- What information does 24-7 Intouch collect, and how is it used and shared?
- What are cookies and how do we use them and other technology?
- How does 24-7 Intouch protect personal information?
- How long does 24-7 Intouch retain my personal information?
- What are my choices concerning my personal information?
- What are my choices concerning online advertising?
- What is 24-7 Intouch’s policy on kids’ privacy?
- Access, objection, deletion and correction
- Your California Privacy Rights
- Transfer of personal information to other countries
- Right to Lodge Complaints
- Contacting us
2. What information does 24-7 Intouch collect, and how is it used and shared?
In providing the Client Services and the Site, 24-7 Intouch will at all times comply with all applicable privacy laws which may include, without limitation, the Personal Information Protection and Electronic Documents Act (Canada), the Personal Information Protection Act (British Columbia), the Personal Information Protection Act (Alberta), the Act respecting the protection of personal information in the private sector (Quebec), The Freedom of Information and Protection of Privacy Act (Manitoba), The Personal Health Information Act (Manitoba), the Health Insurance Portability and Accountability Act (HIPAA), and other similar legislation, statutes, regulations and rules in any other jurisdiction as may be applicable.
|Category of Personal Information Collected||Source||Purpose for Collection||Categories of Recipients|
|Contact information: such as name, address, and phone number.||Client contacts, including employees and representatives we work with provide this information when they visit the Site, call us, or otherwise interact with us.||To communicate with and respond to our clients about the work we do for them and deliver the Client Services to them and their customers, including validation of identity or to meet legal obligations.||We may share this information with select marketing or other service providers and partners.|
|Payment information: name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address.||From our clients and their payment card issuers.||Authorizing of credit card and other financial transactions for our clients and their customers.||Our service providers who process payments for us—they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards.|
|Health and safety information: details about your health, contacts, travel and potential exposure to infectious diseases, including medical symptoms.||From you, your contacts, and from client contacts, including employees and representatives we work with to support public health services.||To assist our client in providing public health services to you and for public health and safety purposes.||Our client and any third-parties authorized by our client who assist in the provision of public health services, in all cases subject to strict confidentiality and applicable law.|
|Accident information: details about any accident or injury in our facilities, or health incident.||From you, witnesses or observed about you.||To get you the help you need, deal with the emergency services, insurance and claims.||Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors.|
Suspected crime information: details of your identity, image, name and address, suspected or alleged thefts, fraud, assault or other criminal behavior.
|From crime and fraud prevention agencies, from you, witnesses, and from the police.||To protect customers, the public and our business against risks and crime.||
Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors.
Client Customer Health and safety information: details about your health, contacts, travel and potential exposure to infectious diseases, including medical symptoms.
|From you, your contacts, and from client contacts, including, but not limited to, employees and representatives we work with to support public health services.||To assist our client in providing its services, including any public health services to you, and related health and safety purposes.||
Our client and any third-parties authorized by law or our client who assist in the provision of health services, in all cases subject to strict confidentiality and in compliance with applicable law.
24-7 Intouch will only use personal information to the extent it is necessary to deliver the Client Services. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in sections 8 and 9. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by 24-7 Intouch, including requirements that such information be maintained in a confidential and secure manner.
In Connection with Business Transfers: In the event that a division, a product or all of 24-7 Intouch is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: 24-7 Intouch may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, our clients’ customers or employees or others, in accordance with or as authorized by law.
Information from our Client’s Customers: 24-7 Intouch processes transactions or applications that are supplied and managed by our clients. As a result, although we may access certain personal information of our client’s customers pursuant to the contractual relationships with have with our clients, we typically do not collect and store personal information in our own systems, with the exception of call recordings and screenshots/recordings. Typically, our clients are responsible for complying with all notices, notifications and alerts to individuals whose information is entered into our systems or portals. We do not use or share that personal information except as directed by our Clients.
3. What are cookies and how do we use them and other technologies?
A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. 24-7 Intouch does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.
Users of 24-7 Intouch Client Services and visitors to the Site should also be aware that technical information may be collected by 24-7 Intouch in relation to such use or as a result of a visit to the Site (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of the Site that you visited, the time and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data. When an individual accesses the Client Services or the Site with a mobile device, this Usage Data may include information such as the type of mobile device used, the mobile device unique ID, the IP address of the mobile device, the mobile operating system, the type of mobile Internet browser used, unique device identifiers and other diagnostic data. 24-7 Intouch uses this anonymous technical information for purposes such as diagnosing problems with 24-7 Intouch’s servers, improving the operation and content of 24-7 Intouch’s services and compiling aggregate and statistical information.
In particular, 24-7 Intouch may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
24-7 Intouch may also participate in interest-based or behavioral online advertising. For more information, please see below: What are my choices concerning online advertising?
Correspondingly, 24-7 Intouch may use third-party tracking technology such as “Demandbase Tags” to collect data about visitors to the Site for the purpose of serving 24-7 Intouch advertisements across the Internet. The data collected through Demandbase Tags will be used by and shared with Demandbase Inc. (“Demandbase”). To learn how Demandbase protects data entrusted to it, please visit: “Demandbase Security Policy” located at: https://www.demandbase.com/security-policy/.
Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore 24-7 Intouch and the Site do not recognize DNT
4. How does 24-7 Intouch protect personal information?
24-7 Intouch has in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under its control. Where applicable, 24-7 Intouch uses industry-standard technology in connection with our Client Services and on the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Personal information received from our clients or others in connection with Client Services is typically stored on servers hosted by our clients or their vendors. With limited exceptions, such as call recordings and screenshots/recordings required by our client contracts for quality assurance or other legitimate purposes, personal information collected by our clients is not stored on our or our service provider’s services.
24-7 Intouch also ensures that employees have completed privacy training before accessing or using personal information, and 24-7 Intouch updates its training programs periodically to reflect legislation and technological changes or as otherwise directed by our clients.
The protection of personal information is of paramount concern to 24-7 Intouch, and 24-7 Intouch is prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws
5. How long does 24-7 Intouch retain my personal information?
Personal information that we collect, access or process will be retained only as long as necessary for the fulfillment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or de-identified.
6. What are my choices concerning my personal information?
24-7 Intouch depends primarily on our clients to notify and provide their customers and employees choices regarding the personal information that they provide. Our clients are therefore responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to 24-7 Intouch.
In addition, as part of the Client Services, our clients may use personal information that we have collected on their behalf for their own communication and promotional purposes. Our clients are responsible for ensuring that any commercial emails sent by them to their employees or customers comply with applicable law. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.
We do not sell, rent, or share the personal information of our clients’ employees or their customers with third parties for their own marketing purposes.
24-7 Intouch may, subject to applicable laws, use personal information from our clients and their employees to contact them about our Site and Client Services, including to provide them with information on additional products from 24-7 Intouch that may be of interest to them. Client contacts may exercise choices regarding these communications as follows:
- Mail marketing, Telephone marketing, Surveys and Quality control communications. You may decide that you prefer 24-7 Intouch not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse to contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the Contacting Us section below.
- Emails/Commercial Electronic Communications.You can always limit the communications that 24-7 Intouch sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.
7. What are my choices concerning online advertising?
We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect information about your visits to the Site and other websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Site and elsewhere over time. Other companies may also use such technology to advertise on our Site.
You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit:
In Canada, please visit: http://youradchoices.ca/choices/
In the EU, please visit: http://www.youronlinechoices.eu/
9. What is 24-7 Intouch’s policy on kids’ privacy?
24-7 Intouch and our Site are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If 24-7 Intouch learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact us using the information detailed in the Contacting Us section below.
10. Access, Objection, Correction and Deletion
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion and to revoke any consent that you have previously provided to us for the processing of your personal information.
Our clients are responsible for managing any request made by their employees or customers regarding access to and rectification of their personal information that is transferred to us. However, if you have questions about your rights, please feel free to contact us using the contact information detailed in the Contacting Us section below.
11. Your California Privacy Rights
Please note: If you are a customer of one of our Clients, you should contact them first concerning your California Privacy rights
If you are a resident of California or of Virginia (starting Jan. 2023), Colorado and Connecticut (starting July 2023), or Utah (as of Dec. 2023), the law in those states provides you with the following rights with respect to your personal information, if applicable:
- The right to know what personal information we have collected, used, disclosed and sold about you. To submit a request, you may call us at 1-800-530-1121 or visit https://24-7intouch.com/contact. You also may designate an authorized agent to make a request for access on your behalf on our website at https://24-7intouch.com/contact.
- The right to correct what personal information we have collected, used, disclosed and sold about you. You also may designate an authorized agent to make a request for access on your behalf on our website at https://24-7intouch.com/contact.
- The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may call us at 1-800-530-1121 or visit https://24-7intouch.com/contact. You also may designate an authorized agent to make a request for deletion on your behalf on our website at https://24-7intouch.com/contact.
When you exercise these rights and submit a request to us, we will verify your identity by asking you for information such as your email address, telephone number, information about your company’s contract with 24-7 Intouch, or the last four digits of a credit or debit card used at 24-7 Intouch. We also may use a third party verification provider to verify your identity.
Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
12. Cross-border transfer of personal information
In some cases, personal information that we process, including information from our clients and their employees and/or customers located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Site may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions. Where requested by our clients, we may also enter into data transfer agreements under applicable laws (e.g., EU Standard Contractual Clauses) to allow for transfer of personal information.
For greater certainty, the foregoing is not applicable where 24-7 Intouch has agreed with a particular client that personal information may only be processed and stored in a particular jurisdiction. In such circumstances, 24-7 Intouch takes reasonable steps to ensure that personal information is not transferred, processed or stored outside of the jurisdiction(s) as may be agreed with the applicable client.
13. Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in Canada. For information on how you can file a privacy complaint with the Office of the Privacy Commission of Canada (OPC), please visit: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/.
This policy was created on and is effective as of July 19 , 2022.
15. Contacting us
200-240 Kennedy Street
Winnipeg, Manitoba R3C 1T1