Gentroo Privacy Policy
Updated: April 2, 2020
Gentroo (“us”, “we”, or “our”) operates the gentroo.com site, Gentroo Care web portal, and Gentroo Care mobile application (collectively, the “Service”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service. We will not use or share your information with anyone except as described in this Privacy Policy. We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at gentroo.com.
Information Collection
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you, and for Gentroo to collect information on your behalf. Personally identifiable information may include, but is not limited to, your name, email, phone number, device identifiers, movement data, and certain other personal data including medical data (“Personal Information”). Gentroo does not claim ownership of the Personal Information provided to it in the use of the Service. Personal Information is collected via the intake forms all users complete on our web and mobile applications, device APIs, and any medical data the user authorizes Gentroo to request and retrieve from health institutions.
Personal information we collect is used to:
- Provide the Service
- Monitor, analyze and improve the Service
- Communicate with you or health institutions on your behalf
- Gather anonymized statistical data, including movement data
- Disclose to third party vendors, service providers or agents who perform functions on our behalf
Individual level data collected by Gentroo is never shared with anyone without the individual’s explicit consent. Any statistical or aggregate data gathered or shared is anonymized such that it cannot be traced back to an individual record.
Applicable Legislation
The Service complies with the federal Personal Information Protection and Electronic Documents Act (PIPEDA), except where substantially similar legislation exists at the provincial level. Substantially similar legislation exists in Alberta, British Columbia, and Québec. In all other provinces and territories PIPEDA applies.
The following legislation applies to the services and operations of Gentroo in Canada:
- Personal Information Protection and Electronic Documents Act (PIPEDA)
- Personal Health Information Protection Act (PHIPA) (Ontario)
- Personal Information Protection Act (PIPA) (Alberta)
- Personal Information Protection Act (PIPA) (British Columbia)
- Act Respecting the Protection of Personal Information in the Private Sector (ARPPIPS) (Quebec)
Gentroo is defined as an “organization” under PIPEDA, PIPA (Alberta) and PIPA (BC) and as a “person” under the Quebec Act, and is subject to, and compliant with, all of the obligations defined under those roles.
Consent
The Service relies on explicit user consent to collect identifiable information on behalf of the user. This is done by collecting personal information, legal authorization, and identity verification and matching it with the applicable information on source databases. Users have the ability to revoke consent at any time by emailing us (inquiry@gentroo.com).
Wearable Device Data
The data we collect from Wearable Devices (“Wearable Device Data”) depends on the type of Wearable Device chosen, but may include GPS location, movement data, heart rate, body temperature, weight, and other information. We collect both non-identifiable and identifiable information from Wearable Devices. We will only collect identifiable data with the consent of individuals. Consent may be collected by health institutions as part of their provision of services using Gentroo.
Wearable Device Data is used by us to:
- provide the Service within health institutions;
- analyze and improve the Service; and
- create or update health institution information such as Incident Reports or health records; and
- provide reporting to health institutions and, where applicable, government agencies, consistent with legislation.
App Data
We collect data from the Gentroo app (“App Data”) includes GPS location, movement data, picture and video from smartphone cameras, and text and chat logs.
App Data is used by us to:
- provide the Service within health institutions;
- analyze and improve the Service; and
- create or update health institution information such as Incident Reports or health records; and
- provide reporting to health institutions and, where applicable, government agencies, consistent with legislation.
Web Log Data
We collect information that your browser sends whenever you visit or use our Service (“Web Log Data”). This Web Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
Web Log Data is used by us to:
- Track and understand page viewing habits in an effort to improve our communications and services
Data Retention
Gentroo will retain Personal Information in its primary database until such a time as the user to whom it pertains ceases to be a Gentroo user, or until they request the data be deleted. Backups of the data will persist for one to seven days following deletion.
Cookies
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Service Providers
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Security
The security of your Personal Information is important to us. Gentroo employs privacy and security measures to guard against identity theft and provide security for your Personal Information. These include, but are not limited to, encrypting data during transfer and storage, maintaining access logs to ensure access is only restricted to relevant parties, and decentralizing our database to protect your information in the unlikely event of a breach.
We regularly re-evaluate our privacy and security policies and adapt them as necessary. However, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Links To Other Sites
Our Service may contain links to other sites (such as health service provider websites) that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes To This Privacy Policy
If we make changes to our Privacy Policy, we will use the email address on file to notify you. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please email us (inquiry@gentroo.com).