SANTHA TECHNOLOGIES INC.
TABLE OF CONTENTS
- Our Privacy Philosophy 4
- Businesses Who Use Santha Technologies Products or Services 4
- Our Policy 4
- Note to Children 4
Please protect Your child’s privacy by instructing them to never provide personal information on this website or any other, or within any software registration process, without Your permission. 4
- Consent 4
- How We Obtain Your Consent 5
- Types of Information Collected 5
- Why We Collect Your Information 6
- How We Collect and Use Your Information 7
- Santha Health Chek® Application and Online Accounts 7
- In-Store and Online Purchases 7
- Refunds and Exchanges 8
- Purchase Follow-Up, Surveys, and Customer Research 8
- Customer Reviews 8
- Newsletters or Updates 8
- Participate in a Contest or Promotion 8
- Subscription Services and Activations 8
- Call Centres 9
- Collected automatically 9
- Social Media 10
- Who We Share Your Information With 10
- Retention and Accuracy 11
- Retention 11
- Keeping Your information accurate 11
- Protecting Your Personal Information 12
- Safeguarding Your information 12
- Opting out 12
- Governing Law 13
- Personal Information Outside of Canada 13
- Accessing Your Personal Information and Addressing Your Inquiries and Concerns 13
1. Our Privacy Philosophy
- Businesses Who Use Santha Technologies Products or Services
A significant part of Santa Technologies’ business is to provide products and services to other businesses to be used by such businesses for helping to ensure the health and safety of that business’s employees and visitors. It is up to the businesses using Santha Technologies products and services to determine how they use Santha Technologies’ products or services in their specific business and environment. As such, the majority of the information we collect and the purposes for the collection are at the request of, determined by, and are on behalf of the businesses which have retained our services.
- Our Policy
In this Policy “we” or “us” refers to Santha Technologies Inc. and our affiliates (collectively referred to as “Santha Technologies”). “You” refers to anyone who visits our websites, our clients, Your employees, and anyone who engages with our services.
- Note to Children
Please protect Your child’s privacy by instructing them to never provide personal information on this website or any other, or within any software registration process, without Your permission.
By providing personal information to Santha Technologies, using our Santha Health Chek® Application, using our websites or engaging with our social media, You are consenting to our use, collection and disclosure of Your personal information in accordance with the terms of the Policy. Providing personal information or authorizing a third party to disclose personal information to us signifies Your consent to Santha Technologies’ collection, use and disclosure of personal information in accordance with this Policy.
You have the right to withdraw Your consent from us collecting and using Your personal information, but of course, a withdrawal of consent does not change the information handling practices that have already occurred. If an individual refuses to consent or withdraws his or her consent where such consent relates to the provision of requested products or services, Santha Technologies may not be able to provide the individual, or continue to provide the individual, with such products, services or information.
Subject to legal and contractual requirements, You may refuse or withdraw Your consent to certain of the identified purposes at any time by contacting Santha Technologies Inc.’s Chief Privacy Officer at the contact information set out below.
- How We Obtain Your Consent
Sometimes You will be asked to give Your consent expressly (such as by checking a box or clicking on a web page). Other times we may obtain Your consent implicitly by asking You to provide information with stated purposes and the collection, use and disclosure of such personal information is reasonably necessary to achieve that purpose. In those cases, Your consent will be implied if You provide us with the requested information.
- Types of Information Collected
The type of information that may be collected reasonably relates to the reason personal information has been collected and/or the reason for using Santha Technologies’ products or services. For example, when using the Santha Health Chek® Application, whether as an employee of a business or a visitor of a business, certain limited health information may be collected, as well information relating to the location(s) You visited or worked within the business, as well as certain other information considered important to protect the health and safety of the business’s employees and visitors will be obtained. Personal information collected includes, but is not limited to:
- Limited health information: this includes Your self-report of Your COVID-19 test, travel, contact, and symptom history when using the Santha Health Chek® Application or related services. As well, certain other services offered by Santha Technologies offered to its client involve the collection of vaccination records, health test results and general physical and mental health records on employees and contractors;
- Contact information: including Your name, mailing address, email address, telephone number, and in some circumstances, additional contact information to secure an account, or additional contact information to participate in a survey in relation to a program or project;
- Employment Information: including days worked, time of day You work, area(s) in which You work when using the Santha Health Chek® Application or related services;
- Personal Protective Equipment: If personal protective equipment has been assigned to You, the nature and quantum of such personal protective equipment when using the Santha Health Chek® Application or related services;
- Payment information: including Your credit or debit card details, bank account information, and payment or other information required when You make a purchase;
- Computer and phone information: this includes information like device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, and frequency of use; and
- Other information You voluntarily provide to us, our employees, or our contractors.
- Why We Collect Your Information
We collect and use personal information for reasons that are reasonably related to why You are engaging with Santha Technologies, either directly or as a result of your relationship with a business that is using Santha Technologies’ products or services. Santha Technologies is often a service provider to businesses and as such the information we collect and the purposes for the collection are at the request of, determined by, and are on behalf of the businesses which have retained our services. For example, Santha Technologies may collect personal information for the following reasons:
- Risk Assessment: When using the Santha Health Chek® Application or related services, information is collected to determine risks to exposure of Covid 19 and other health and safety concerns, and whether attending on certain workplace premises in person poses a safety issue to the employees, guests and visitors at that location;
- Contact Tracing: When using the Santha Health Chek® Application or related services, information is collected to be able to contact You if we believe You may be at risk of exposure to Covid 19 or other health and safety concerns as a result of attending at a business’s premises;
- Employee and Contractor Wellness Programs: Some of the services offered by Santha Technologies to its clients involves assisting those clients in improving the overall general physical and mental health and wellbeing of Santha Technologies’ employees and contractors.
- Providing Services and Product Management: Maintaining and improving our products and services, fulfilling agreements, maintaining commercial relationships, developing and enhancing products and services, and otherwise running and managing our business in the ordinary course, including personnel and employment matters;
- Client and Vendor Communication: Newsletters or other communications to which You have subscribed or may be interested;
- Regulatory Requirements: Complying generally with privacy laws and all other applicable regulatory requirements;
- Education and Market Research: We use data to understand demographics, interests, usage patterns, and other characteristics of customers and to track and analyze trends and patterns and to understand and respond to the needs and preferences of, and to communicate with, customers, potential customers and website visitors;
- Sponsorships, Promotions and Scholarships: If an individual indicates that they are interested in receiving offers or information from our selected sponsors and advertisers, we may send them information, products or services that we feel may be of interest, which may include information regarding promotions, contact information, announcing and promoting winners and the review and promotion of scholarship applicants and recipients;
- Marketing and Advertising: Administering surveys, contests, draws, and raffles, offering tailored content, and promotional materials;
- Customer Support: Assisting You when You contact our customer support services, including to direct Your questions to appropriate individuals, investigate and address any of Your concerns, and to improve and monitor our customer support responses;
- Audit and Protection from Illegal Activity: To assess, audit, evaluate, measure and verify data and information, including to protect ourselves and other third parties against error, fraud, theft and other illegal activity;
- Integrity of Database: To develop, manage, update and verify our databases and information provided by third parties;
- Protection of Rights: To protect the rights and interests of Santha Technologies, its employees, customers and third-party service providers and partners;
- Consent: For any other purpose to which You consent; and
- Lawful Authority: As otherwise permitted or required by law.
- How We Collect and Use Your Information
Personal information may be collected in a number of ways, including: through our Santha Health Chek® Application, in person, by mail, by fax, through our websites, by email, through our applications or other software, and from third parties whom You have authorized to disclose personal information to us. Again, it’s important to remember that Santha Technologies is often a service provider to other businesses. In that role, we collect information through the businesses using our products and services with its employees and visitors. For example, when a business uses the Santha Health Chek® Application, we collect information from the business and from the business’s employees, guests and visitors.
If You provide information about a third party or authorize a third party to do so, we will assume You have taken proper measures to obtain informed consent.
- Santha Health Chek® Application and Online Accounts
When You engage with Santha Health Chek®, You will be asked to provide answers to questions relating to Your potential exposure to health and safety risks (including for example, exposure to Covid 19). Santha Technologies’ clients may also request vaccination records and test results of employees and contractors and if so, those will be loaded to Santha Technologies’ systems. We use this information to determine health and safety risks to the business’s employees, guests, visitors and customers, and to contact those who may be exposed to a health or safety risk while attending at the business in question’s premises.
To engage in certain special features or functions of our websites, or to order products and services from our websites, You may be asked to provide certain personal information, such as Your name, email address, postal address, telephone number, or payment card information. We use this information to create Your account, process Your payment, contact and correspond with You about Santha Technologies’ services, respond to Your inquiries, and monitor functions of our websites that You choose to use, such as Customer Reviews. If You purchase an e-gift card, we collect the recipient’s name, email address and any message You provide in order to send the gift card on Your behalf. We rely on You to ensure that You have obtained all necessary consents to provide this information to us.
- In-Store and Online Purchases
When You purchase a product or service from Santha Technologies or a website, You may need to provide us with contact and payment information (such as credit card information) so that we can process Your request or complete Your transaction and communicate with You regarding Your purchase. We may also need to collect contact information to provide certain services, including delivery services, reserve and pick-up, product servicing, and in-home consultations or installations. We may also use Your contact information to send You promotional information. You can opt-out by following the instructions under “Unsubscribe” below.
- Refunds and Exchanges
Our goal is to ensure that You are completely satisfied with Your purchase and to this end, Santha Technologies offers a Refund Policy. For Santha Technologies to continue to offer our Refund Policy, we ask for personal information such as Your name, address, and telephone number for the purposes of detecting and preventing fraud. You may also be asked to produce photo ID for verification purposes only.
- Purchase Follow-Up, Surveys, and Customer Research
Following a purchase, we may send You a follow-up letter to thank You for Your business, or we may contact You to ensure that You are completely satisfied with our services, or the delivery, setup, or installation of Your new product. We may use contact information collected in-store, online, or via our call centres to conduct occasional surveys and other customer research. These surveys are entirely voluntary and You may easily decline to participate. The information obtained through our surveys and customer research is used to help us understand our customers, to enhance our product and service offerings, promotions and events, and/or to assist in the selection of store locations. In limited circumstances we may collect information from credit bureaus only to the extent that credit is being extended to an individual.
- Customer Reviews
The Customer Review functionality is provided as a rating system that offers You the chance to share Your thoughts on a product. These reviews are accessible to all website visitors, so please use discretion when posting information to them and do not post personal information.
- Newsletters or Updates
Santha Technologies offers a variety of newsletters and promotional communications. If You sign-up or are subscribed for our newsletter or other promotional communications, we will send You communications that may be tailored based on Your interests, preferences and behaviour. You may choose to stop receiving these communications at any time. Each marketing or promotional message we send to You will include a link or other method to quickly and easily unsubscribe and decline further similar messages. You may also use the unsubscribe link included below under the heading “Unsubscribe”. Please note that even if You unsubscribe from receiving our promotional communications, You may continue to receive certain transactional or account-related communications from us. Our subscriber list is not sold or rented to other parties.
- Participate in a Contest or Promotion
- Subscription Services and Activations
Santha Technologies may offer activation of certain products and services like education plans, Internet services or support services. These activations may require that certain contact and financial information be collected and provided by Santha Technologies to the respective service providers as part of the activation process. For example, a cellular carrier may need to perform a credit check prior to activation so certain identification such as a government-issued ID number and Your credit card number may be provided to the carrier for that purpose.
- Call Centres
Santha Technologies operates customer support call centres to accept and address Your questions, concerns, or complaints. When You contact our call centres, we may ask for personal information to help us respond to Your inquiry or to verify Your identity. For example, if You have a question about the status of a recent online order, we will ask for personal information to verify that You are the account holder. We may also monitor or record Your telephone discussions with our customer support representatives for training purposes and to ensure service quality. If You do not want Your call to be monitored and recorded, please let us know and we will provide You with an alternative means of communicating with us.
- Collected automatically
In some cases, we automatically collect certain information.
- Our Websites
Our websites can be browsed without You providing us with any personal information. However, when using our websites, we may collect the Internet Protocol (IP) address of Your computer, the IP address of Your Internet Service Provider, the date and time You access our websites, the Internet address of the website from which You linked directly to our websites, the operating system You are using, the sections of the website You visit, the website pages read and images viewed, and the content You download from the website. This information is used for website and system administration purposes, to understand website activity and to improve the websites. Santha Technologies May use a user’s IP address to facilitate the diagnosis and remedy of a technical problem reported by the user’s or Santha Technologies’ technical team, display (or allow the display by third-party advertising providers of) more appropriate and relevant content and advertising, such as content and advertising based on the user’s geographic area; and estimate user traffic from specific countries or organizations. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.
- Cookies, Tracer Tags and Web Beacons
- Website Tracking Information
- Interest-Based Advertising and Opting Out of Same
To learn more and to opt-out of having Your information used by participating companies for online behavioural advertising purposes, please visit http://Youradchoices.ca/choices. Please note that if You choose to opt-out You must opt-out on each Web browser on each computer, mobile device and tablet You use. If You opt-out of receiving interest-based ads, You will continue to receive advertising, but it will not be based on online behavioural information about You. We may also use services provided by third-party platforms, including social networking platforms, to serve You tailored ads. We do this by providing a hashed version of Your email address or other information to the platform provider. To opt-out of this type of tailored advertising, please contact us as set out below under the heading “Unsubscribe”.
- Social Media
We may offer You the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When You engage with our content on or through third-party social networking websites, plug-ins and applications, You may allow us to have access to certain information associated with Your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When You provide information from Your social media account, we may use this information to personalize Your experience on the website and on the third-party social networking websites, plug-ins and applications, and to provide You with other products or services You may request.
- Who We Share Your Information With
- Relevant Businesses: The information obtained through our Santha Health Chek® Application will be shared with the businesses who have licensed the Santha Health Chek® Application and which are relevant to the information obtained. For example, if You are an employee of one of our Customers who uses Santha Health Chek® Application, Your information would be shared with Your employer (not other customers). Similarly, if You were a guest or visitor of one of our customers, the information obtained through Santha Health Chek® Application would be shared with the customer You were a guest or visitor of (and not other customers).
- Government Authorities: If the information provided using the Santha Health Chek® Application may impact the health and safety of others, Santha Technologies may disclose the information to appropriate government and health ministries including Ontario Ministry of Labour and the Ontario Ministry of Health for the purposes of tracking, assisting and ensuring the health and safety of others. Such information may be subject to the Freedom of Information and Protection of Privacy Act (Ontario) while in the possession or control of such government and health ministries.
- Administrative and Technical Support: Cloud storage providers, data analytics providers, hosting services, accounting services, order fulfillment, and data processing.
- Service Providers: Santha Technologies may share Your information with its third-party service providers to assist in managing, reviewing, and administering the Santha Health Chek® and related services. Santha Technologies will require its recipient service providers to use such information only for the purposes identified above and in accordance with this Policy.
- Payment Providers: We do not store Your payment information for online purchases with debit/credit cards. This is shared directly with our third-party payment provider.
- Parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets: In the event that the transaction does not go through, we require by contract that other parties do not use or disclose personal information in any manner whatsoever, for any purpose, and return or destroy same.
- When Legally Required or Permitted: We may also disclose personal information in situations where we are legally required or permitted to do so. These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk.
We may share aggregated and anonymized information (information that cannot identify an individual directly or through reasonably available means) with third-party market research companies.
If You believe that a third party has inappropriately disclosed Your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to Your inquiries, please let us know immediately.
- Retention and Accuracy
We will store Your information only for as long as reasonably necessary to fulfill the purpose for which it was collected or to protect the legal interests of Santha Technologies, our customers or other third parties, and as otherwise legally permitted or required. Once Your information is no longer needed, we will securely and effectively dispose of it.
- Keeping Your information accurate
We make reasonable efforts to keep Your personal information as accurate, complete and up-to-date as necessary. You should verify the accuracy and completeness of Your personal information in our records. You may also request access to Your personal information in our records.
Despite our efforts, errors sometimes do occur. Should You identify any incorrect or out-of-date information in Your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
- Protecting Your Personal Information
We have policies in place to restrict access to private, sensitive and confidential information, including Your personal information, to authorized employees or contractors with legitimate business reasons to have such access.
Our employees and contractors understand the importance of keeping Your information private. All employees and contractors are expected to maintain the confidentiality of personal information.
- Safeguarding Your information
To ensure that Your personal information is protected, we utilize security safeguards that are on par with the industry standard. We keep electronic customer files in a secured environment with restricted access and use.
To help protect the confidentiality of Your personal information, we use administrative, physical and technological safeguards appropriate to the sensitivity of Your personal information to protect against unauthorized disclosure, use, alteration and destruction of the personal information in our possession. We operate secure data networks protected by industry standard firewall and password protection systems. We require all of our Service Providers and agents who collect or process personal information on our behalf to provide security safeguards equivalent to those maintained by us.
Your personal information is stored in secured locations, on servers controlled by us or our Service Providers, and located in Canada.
- Opting out
As noted above, subject to certain limitations at law and contract, You may withdraw Your consent for our use and collection of Your personal information at any time, however this may limit the services and products we can provide. As well, You cannot opt out of information sharing that has already occurred.
You can opt out of email subscriptions by clicking the “unsubscribe” button.
Santha Technologies strives to evolve to meet our customer’s needs and expectations and that means our products and services, and how we offer our products and services, may change. With that in mind, we review our privacy practices from time to time, and our information handling practices may change.
If Santha Technologies makes a material change to this Policy, we will post a notice on our websites and highlight the changes. We may also notify You by email or other electronic means. Material changes to this Policy will be binding thirty (30) days after such changes have been introduced and for which notification of such material changes has been made. You may determine when this Policy was last updated by referring to the date found at the bottom of this Policy. If at any point You do not agree with the terms of this Policy, You must not use Santha Technologies’ services.
Our websites and any of our applications available from our websites or third-party platforms are governed by the provisions and practices stated in this Policy. Our websites and such applications may contain links to third-party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to Your privacy, please be aware that this Policy will no longer apply once You leave our websites or such applications, and that we are not responsible for the privacy practices of third-party sites or applications. We therefore suggest that You closely examine the respective privacy policies of third-party sites and applications to learn how they collect, use and disclose Your personal information.
- Governing Law
This Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.
- Personal Information Outside of Canada
- Accessing Your Personal Information and Addressing Your Inquiries and Concerns
We will, upon written request, provide You access to Your personal information and an opportunity to request that we update or correct Your personal information subject to certain limitations at law. Upon written request, You may review any of the information that we have on file about You and You may also learn how we have used it and to whom we have disclosed it. This right is subject to certain exemptions under law such as when the information is subject to legal privilege. If access to Your personal information is denied, we will notify You in writing, give reasons for the denial, and inform You of the recourses open to You.
Access requests should be sent to our Chief Privacy Officer using the contact information below.
We are happy to provide You with a copy of this Policy and to discuss any of its content with You.
Please direct all questions or enquiries about this Policy to:
Privacy Officer Mayuran Srikantha Santha Technologies
C/O Aaron Bains – 181 Bay Street-Suite 1800, Toronto, ON, M5J 2T9
If You have any questions or concerns about our privacy practices or Your personal information that remain unresolved after contacting our Chief Privacy Officer, You may contact Canada’s Information and Privacy Commissioner at:
Information and Privacy Commissioner of Canada
30, Victoria Street
Last revised Friday, June 12, 2020
Have Questions ?
Get in touch with our client success team and we will be happy to answer them.