Who we are and what this policy covers
My Health Information Co-op is a democratically owned Canadian non-profit Co-op registered with the B.C. Registrar of Companies on July 14, 2020.
Your privacy is critically important to us. At My Health Information Co-op, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information only if we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
What personal data we collect and why we collect it
- Our WordPress website;
- Our mobile applications (mobile app for Android and iOS);
- Any other My Health Information Co-op products, services, and features that are used for business operations or available on or through our websites:
|Service Provider||Location||Information Held|
|Zenutech Web Hosting||Canada||Information entered into website excluding complete payment information, which is stored on Stripe’s secure database|
|MailChimp||USA||Email contact information and limited profile information such as jurisdiction in which a member received Canadian health services.|
|Microsoft Office 365||Canada||General contact information and information related to Co-op membership shares and participation.|
|Stripe||USA||Contact and payment information|
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from two sources: when you provide information to us automatically through operating our Services, and from outside sources.
Let’s go over the information that you provide.
- At checkout, we will collect your name, email address, username, and password. This information is used to setup your account for our site. If you are redirected to an offsite payment gateway to complete your payment, we may store this information in a temporary session variable to setup your account when you return to our site.
At checkout, we also collect your billing address and phone number which is used to confirm your credit card and Co-op member account information. The billing address and phone number are saved by our site to prepopulate the member account information fields and so we can get in touch with you if needed to discuss your order.
At checkout, we may also collect your credit card number, expiration date, and security code. This information is passed to our payment gateway to process your purchase. The last 4 digits of your credit card number and the expiration date are saved by our site to use for reference and to customer support.
- For your account: We ask for basic information from you to set up your members-only area account. For example, individuals who sign up for an account provide an email address and password, along with a username or name. You may provide more information — such as information you put into your profile, like a photo or an “About Me” description.
- Website content information: You might provide us with information about you in the t and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
- Communications with us (hi there!): You may also provide us with information when you respond to surveys, communicate with customer support, post a question in a public forum, or sign up for a newsletter or monthly email communications. When you communicate with us via form, email, phone, comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
- When requesting medical records on your behalf: For example, if you ask us to request a copy of your MSP Billing History you will need to complete an application that provides a Provincial Ministry of Health with information, they require to find your records – such as your provincial health number (PHN) or other information such as a drivers license or social insurance number.
- Job, Volunteer and Board applicant information: If you apply to volunteer with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.
We also collect some information automatically:
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our services; for example, logging in and out or when you create or make changes in your account – such as adding documents, images or data files.
- Usage information: We collect information about the usage of our Services. For example, we collect information about the actions that site administrators and users perform on a site to assist you — in other words, who did what and when (e.g., [username] deleted “[Name of uploaded file]” at [time/date]). We also collect information about what happens when you use our Services (e.g., page views, support document searches, changes to your profile information, interactions with our navigation menus and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, identify unusual login from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored information: If you use our phone App we may access information stored on your mobile device via the mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a photograph of an injury, prescription label or test result to your account.
How and Why We Use Information
We use information about you for the purposes listed below:
- To provide our Services. For example, to set up and maintain your account, host your website, backup and restore your website, provide customer service, process payments and orders, and verify user information.
- To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.
- To place and manage ads in our advertising program. For example, to place ads on other websites, mediums and with partner organizations as part of our membership growth program and understand our performance.
- To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users, promoting our Services, analyzing the results of our marketing campaigns (like how many people donated, purchased a premium subscription after receiving a marketing message), and understanding and forecasting user retention.
- To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of My Health Information Co-op and others, which may result in us, for example, declining a transaction or terminating Services.
- To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
- To customize the user experience. For example, to personalize your experience by serving you relevant notifications and messages about our Services, recommending content and activities, and providing education material related to your health and wellness.
- To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on My Health Information Co-op; texting you to verify your payment; or calling you to share information that we think will be of interest to you. If you don’t want to hear from us, you can opt out of communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
A special note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
- The use is necessary to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, to enable access to our website on your device or charge you for membership or make a donation; or
- The use is necessary for compliance with a legal obligation; or
- The use is necessary to protect your vital interests or those of another person; or
- We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services, and to personalize your experience; or
The information that is uploaded into your OmniHealth Vault is owned by you as is all information you provide inside the members-only account area. My Health Information Co-op will never share your personal information with any third party without your consent unless it is required to do so by law. We may share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below,
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so (i.e. you agreed that you are available to participate in clinical trials or other health service related research).
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental requests. For more information on how we respond to requests for information about My Health Information users, please see our Legal Guidelines.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of My Health Information Co-op, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- Aggregated or de-identified information: Only with your consent, we may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you.
Co-op members set policy and the standing policy is that we do not sell your information to other companies that want to spam you with marketing emails. Co-op members may set and alter policy as set out in it Rules. The Co-op may show ads on our site and the revenue we generate lets us offer free access to some of our Services so that money does not become an obstacle to participating in the Co-op.
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly. For example, this means your member profile, posts, other content that you make visible to other co-op members account area of our website. All information in Co-op members-only account area can not be seen by the general-public but some can be seen by other Co-op members.
For example, the photo that you upload to your member profile, or a default image if you haven’t uploaded one, is your Globally Recognized Avatar, or Gravatar — get it? 🙂 Your Gravatar, along with other member viewable profile information, displays alongside the comments that you make in groups and on forms — remember, you control your privacy settings for you profile information.
You can make all or some of your account profile private. You can choose to hide Pages, Posts and content such as Activity, Groups, Members, Member Profile Pages, etc. Go to your Account Settings > Profile Privacy page, select the preferred options in the Profile Privacy settings and then click the Save button.
How Long We Keep Information
Until you delete it – you have the right to your information and can download and purge our system of your information. We generally discard information about you when it is no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.
For example, we keep web server logs that record information about a visitor to My Health Information Co-op’s websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this time period in order to, among other things, analyze traffic to our website and investigate issues if something goes wrong with it.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We and our service providers monitor My Health Information Co-op Services for potential vulnerabilities and attacks.
The servers and files are in data centres located in Canada which are provided by Zenutech Web Hosting (https://zenutech.com). Zenutech is committed to Green Sustainable Dedicated Server Web Hosting Canada » Zenutech.
My Health Information Co-op has a Cyber Security Incident Plan in accordance with Canadian Privacy Legislation and best practices. The plan includes regular security audits by an independent third party.
To enhance the security of your account, we encourage you to consider the importance of your role and responsibility for security. Keep your password private and take steps to keep your information safe. If you are using the App, you should make sure you keep your device in a safe place, so it will not be lost or stolen. You should use a secure password or another method to lock your device, such as biometrics. You can also download an app (like Find My iPhone or Android Device Manager) that lets you remotely lock your device if you lose it.
Resources you may find helpful are:
- Rethink Your Password Habits to Protect Your Accounts from Hackers
- Best Practices for Passphrases and Passwords
- How to protect yourself – Internet, email and telephone scams
- Citizens who fear that they have been the victims of fraud can contact their local police or the Canadian Anti-Fraud Centre.
How can I delete my information or close my account?
The information held by My Health Information Co-op is your personal information. You may remove it if you no longer wish to use the My Health Information Co-op service. You can erase your information from the members-only site by ending your co-op membership. This functionality is available in the Co-op membership Account Settings menu. Once you delete your account, My Health Information Co-op cannot get your information back. When you delete your account, your personal information will be removed from the active user databases, but it may stay in backup storage for up to 30 days before it is completely removed or destroyed.
If you have downloaded your information to share it with another service provider, this service provider will have a copy of your information. This information is not under My Health Information Co-op’s control. When you end your Co-op membership, any of your information held by another service provider will not be deleted from their records. If you need to delete any information that you shared with another company or organization, you will need to contact them directly.
You have several choices available when it comes to information about you:
- Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information. Please keep in mind that if you do not provide certain information, certain features of our Services — for example, our OmniHealth Vault Service — may not be accessible.
- Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Close your account: While we would be very sad to see you go, you can close your account if you no longer want to use our Services. (Here are account closure instructions for Co-op accounts.) Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
European General Data Protection Regulation (GDPR)
If you are in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
- You also have the right to make a complaint to a government supervisory authority.
Advertising and Our Ads Program
Our mission is to democratize health records, and that means making our Services accessible to as many people as possible. We show ads on some of our users’ sites as well as some of our own sites, and the revenue these ads generate lets us to subsidize our Services so that money does not become an obstacle to having participation in the Co-op.
Contacting Us About These Rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to “How to Reach Us” to, well, find out how to reach us.
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
How to Reach Us
Registered Office: 3125 Somerset Street, Victoria, BC, V8X 1C8
Our website address is: https://myhealthinformation.ca
This is our current policy, updated on December 13, 2020