Last updated: Feb 09, 2023
INTRODUCTION AND SCOPE
Innovana is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing.
Innovana shall implement policies and practices to give effect to these principles, including:
HOW DO WE COLLECT INFORMATION ABOUT YOU?
We collect information from you when you voluntarily provide it to us by using our Site or Services. For example, we may ask you to provide Personal Information if you:
WHAT INFORMATION DO WE COLLECT FROM AND ABOUT YOU?
Personal Information that Innovana collects includes, but is not limited to:
We also collect the following information about you, including:
HOW DO WE USE PERSONAL INFORMATION?
We use Personal Information that we collect from for following purposes:
HOW DOES INNOVANA COLLECT, USE AND SHARE NPI?
Innovana uses NPI in an ongoing effort to better understand and serve our customers and to improve the content and functionality of our Site.
No NPI by itself, or together with aggregated Personal Information, can be tracked to a specific individual’s Personal Information.
Innovana respects your privacy and, unless otherwise required by law, Innovana will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. In certain circumstances, your consent may be implied by your actions. For example, providing Innovana Personal Information to register for our services is implied consent to use such information to provide you with the associated services.
The form of consent sought by Innovana may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Innovana shall take into account the sensitivity of the Personal Information and the reasonable expectations of Innovana’s Users. Innovana will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, you must provide notice to Innovana in writing. See “Inquiries; Challenging Compliance” section below.
DO WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?
We may share your Personal Information with our service providers that help us with our business operations. For example, we may transfer information with service providers who provide us with marketing and promotional services. We require our service providers to keep your Personal Information secure. In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.
We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.
Subject to the foregoing, only Innovana’s employees, agents, contractors, service providers (and their employees and contractors) with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about you. All such employees and contractors will be required as a condition of employment to contractually respect the confidentiality of Innovana’s Users’ Personal Information.
Innovana will disclose Personal Information without your knowledge or consent if Innovana receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your Personal Information. If Innovana receives a written request from a police officer or other law enforcement agency with authority to request access to your Personal Information in the course of an actual or potential investigation into a breach of a law, Innovana’s policy is to provide the requested information.
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
Innovana will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made anonymous according to the guidelines and procedures established by Innovana.
COOKIES & OPT-OUT
You may disable cookies using your browser’s settings. Please consult your browser’s help function for information on how to disable cookies. Note that if you disable cookies, certain features of Innovana’s Site may not function to its fullest potential.
You may opt-out of Google Analytics by clicking here: tools.google.com/dlpage/gaoptout?hl=en=
HOW CAN I ACCESS MY PERSONAL INFORMATION
Upon request, Innovana will provide you information regarding the existence, use and disclosure of your Personal Information and you will be given access to that information. Innovana will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, Innovana may not be able to provide access to all of your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Innovana will provide the reasons for denying access upon request.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Innovana protects your Personal Information by security safeguards appropriate to the sensitivity of the information. Innovana will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. This includes limiting access of employees to, and the use of, your Personal Information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require any third-party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit Personal Information to us using our website if you consider that information to be sensitive.
Innovana complies with Canada’s anti-spam legislation (CASL), and we will not send you electronic communications in contravention of this law.
We will ensure that each email includes an opt-out feature and instructions on how to unsubscribe if you no longer wish to receive future emails from us. You can unsubscribe using the link included in the email or electronic message, or by using the contact information set forth below. If we do not have consent, express or implied, to send you commercial electronic messages, we will only communicate with you for the limited purposes permitted under CASL.
To unsubscribe from our email communications or any other questions you may have about our electronic communications practices please contact our Privacy Officer as set out below.
INQUIRIES; CHALLENGING COMPLIANCE
The Privacy Officer will respond to all such inquiries or complaints within fourteen (14) business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Innovana finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact Innovana’s Privacy Office as follows:
Innovana Solutions Inc.
88 Queens Quay West, Suite 2500
Toronto, Ontario M5J 0B8 Canada
STORAGE OUTSIDE OF CANADA
Your Personal Information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your Personal Information. However, if your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
CHILDREN AND MINORS
The Site is not directed to children under the age of 18 years. Innovana will not knowingly collect Personal Information about a child under the age of 18. Innovana does not allow minors (persons who are under the age of majority in their place of residence) to use the services provided on the Site.