account Host registers a User with an account associated with the Platform, and assessment results gathered by the Account Host. We use your account and profile information to provide you with access to the Platform and/or Services, to create and set up your account and user profile, and to administer your use of the Platform and/or Services. We also may use your account and profile information to facilitate connection between you and your Network. For example, the following information will be collected from each User when the Account Host creates the User’s account:
· Name
· Address
· Email address
· Telephone number
(collectively, your “Account Information”)
Meticulon also may receive Personal Information from and about individuals in a variety of ways, including: when it is provided directly; and when individuals interact with us and use the Platform and/or the Services. This may include, if you choose to provide it to us, limited personal health information, appointment information, job application information, and any other information that you choose to post on the Platform or share with your Network through the Platform.
Generally, the Platform will host Personal Information directly from the person to whom the Personal Information relates. However, given the nature of the Platform, Meticulon will sometimes receive Personal Information about you from a coach or someone else within your Network. If you have concerns about that Personal Information, you should address that concern directly with that person, or with the Account Host. Ultimately, the Account Host is responsible for handling such information, and Meticulon will only access such information to facilitate use of the Platform. Meticulon will reasonably assist Users in answering questions that they may have about their accounts.
Information Automatically Collected When Using the Platform
Meticulon uses various technologies which automatically collect certain information. These technologies include cookies and analytics technology. The information we collect includes device, technical and usage information, and geolocation information as follows.
· Device information: we may collect information regarding your internet connection, including your IP address, web browser type, and operating system when accessing our Platform.
· Usage details: we collect information about the sections of the Platform that you visit, the date and time of your use of the Platform, your in-media time, your actions within the Platform, crashes and other system activity on the Platform, if applicable, and certain content that you download from the Platform.
· Web analytics: We want to learn more about how Users interact with our Services so we can improve the Platform and better understand how Users can benefit from it. This information is not transmitted to or shared with any third parties.
How is Your Personal Information Used by Meticulon?
Meticulon uses the Personal Information that you provide to operate the Platform and our business, including to:
· present our Platform and its contents to you;
· provide you with information, products, or parts of the Services that you request from us or that we deem relevant to you;
· conduct data analysis, testing, and monitor and analyze usage and activity trends;
· ensure compliance with and identify violations of the applicable Terms of Use;
· identify and prevent fraudulent activity and to protect security of the Platform;
· meet legal and regulatory requirements; and
· facilitate such other services and activities, as we may identify to you at the time.
Where Required or Authorized by Law
Meticulon may also disclose your Personal Information where authorized or required by law. For example, we may disclose your Personal Information to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel.
Getting Your Consent
There are various ways you may consent to the collection, use and disclosure of your Personal Information processed through our Platform on behalf of the Account Host and Meticulon.
Typically, you will voluntarily post information on the Platform or will otherwise provide your consent for someone in your Network to do so.
When completing your initial assessment, the Account Host will measure each key performance indicator (each, a “KPI”) to form your assessment results. You should raise any questions you have about consent you have given the Account Host regarding the use or disclosure of your KPI directly with them.
As described above, there are some instances in which individuals provide Personal Information to Meticulon. If you create an account to use our Platform, or use the Services, you acknowledge the notices in this Policy and you consent to Meticulon’s collection, use, disclosure, and retention of your Personal Information in accordance with this Policy and as otherwise permitted by law. You may withdraw your consent at any time by giving Meticulon reasonable notice, but consent may not be withdrawn where doing so would frustrate performance of a legal obligation.
In some cases, Meticulon may seek your consent for the use and disclosure of your Personal Information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your Personal Information for a purpose not previously identified to you). We will not use or disclose your Personal Information for any new purpose without first identifying the new purpose and providing notice to you or obtaining your consent (as applicable), unless otherwise permitted by law. You can always choose not to provide Meticulon with certain requested Personal Information, but then you may not be able to access or utilize all or part of the Platform and/or the Services.
What Choices Do You Have About How We Use and Share Your Personal Information?
We want you to understand your choices and make informed decisions about how we use and disclose your Personal Information. There are several options available for you to manage your privacy preferences in the Platform including, for example by:
· managing your preferences within your account
· contacting Meticulon directly
· changing your browser settings, and/or
· contacting the Account Host.
We rely on you as a User to review and manage your privacy preferences, and to discuss access, use and disclosure with your Account Host so that you are fully informed of how your information is being used and who has access to it.
Tracking Technologies
As mentioned above, we use Cookies to track use of our Platform. Cookies are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. Meticulon uses cookies to track use of the Platform. Cookies may also be used to monitor traffic, improve the performance of the Platform, and to make the Platform easier and/or more relevant for your use. You can disable cookies by adjusting the settings on your internet browser. However, certain features of the Platform may not be accessible or may not function properly if you delete or disable cookies.
How Do We Secure Your Personal Information?
The security of Personal Information in our care is important to us.
We have built security features into our Platform to help the Account Host protect your Personal Information when they are using the Platform. Some of these features include access controls, unique user accounts, multi-factor authentication, and firewall threat detection. We have made security arrangements to protect against unauthorized access, collection, use, disclosure, and disposal of Personal Information, in a manner appropriate to the sensitivity of the information.
As well, Meticulon will use care when destroying or disposing of Personal Information to prevent unauthorized access, use or disclosure of any Personal Information. Meticulon’s employees with access to Personal Information are required to respect the confidentiality of such information.
The safety and security of your Personal Information also depends on you. Meticulon is not responsible for any lost, stolen, or compromised usernames, passwords or for any activity on your account via unauthorized password activity. You should take steps to protect against unauthorized access to your account by, for example, choosing a strong password and keeping your username and password private. Meticulon is not responsible for any failure by you to secure your own devices and their access to the Internet or your use of public, unsecured networks.
Unfortunately, information systems, the transmission of information via the Internet and mobile platforms are not completely secure. Although we have designed features and employed security techniques to protect your Personal Information, we cannot guarantee the security of Personal Information at all times. Any transmission of your Personal Information is at your own risk.
Where do we Store Data?
All of Meticulon’s data is stored by Amazon Web Storage (“AWS”), hosted on datacentres located in Canada, so your Personal Information is always stored in Canada.
If you have any questions about Meticulon’s policies and practices with respect to service providers outside of Canada, including its collection, use, disclosure, and storage of Personal Information, you can contact the Meticulon Privacy Officer at the details listed below.
Data Retention
Most of the data that Meticulon hosts is on behalf of the Account Host, coaches, and individuals through use of the Platform. As described above, we also collect limited Personal Information for use by Meticulon. Our approach to data retention in both cases is described below.
Personal Information Managed on Behalf of Your Network
Personal information that is collected by your coach or others within your network, including your Personal Information, is the responsibility of the Account Host, being the custodian of that information. Your Personal Information associated with your relationship with that custodian will be subject to the retention policies and practices of the custodian.
Personal Information You Provide to Meticulon
Personal information collected by Meticulon for its use directly is maintained in accordance with applicable privacy legislation and Meticulon’s retention policies and practices. Generally, Meticulon stores your Personal Information for as long as it is reasonably necessary to fulfill the purposes we collected it for, except as otherwise permitted or required by applicable law or regulation.
After twelve months of inactivity in your account, Meticulon will send you an email stating that deactivation of your account will take place in thirty days. If you do not access your account or respond to the email, your Personal Information will be scheduled for secure destruction or deletion. Where the Personal Information is stored in an electronic format, it will be securely deleted from the Platform.
If your account is deactivated as described above, Meticulon will not retain any of your Personal Information.
Under some circumstances we may de-identify or aggregate your Personal Information so that it can no longer be associated with you.
How Can You Correct and Access Your Personal Information?
You can challenge the accuracy and completeness of your Personal Information. It may be most appropriate for you to raise this with the Account Host which manages your information.
All Personal Information in your Meticulon account and user profile is accessible by you through the Platform. You can make changes to certain Personal Information that Meticulon holds about you, such as your contact information, by editing the information in your account. You are responsible for keeping the Personal Information in your account up to date and accurate.
In appropriate circumstances, your Account Host will amend Personal Information on the Meticulion Platform. It is your responsibility to provide any updates to your Personal Information to your Account Host in writing, as applicable.
You may request access to your Personal Information and/or correction of that information by contacting your Account Host or, if necessary, by contacting Meticulon in writing at the contact information noted below, with sufficient detail to enable Meticulon to identify the Personal Information being sought. When you contact Meticulon, we may ask for further information to confirm your identity and the nature of the information being sought.
After we receive your request for access to Personal Information, Meticulon may provide you with an estimate of when you can expect a response. In some cases, Meticulon may need additional time to respond to a request, in which case we will provide you with written notice of the extension.
Please note that in some cases, Meticulon may not provide access to Personal Information that we hold about you, such as where the denial of access is authorized by law. There are also cases where Meticulon may be legally required to refuse access to Personal Information. If Meticulon denies your request for access to Personal Information, we will advise you of the reason for the refusal, and will provide the name, title, and contact information of the designated person who can address the refusal.
Meticulon may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information, or to provide it in a requested alternative format. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.
Questions and Concerns
Questions or concerns about your personal health information should be directed to the Account Host who established your Meticulon account.
Questions or concerns regarding this Policy, including the collection of your Personal Information, can be directed to the Meticulon Privacy Officer, who is responsible for ensuring Meticulon’s compliance with this Policy. You can contact the Privacy Officer using any of the following methods:
Mailing Address: 3820 24 Ave NW #300
Calgary, AB
T3B 2X9
Email: privacy@meticulon.com
Meticulon takes any complaint about our privacy practices seriously. Meticulon will investigate all complaints. If Meticulon finds a complaint justified, we will take the necessary steps to resolve it. You will be informed following the investigation regarding any complaint. If you are not satisfied with Meticulon’s response to a complaint, you may have options to exercise various complaint procedures, including with the relevant Privacy Commissioner or regulatory authority.
Changes to the Policy
Meticulon may update this Policy from time to time by posting a new version of the Policy on the Platform. If there are significant changes made to the Policy, we will notify the Account Host who may notify Users in advance through the Platform or by e-mail. Meticulon’s collection, use, disclosure, and retention of your Personal Information will be governed by the version of the Policy in effect at that time. We suggest that you review this Policy periodically.
Last updated: September 11, 2024