Last revised: August 20, 2021

Privacy Statement

13014967 CANADA INC.  (“Summit Health”, “we”, “us”, “our”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Statement is to inform you about the types of Personal Information we collect, use and disclose. It explains how we collect, use and disclose that information, the choices you have regarding such use and disclosure, and how you may access and correct that information.

From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information (as defined below) in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source. The following topics will be covered in this Privacy Statement:

1. What is Personal Information?
2. How do we collect your Personal Information?
3. Where do we store your Personal Information?
4. How do we use your Personal Information?
5. To whom do we provide your Personal Information?
6. When and how do we obtain your consent?
7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
8. How long will we utilize, disclose or retain your Personal Information?
9. How can you review your Personal Information that we have collected, utilized or disclosed?
10. How do you know that the Personal Information we have on you is accurate?
11. What if the Personal Information we have on you is inaccurate?
12. How fast will we respond to your written requests?
13. Are there any costs to you for requesting information about your Personal Information or our privacy practices?
14. How do we know that it is really you requesting your Personal Information?
15. What safeguards have we implemented to protect your Personal Information?
16. How do you contact us regarding access to your Personal Information or our privacy practices

1. What is Personal Information?
   
   “Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, mailing address, e-mail address, account access token, retail account log-in credentials, location information, information about your usage of Summit Health services and the devices you use to access Summit Health services, or credit card and other financial information. If you provide us with access to your email or retailer accounts (for example, through an account access token or your credentials), Personal Information includes your emails, email header information, your purchase history at retailers, and other information about what you buy and own that is stored in the email or retailer account.
2. How do we collect your Personal Information?

We will collect your Personal Information by fair and lawful means. We may collect Personal Information from you directly, through your use of our products and services, through your use of our website, app, or as otherwise required or permitted by law.

3. Where do we store your Personal Information?

We will keep the Personal Information that we collect at our offices in Canada, or at data centers managed by us or third party service providers in Canada and the United States, as applicable.

4. How do we use your Personal Information?

Generally, we identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):

• to provide you with Summit Health services, including personalized services and to monitor your purchases, receipts, claims, and returns;
• to initiate and facilitate claims on your behalf as your agent, and communicate with you and third parties about your claims;
• to understand how you use Summit Health services and to improve on and develop new products and services;
• to help you locate products and services;
• to help you conduct product research;
• to communicate with you (via e-mail, post or otherwise) and provide you with promotional materials and additional information regarding our products, services, surveys, contests, promotions and special offers;
• to provide advertising to you, including targeted advertising;
• as part of contests and promotions;
• to respond to requests, complaints or inquiries;
• to investigate legal matters;
• for such purposes, as you may otherwise consent from time to time; and
• as otherwise required or permitted by law.

5. To whom do we provide your Personal Information?

We generally identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. With your consent, we may share your Personal Information with retailers, consumer product companies, and other third-party partners.  Where we are directed to do so, we will disclose your Personal Information to retailers, manufacturers, and others to initiate claims on your behalf. If you participate in a contest, survey, promotion or special offer, we may disclose your Personal Information with the Summit Health partners conducting the contest survey, promotion, or special offer.

We may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes. We may also disclose or transfer your Personal Information in connection with an actual or proposed business transaction (for example, the sale of part or all of our assets).

In addition, we may send Personal Information outside of the country for the Purposes, including for processing and storage by service providers in connection with such Purposes. We may send Personal Information to the United States.

You should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.  For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Officer (see question 16 below).

We may transfer or share your Personal Information where required or permitted by law.

6. When and how do we obtain your consent?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances.

7. How do we ensure the privacy of your Personal Information when dealing with ouraffiliates and other third parties?

We take appropriate steps to ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Information are generally contractually required to observe the intent of this Privacy Statement and our privacy practices.

8. How long will we utilize, disclose or retain your Personal Information?

We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

9. How can you review your Personal Information that we have collected, utilized or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will attempt to make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.

10. How do you know that the Personal Information we have on you is accurate?

We will attempt to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

11. What if the Personal Information we have on you is inaccurate?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

12. How fast will we respond to your written requests?

We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner in respect of this time limit.

13. Are there any costs to you for requesting information about your Personal Information or our privacy practices?

We will not charge any costs for you to access your Personal Information in our records without first providing you with an estimate of the approximate costs, if any.

14. How do we know that it is really you requesting your Personal Information?

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

15. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

16. How do you contact us regarding access to your Personal Information or our privacy practices?

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be forwarded to our Privacy Officer as follows: 

Address:	Attn: Privacy Officer Summit Health 1055 Beaver Hall Montreal, Quebec H2Z 1S5
By email:	[email protected]