Talking Stick Privacy Notice

Last updated: March 2024

1. Purpose of this privacy notice

This Privacy Notice pertains to the collection, use and disclosure of your Personal Information, as defined below, in the custody and control of TryCycle Data Systems Inc. (“TryCycle”/“we”/“us”/“our”) in connection with your use of the Talking Stick mobile application (“Talking Stick”, “App”, or “Web App”).

Talking Stick is an anonymous peer support platform for Indigenous Canadians and as such, we have designed the App to avoid any collection of Personal Information about our users and you don’t have to set up an account to use the App. While we always make efforts to avoid identifying a specific user and we automatically delete chat history, this Privacy Notice applies in the rare cases in which we may collect information that qualifies as Personal Information (such as information about your device), as discussed below.

Talking Stick also offers an emergency response and support system. By signing up to the First Alerts service from the Talking Stick App, you will receive notifications on your phone, but we will never ask you to share your phone number, email address, or identity.

By using the Talking Stick App, you consent to the collection, use and disclosure of your Personal Information in accordance with this notice. We strongly recommend that you read this notice carefully and retain it for future reference. This notice may change from time to time (see Section 6 “Changes to this Privacy Notice” below) so please check this notice periodically for updates. Your continued use of our App after we make changes to this notice indicates that you accept and consent to those changes. We will notify you in advance of any material changes to this notice and obtain your consent to any new ways that we collect, use and disclose your Personal Information.

The application of this notice is subject to applicable laws, including legislation, regulations and the orders or lawful requests of any courts or legal authorities.

2. Information we collect about you, how we collect it and how we use it

For the purposes of this notice, “Personal Information” includes any information about an identifiable individual, or an individual whose identity may be inferred or determined from such information, that can be used on its own or with other information to identify a single person, but does not include names, titles or other information that is publicly available, such as business contact information or information found in a telephone directory.

We will only collect information that may qualify as Personal Information in the following circumstances:

Technical information about your device. We collect technical information about your device, including information about your device type, device identifier, operating system, language, duration of use, number of notification messages sent or received, and times and dates at which our App was accessed and utilized. While we make efforts not to associate device information with any identifiable user, such information may in certain cases qualify as Personal Information under applicable privacy laws.

We use technical information about your device for the following purposes:

  • To provide our App and deliver our services to our users;
  • To understand how users access and utilize features and services on our App;
  • To troubleshoot, enhance, improve and optimize our products and services;
  • To send essential push notifications required to provide the features and services relevant to the Talking Stick system;
  • To deliver any First Alerts notifications that you have signed up to;
  • Recognize when you return to our App;
  • In case of violation of our rules relating to harassment and abuse, we may also use this information to block a device from accessing our App;
  • To comply with our legal obligations.

Chat history. As disclosed in the App, we reserve the right to save chat history in cases of harassment, abuse, or if personal safety is considered at risk. We may therefore collect any Personal Information you have inputted in the chat. We may use this information to protect the safety or security of individuals and to enforce our Terms and Conditions.

Non-confidential information. Unless otherwise explicitly stated herein or in our Terms & Conditions, any non-personal information or material, including but not limited to any submissions or posts in public areas of a Website or App (“User Submissions”) or suggestions, reviews, comments or feedback sent to TryCycle related to any aspect of a Website or App (“Feedback”), will be deemed not to be confidential.

As you navigate through and interact with our Website and Apps, we may use automated technologies, such as “cookies”, small files placed on your devices, to collect certain information about you, your device, and how you interact with our Website and Apps. You can learn more about how we use cookies by consulting our Cookies Notice.

3. When and to whom we disclose your Personal Information

TryCycle will never sell your Personal Information.

To the extent we collect Personal Information, we will only disclose it in exceptional cases, namely:

  • As required or as authorized by law or by order or requirement of a court, administrative agency or other governmental tribunal;
  • As required to enforce or apply our Terms and Conditions and other agreements;
  • Where we believe, upon reasonable grounds, that it is necessary because of an emergency that threatens the life, health or security of an individual; or
  • Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain.

TryCycle uses third-party service providers, such as Microsoft, PostHog and Raygun to host servers in Canada and the United States and to track and prevent errors in our software. These third-party service providers may have access to Personal Information as an incidental result of the services provided by such third parties to TryCycle, but the access of such third parties to such information is strictly controlled by our agreements with these service providers.

4. How we protect your Personal Information

To the extent we collect Personal Information, keeping it safe and secure is very important to us. While we cannot guarantee complete protection of your Personal Information, we follow commercially reasonable practices to protect Personal Information collected from you against accidental loss and unauthorized access, use, alteration, disclosure and destruction.

We store all Personal Information with Microsoft Azure at a data centre in Canada. Microsoft Azure is responsible for the hosting and security of all servers, databases and applications in a secure cloud and are certified as compliant with ISO Standard 27018 Code of Practice for personal identifiable information (PII) protection in public clouds acting as PII processors. In addition to the independent certification process under ISO27018, the ISO Standard also includes the right to audit Microsoft for compliance.

Because the transmission of information via the Internet is not completely secure, any transmission of Personal Information is at your own risk. Although we maintain security measures to maintain the integrity of the data in our care, including the encryption of all Personal Information, while in transit or at rest, we are not responsible for circumvention of any of our privacy settings or security measures. Your Personal Information may be transmitted over various networks and may be subject to changes to confirm and adapt to technical requirements of connected networks or devices.

Access to private, sensitive and confidential information, including your Personal Information, is restricted to authorized TryCycle employees who are required to abide by our privacy standards. Our employees are bound by a confidentiality agreement, which strictly prohibits access to or disclosure of your information without authorization. Our employees are subject to appropriate disciplinary measures, including dismissal, if they fail to abide by our confidentiality agreement or privacy standards.

Our App may contain links or references to other websites and services owned or operated by third parties. These third-party platforms and websites are not governed by this notice. This notice does not extend to the collection of information by third parties, and we are not responsible for the privacy practices, policies or actions of third parties. When visiting third party websites or platforms, you do so at your own risk, and you assume all responsibility associated with the same. We encourage you to review the privacy policies and terms and conditions of each website and platform visited prior to using them or disclosing information to third parties.

5. Retention of your Personal Information

To the extent we collect Personal Information, we will only retain it for as long as is necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements or to protect us from liability in the event of a dispute.

All text messages sent through Talking Stick will be automatically deleted upon the termination of the chat session during which said text messages were sent, except where we need to retain the chat in cases where personal safety is considered at risk.

6. Changes to this Privacy Notice

We reserve the right to modify this notice at any time. The notice posted on our App shall be deemed to be the notice in effect. A current notice can also be obtained by contacting us. If we make any material changes to this notice regarding how we treat your Personal Information, we will notify you through a notice on our App and will obtain your express consent as required under applicable privacy laws. We also include the date this notice was last revised at the top of the notice.

7. Governing law

This notice shall, in all respects, be governed by and interpreted, construed and enforced in accordance with applicable provincial and federal laws of Canada.

For users in First Nations Communities, TryCycle works with community leaders to ensure compliance with the First Nations Principles of ownership, control, access and possession (OCAP) of First Nations data.

8. Correcting or updating information and withdrawing consent

You have the right to request access to and to correct any Personal Information we hold about you. You may contact us if you would like to review, verify, correct or withdraw consent to the use of your Personal Information. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.

We may not accommodate a request to view or change information if we believe that:

  • The identity of the person requesting access cannot be confirmed;
  • The information is not readily retrievable, and the burden or cost of providing it would be disproportionate to the nature or value of the information;
  • The requested information does not exist, is not held or cannot be found;
  • Disclosure of the information would compromise the confidentiality of another individual or threaten the safety of another person; and/or
  • Non-disclosure of the information is required or permitted by law.

Where a request for access to information is made, to protect vulnerable populations, TryCycle reserves the right to verify communications before taking action. Where a request for access or alteration of Personal Information is declined, the individual making the request will be provided with the reason(s) for declining the request, subject to any legal or regulatory restrictions.

9. Contacting us

TryCycle has appointed a designated privacy contact who acts as Chief Privacy Officer (“CPO”) responsible for information system monitoring and information security notice and procedure management by:

  • Undertaking privacy impact assessment and threat and risk assessments on a regular basis; and
  • Adopting policies and procedures based on privacy impact assessment and threat and risk assessments to mitigate all identified risks, updated as necessary.

If you have questions about this notice or would like to submit a request or complaint, you may contact our CPO, Geoff Schaadt, by e-mail at privacy@nulltrycycle.ca or by regular mail using the details provided below:

Canada
TryCycle Data Systems Inc
1525 Carling Ave
Suite 408
Ottawa, ON K1Z 8R9


 

 

TetherAll Privacy Notice

Last updated: March 2024

1. Purpose of this privacy notice

This privacy notice pertains to the collection, use and disclosure of your (“you”/ “Clients”/ “Patients”/ “Users”) Personal Information and Personal Health Information, as defined below, in the custody and control of TryCycle Data Systems Inc. (“TryCycle”/ “we”/“us”/“our”).

By consenting to your health care provider’s use of our websites, located at https://trycycle.ca and at https://my.tetherall.io (“Website”), located at the URL provided to you by TryCycle, if applicable, and any of our web applications or mobile applications (“Apps”), including the TetherAll App (previously known as the TryCycle App), you consent to the collection, use and disclosure of your Personal Information and your Personal Health Information in accordance with this notice.

We strongly recommend that you read this notice carefully and retain it for future reference. This notice may change from time to time (see Section 8 “Changes to this privacy notice” below) so please check this notice periodically for updates. Your continued use of our Website, Apps, and/or any of our services, after we make changes to this notice, indicates that you accept and consent to those changes. We will notify you in advance of any material changes to this notice and obtain your consent before we collect, use, or disclose your Personal Information or Personal Health Information.

The application of this notice is subject to applicable laws, including legislation, regulations and the orders or lawful requests of any courts or legal authorities.

Please note that your healthcare provider acts as the health information custodian of your records and has the overall responsibility for protecting your Personal Information and Personal Health Information, including your records stored with us. Please contact your health information custodian for more information on how it collects, uses, and discloses your Personal Information and Personal Health Information.

We primarily act as an agent of your health information custodian. As an agent, we collect, use, and disclose Personal Information and Personal Health Information on your health information custodian’s behalf to assist them in delivering health care to you, to deliver our Website and Apps to you and the health information custodian, and for the purposes described in this notice. Please note that we may collect and use certain Personal Information and Personal Health Information in a limited way for our own purposes, including for analytics purposes and to improve our services. These purposes are described in this notice.

In certain circumstances, we may be acting as a Business Associate, as that term is defined by the United States’ Health Insurance Portability and Accountability Act’s Privacy and Security Rules at 45 C.F.R. Parts 160-164 (“HIPAA”), of your health care provider. When we are acting as a Business Associate, this Privacy Notice does not apply to our use and disclosure of your information that constitutes Protected Health Information, as that term is defined by HIPAA. Instead, the terms of your health care provider’s HIPAA Notice of Privacy Practices will govern our use and disclosure of your Protected Health Information. Please contact your health care provider to view their HIPAA Notice of Privacy Practices for more information about how we will treat your Protected Health Information when we are acting as a Business Associate.

If we need to collect, use, or disclose your Personal Information or Personal Health Information in a way that is not identified or anticipated by this notice, we will notify you and/or obtain your consent as required under applicable privacy laws.

2. Information we collect about you and how we collect it

Personal Information

For the purposes of this notice, “Personal Information” includes any information about an identifiable individual or an individual whose identity may be inferred or determined from such information, that can be used on its own or with other information to identify a single person, but does not include names, titles or other information that is publicly available, such as business contact information or information found in a telephone directory.

Personal Information we collect includes, but is not limited to, your name, contact information (email address, telephone number, or other information we may use to contact you and that you provide to us) race, sex, date of birth, marital status, other information that you may choose to add to your user account profile in any Apps, records, and copies of your correspondence with us and with your health care providers through our Apps.

Personal Health Information

We collect Personal Health Information. For the purposes of this notice, “Personal Health Information” includes identifying information about an individual that relates to:

  • an individual’s physical or mental health or family health history;
  • the provision of health care services to an individual, including the identification of persons providing health care services to an individual;
  • an individual’s health number;
  • any other information about an individual that is included in a record containing Personal Health Information.

Information you input into our App

We collect the information that you actively enter into our Apps, including, but not limited to, real-time behavioral input and free-form text entries (i.e., messages and logs).

Information from your mobile device

When you use our Apps, our system collects your location data from sources such as the Global Positioning System (GPS), Wi-Fi networks, and cell towers. Your location data is only collected with your consent, which may be withdrawn at any time. We may also collect accelerometer samples, Wi-Fi network identifications and other activity data that is personally identifiable. We may also collect information from your device, including but not limited to information about your device type, device identifier, IP address, operating system, browser type, time zone, pre-existing cookies installed on your device, carrier, language, battery performance, network connections, duration of use, number of notification messages sent or received, and times at which our Website and Apps were accessed and utilized. TryCycle collects both individual and aggregate data about a group or category of services or users of our Website or Apps.

In addition, most mobile device operating systems collect and make available to us health and fitness information shared by the user and other mobile health and fitness applications. This information might pertain to your physical activity, mindfulness, sleep patterns, nutrition, heart rate, reproductive health and other data logged in and tracked by your mobile device or other mobile applications.

As you navigate through and interact with our Website and Apps, we may use automated technologies, such as “cookies”, small files placed on your devices, to collect certain information about you, your device, and how you interact with our Website and Apps. You can learn more about how we use cookies by consulting our Cookie Notice at https://trycycle.ca/cookies.

Information provided by your health care providers

Your health care providers may record Personal Information and Personal Health Information in the applicable Apps, such as interactions with you, test results, evaluations, treatment records and notes and other information related to your personal health and/or health care. You understand and agree that your health care providers may also access, use, and/or disclose the Personal Information and Personal Health Information that you upload to the Apps.

Non-confidential information

Unless otherwise explicitly stated herein or in our Terms and Conditions, any non-personal information or material, including but not limited to any submissions or posts in public areas of a Website or App (“User Submissions”) or suggestions, reviews, comments or feedback sent to TryCycle related to any aspect of a Website or App (“Feedback”), will be deemed not to be confidential.

3. How we use your Personal Information and Personal Health Information

We only use your Personal Health Information strictly as is necessary in the course of providing our Website and Apps to you and your health care providers.

We use your Personal Information and Personal Health Information on your health information custodian’s behalf (or your healthcare provider’s behalf, as applicable) to:

  • Deliver the Website and Apps to you and your healthcare providers, and to fulfill the purposes set out in this notice or that were described when the information was collected;
  • Facilitate communications between you and us;
  • Send essential automated SMS, mobile and email notifications relevant to TryCycle system events to the mobile number and email address you provided during registration (note that notification preference settings will be provided to allow you to turn off non-essential/informative notifications only);
  • Facilitate communications and provide a platform on which information and documentation can be shared between you and your health care providers;
  • Store information about your preferences, which allows us to customize our Apps to provide you with a personalized experience;
  • Recognize you when you return to our Apps;
  • Fulfill any other purpose with your consent.

We use your Personal Information and Personal Health Information for our own purposes to:

  • De-identify and/or anonymize your Personal Information and Personal Health Information;
  • Understand how you access and utilize features and services on our Website and in our Apps in order to troubleshoot, enhance, improve and optimize our products and services;
  • Carry out our obligations and enforce our rights arising from any contracts with you or to comply with our legal obligations;
  • Complete transactions with you, where applicable;
  • Screen for potential patterns of misuse and/or fraudulent use of TryCycle’s systems;
  • Estimate our audience size and usage patterns and analyze trends and track movements around our Website and Apps;
  • Fulfill any other purpose with your consent.

The Personal Information and Personal Health Information that we collect may be assigned to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change respecting TryCycle, our Website and/or Apps. In such an event, TryCycle will attempt to notify you before your information is transferred.

TryCycle may also conduct analysis of de-identified or anonymized data, using machine learning techniques or other artificial intelligence, which may include health information to which you have provided us access, as part of application service development to enable better healthcare outcomes and to provide your authorized health care providers with information including, but not limited to: (a) a triaged view of their patient population, based on risk assessments; (b) a current risk assessment of each patient; (c) a view of immediate and historical patient data collected; and (d) patient demographic information. Information that is processed using the identity of individual users will remain anonymous in such analysis.

Should TryCycle conduct market or product research, it will only do so using de-identified or anonymized Personal Information or Personal Health Information.

4. When and to whom we disclose your Personal Information and Personal Health Information

Disclosure of Personal Information and Personal Health Information

TryCycle will never sell your Personal Information or Personal Health Information.

TryCycle may disclose your Personal Information and Personal Health Information:

  • As required or as authorized by law or by order or requirement of a court, administrative agency or other governmental tribunal;
  • To enforce or apply our Terms and Conditions and other agreements;
  • Where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
  • Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
  • Where the information being disclosed or used is publicly available.

Where we are obliged or permitted to disclose your Personal Information or Personal Health Information without your consent, we will not disclose more information than is minimally required in the applicable circumstances.

Please note that any Personal Information or Personal Health Information sent via our Apps (or via text message, facilitated by our Apps) to a third-party will be delivered to such third-party.

Sharing or Disclosure of Personal Information and Personal Health Information by a Health Information Custodian

Your health information custodian may share Personal Information or Personal Health Information stored in our Apps with your other healthcare providers or insurers. Please contact the health information custodian to learn more about how they share your Personal Information and Personal Health Information with others.

Third-Party Service Providers

TryCycle uses third-party service providers, such as Microsoft, Raygun and Mailgun to host servers in Canada and the United States; track and prevent errors in our software; and send, receive and track emails and user login invitations. These third-party service providers may have access to Personal Information and Personal Health Information as an incidental result of the services provided by such third parties to TryCycle, but the access of such third parties to such information is strictly controlled in accordance with the safeguards detailed below.

5. How we protect your Personal Information and Personal Health Information

The safety and security of your Personal Information and Personal Health Information is very important to us. While we cannot guarantee complete protection of your Personal Information or Personal Health Information, we follow commercially reasonable practices to protect Personal Information and Personal Health Information collected from you against accidental loss and unauthorized access, use, alteration, disclosure and destruction.

We store all Personal Information and Personal Health Information with Microsoft Azure at a data centre in Canada for Canadian residents and at a data center in the United States for residents of the United States. Microsoft Azure is responsible for the hosting and security of all servers, databases and applications in a secure cloud and are certified as compliant with ISO Standard 27018 Code of Practice for personal identifiable information (PII) protection in public clouds acting as PII processors. In addition to the independent certification process under ISO27018, the ISO Standard also includes the right to audit Microsoft for compliance.

Because the transmission of information via the Internet is not completely secure, any transmission of Personal Information or Personal Health Information is at your own risk. Although we maintain security measures to maintain the integrity of the data in our care, including the encryption of all Personal Information and Personal Health Information, while in transit or at rest, we are not responsible for circumvention of any of our privacy settings or security measures. Your Personal Information and Health Information may be transmitted over various networks and may be subject to changes to confirm and adapt to technical requirements of connected networks or devices. We urge you to be cautious about giving out information in any public areas of our Website or Apps.

Safeguard measures to ensure authorized access to your account on our Apps include the use of a username and a password for authentication. You are responsible for keeping your personal password and username private. Please contact us immediately if you believe that your password has been compromised or misused.

Access to private, sensitive and confidential information, including your Personal Information and Personal Health Information, is restricted to authorized TryCycle employees who are required to abide by our privacy standards. Our employees are bound by a confidentiality agreement, which strictly prohibits access to or disclosure of your information without authorization. Our employees are subject to appropriate disciplinary measures, including dismissal, if they fail to abide by our confidentiality agreement or privacy standards.

Our Website or Apps may contain links or references to other websites and services owned or operated by third parties. These third-party platforms and websites are not governed by this notice. This notice does not extend to the collection of information by third parties, and we are not responsible for the privacy practices, policies or actions of third parties. When visiting third party websites or platforms, you do so at your own risk, and you assume all responsibility associated with the same. We encourage you to review the privacy policies and terms and conditions of each website and platform visited prior to using them or disclosing information to third parties.

6. Retention of your Personal Information and Personal Health Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information and Personal Health Information for as long as is necessary to fulfill the purposes for which we collected it on behalf of your health information custodian, and for certain other purposes including for the purposes of satisfying any legal, accounting or reporting requirements or to protect us from liability in the event of a dispute.

Unless you explicitly withdraw your consent, we will retain your name and contact information so that we may archive your participation in our services. When you explicitly withdraw your consent to our retention of your Personal Information or Personal Health Information, or if we decide that your Personal Information or Personal Health Information is no longer necessary or relevant for the identified purposes or is not required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated, de-identified or made anonymous.

We reserve the right to use and to publish aggregated, anonymized, and de-identified data that we have collected from you for any legitimate business purpose, including performing analytical procedures to improve, extend and promote our App and services, without further notice to you and without your consent.

We also reserve the right to reject, suspend, alter, remove or delete data if it breaches our Terms and Conditions, if it is necessary to protect ourselves or others, where we have reasonable grounds to believe that a criminal act has been committed, or if required to do so by law.

7. Knowledge and consent

Where required by applicable law, we seek consent to collect, use, and disclose your Personal Information and Personal Health Information on behalf of your health information custodian. In cases where you voluntarily provide us with your Personal Information or Personal Health Information, we will seek consent for the use or disclosure of such Personal Information at the time of collection, when required by applicable law. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).

The form of consent that we seek, including whether it is express or implied, will largely depend on the legal requirements surrounding such consent, as well as the sensitivity of the Personal Information and Personal Health Information and the reasonable expectations of the individual in the circumstances. When you fill out a form on one of our Apps, for instance, you imply that we may use that information for the purpose for which you filled out the form.

You may withdraw consent to the collection, use or disclosure of your Personal Information or Personal Health Information at any time, subject to legal restrictions (such as information required to protect us from liability) and reasonable notice. If you wish to withdraw your consent, please contact us. We will inform you of the implications of withdrawing your consent as appropriate, which may include our inability to offer certain services to your health information or to you.

8. Changes to this privacy notice

We reserve the right to modify this notice at any time. The notice posted on our Website and in our Apps shall be deemed to be the notice in effect. A current notice can also be obtained by contacting us. If we make any material changes to this notice regarding how we treat your Personal Information or Personal Health Information, we will notify you through a notice on our Website and on our Apps, and/or by email to your last known email address and will obtain your express consent as required under applicable privacy laws. We also include the date this notice was last revised at the top of the notice.

You are responsible for ensuring that we have an up-to-date, active and deliverable email address for you and for periodically visiting this notice to check for any changes.

9. Governing law

This notice shall, in all respects, be governed by and interpreted, construed and enforced in accordance with applicable provincial and federal laws of Canada and the applicable laws within the United States.

For users in First Nations Communities, TryCycle works with community leaders to ensure compliance with the First Nations Principles of ownership, control, access and possession (OCAP) of First Nations data.

10. Correcting or updating information and withdrawing consent

It is important that the Personal Information and Personal Health Information we hold about you is accurate and current. The accuracy, integrity and completeness of your Personal Information and Personal Health Information you input into our Apps or allow someone to input into our Apps on your behalf, is your responsibility. Please keep us informed if your information changes.

Please note that there is no mechanism for users of our Apps to edit, alter or delete this information after submitting it to TryCycle. If you would like to correct the information you provided to us via our Apps, please contact us.

By law, you have the right to request access to and to correct the Personal Information and Personal Health Information that we hold about you. You may contact us if you would like to review, verify, correct or withdraw consent to the use of your Personal Information or Personal Health Information. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information or Personal Health Information records.

We may not accommodate a request to view or change information if we believe that:

  • The identity of the person requesting access cannot be confirmed;
  • The information is not readily retrievable, and the burden or cost of providing it would be disproportionate to the nature or value of the information;
  • The requested information does not exist, is not held or cannot be found;
  • Disclosure of the information would compromise the confidentiality of another individual or threaten the safety of another person; and/or
  • Non-disclosure of the information is required or permitted by law.

Where a request for access to information is made, to protect vulnerable populations, TryCycle reserves the right to verify communications, including with your health care providers, before taking action. Where a request for access or alteration of Personal Information is declined, the individual making the request will be provided with the reason(s) for declining the request, subject to any legal or regulatory restrictions.

11. Contacting us

TryCycle has appointed a designated privacy contact who acts as Chief Privacy Officer (“CPO”) responsible for information system monitoring and information security policy and procedure management by:

  • Undertaking privacy impact assessment and threat and risk assessments on a regular basis; and
  • Adopting policies and procedures based on privacy impact assessments and threat and risk assessments to mitigate all identified risks, updated as necessary.

If you have questions about this notice or would like to submit a request or complaint, you may contact our CPO, Geoff Schaadt, by e-mail at privacy@nulltrycycle.ca or by regular mail using the details provided below:

Canada
TryCycle Data Systems Inc.
1525 Carling Ave., Suite 408
Ottawa, ON K1Z 8R9

United States
TryCycle Data Systems Inc.
University of Connecticut
Technology Incubation Program Building
Room R1844
400 Farmington Ave
Farmington, CT 06032