Summary
We are TELUS Health (Canada) Ltd. ("TELUS Health"), a corporation organized under the laws of Ontario, Canada. (Canada) Ltd. owns and operates the TELUS Health business through its subsidiaries in various countries including without limitation Canada, the United States, the United Kingdom and Australia. For the purposes of applicable data protection laws, TELUS Health is a wholly owned subsidiary of TELUS Health Inc. and out primary business address is 25 York Street, 29th floor, Toronto, Ontario M5J 2V5 Canada. TELUS Health (Canada) Ltd. is the data controller of your personal data.
When using TELUS Health One in the UK or EU the controller is TELUS Health (U.K.) Ltd., a private limited company organized under the law of England and Wales (Reg. No. 8223675) located at 90 High Holborn, Holborn, London, WC1V 6JL UK.
This Privacy Policy explains the collection, use and disclosure of personal information and sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand the ways in which we use, share and protect your personal information.
The management of personal information is fundamental to TELUS Health services and we are committed to protecting your privacy.
TELUS Health collects and uses personal information to identify you, establish eligibility, and to provide technology-enabled total health, wellbeing and human resources services (such as pensions and benefits, employee assistance programs, and health management programs), including through our websites and apps. We also use your information for our own purposes, including to analyze and improve our services and for communications.
Please see the headings below to get more detailed information on how TELUS Health handles your personal information and on any topics of interest in our Privacy Policy. If you are located in:
- The European Economic Area (EEA) or Switzerland, you should read this Privacy Policy together with the Privacy Policy Addendum for Europe to understand your rights and options.
- Barbados, you should read this Privacy Policy together with the Privacy Policy Addendum for Barbados.
- South Africa, you should read this Privacy Policy together with the Privacy Policy Addendum for South Africa.
- Ukraine, you should read this Privacy Policy together with the Privacy Policy Addendum for Ukraine.
About this Privacy Policy
We created this privacy policy to tell you:
- What personal information we might collect about you;
- What we might do with that personal information; and
- Your choices about the personal information you provide.
This policy covers our websites, mobile apps, services provided through these platforms or otherwise accessed by a user (such as our counselling and well-being services) and any other interactions you may have with us (such as by telephone, email, or in person). This policy specifically covers our handling of personal information (including, in the case of some of our services, sensitive personal information) relating to identifiable individuals and does not apply to proprietary business information.
Some of our services are provided on behalf of our clients, which means our client remains primarily responsible for your personal information. For instance, we may be providing services on behalf of your employer or plan sponsor. In these circumstances, we may re-direct a query about our use of your personal information to our client.
Getting Your Consent
As part of using our services or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes we’ve informed you of, or as may be otherwise permitted or required by law. Your consent can be express or implied (where this is permitted by law). For example, by participating in your benefits plan, you consent to TELUS Health's collection and use of your personal information to provide services to that plan. In some situations, we may get consent directly from you (including as described in this privacy policy). In other situations, we may rely on the consent you provided to your employer or benefits sponsor.
You can withhold or withdraw your consent for us to collect, use or share your personal information (to the extent our processing is based on your consent in accordance with applicable law). The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Depending on the circumstances, however, withdrawal of your consent may impact our ability to serve you, or in the case of administering benefits, it may prevent us from processing your claims.
Where We Get Your Information
We collect personal information in the following ways:
- Directly from you;
- From your use of TELUS Health's services, programs, websites and apps;
- From your employer, association, insurer or benefits plan sponsor;
- When you attend a TELUS Health site or event;
- When you apply for a position at TELUS Health;
- If you contact us with a complaint or query;
- When you engage with us over social media; and/or
- From legally authorized third parties
Children's Information
We will not knowingly collect, use or share personal information if you are under the age of majority in your area without the permission of your parent or guardian. If you are underage and want to access our counselling and wellness services, your parent or guardian needs to contact TELUS Health on your behalf.
What Information We Collect and Why
Our collection and use of your personal information depends on what products and services your sponsoring organization chooses to make available to you, which TELUS Health products and services you choose to participate in, and what information you choose to provide to us.
We may collect and use the following types of information for the following purposes:
Personal Information
|
Personal Information Category |
Types of Information We May Collect |
How We May Use It |
|
Identity information |
Your name, username, employee number or similar identifier, marital status, date of birth and reported gender |
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Contact information |
Your billing address, postal address, email address and telephone numbers |
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Employment information |
Your job title, place of work, hire date, employment history, work address |
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Interaction information |
Telephone recordings and transcripts, records of communications (such as emails, letters, online chat, etc.) |
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Digital interaction information |
Geolocation data, IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system (including the type of device used) and other technology, related to the devices you use to access our websites and/or our apps |
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Job Applicant Information |
Résumé, cover letter, reference letters, employment history and interests |
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Sensitive Personal Information
|
Sensitive Personal Information Category |
Types of Information We May Collect |
How We May Use It |
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Financial information |
Your banking information, email linked to your electronic transfers, and payment information |
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Transaction information |
Details about payments to and from you, and other details of products and services you have purchased from us, including customer account numbers |
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Health information |
The state of your physical and/or mental health which we receive in connection with your use of our services, provided by you through connected devices or through any Assessment you complete |
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Health measurement |
Your weight, height, body mass index, waist circumference, cholesterol, lipoprotein, triglycerides, glucose and blood pressure readings, sleep patterns or other similar information provided by you through connected devices or through any Assessment you complete |
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Lifestyle information |
Your alcohol consumption, tobacco/nicotine use, eating and nutrition (e.g., number of servings of food groups and nutrition related questions), cardiovascular disease risk, emotional well-being (e.g., depression and stress), and readiness to change |
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Claims information |
Information disclosed to us with your permission by your insurance, health plan provider, or plan sponsor regarding claims you have made under your policy and/or other information, including health information |
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We may also collect and use your information to:
- Perform services on your behalf or your employer’s/benefits sponsor’s behalf (including total health and wellbeing, rewards and recognition services, employee and family assistance services, health management programs, group benefits and investment plans, and pension administration services);
- Understand your needs, the suitability of our products and services, and improve our products and services;
- Provide services tailored to your requirements and to treat you in a more personal way;
- Promote and market our products and services to you;
- Improve our business operations and the quality of our products and services;
- Develop and test new products and services;
- Manage our business and operational needs;
- Administer and protect the security of our business, and our websites, apps and other services;
- Meet our legal and regulatory obligations, including to enforce our legal rights; and
- Carry out other purposes related to any of the above.
- De-identified, Aggregated, and Anonymized Information
De-identified, Aggregated, and Anonymized Information
We may use your personal information to generate de-identified, aggregated or anonymized information that does not reveal your identity. TELUS Health uses this information to conduct research, compile aggregate data sets, statistics and reports, and to perform analytics on our services, service standards, business operations, and trends.
We may share de-identified, aggregated or anonymized information with our clients for reporting purposes, including usage of our services, and with third party service providers for use in creating marketing materials, cases studies and statistical analyses. This allows TELUS Health, its clients and our respective third-party service providers to understand how we are performing, or develop relevant products, services or offers.
When Does TELUS Health Share Your Personal Information?
TELUS Health may share your personal information with:
- Other TELUS Health entities in order to serve you, including for our internal management and administrative purposes.
- Third party service providers who are required to keep your information confidential and secure and are restricted from using or disclosing information for reasons other than performing services on our behalf or to complying with legal requirements.
- Third parties and partners in the event of a potential merger or acquisition, transfer of assets, reorganization, or bankruptcy. These parties are also required to keep your information confidential and secure and are restricted in their use of information to this purpose.
- Government, regulatory and law enforcement agencies to meet our compliance, regulatory, and risk management obligations or to comply with the law.
- The general public and other users when you post or share comments, blog postings, testimonials, or other similar information on our technology platforms.
- Your sponsoring organization or health plan provider when you provide your express or implied consent (where this is permitted by law) or if we are required to do so by law.
International Transfers of Information
TELUS Health is a global organization with affiliates, partners and subcontractors located in many countries around the world. To provide our services to you, TELUS Health may exchange personal information across geographical borders with TELUS Health entities, affiliates or service providers in other countries working on our behalf in accordance with applicable law.
Examples of countries we transfer and exchange personal information with include, but are not limited to, the United States of America, the United Kingdom, Canada, and Australia. If your personal information is transferred outside of your country, we will take appropriate measures to ensure an equivalent standard of personal information protection under applicable law. We will also obtain consent where this is required under applicable law. Please contact us if you want more information on how we protect personal information transferred out of your country.
Notice to Users in China
The below information which may be collected from you or provided by your Sponsoring organization is exported out of China
|
Personal information collected (including sensitive information) |
Description |
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Identity information |
Provided by you or your sponsoring organization when creating your account such as your name, date of birth, employee number, gender, language |
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Contact information |
Provided by you or your sponsoring organization when creating your account such as your email, Country, City |
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Employment information |
Provided by you or your sponsoring organization when creating your account such as Company name, job title, work status, employment start date |
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Health information |
The state of your physical and/or mental health provided by you in connection with your use of our services, provided by you through connected devices or through any Assessment you complete |
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Health measurement |
Your weight, height, body mass index, waist circumference, cholesterol, lipoprotein, triglycerides, glucose and blood pressure readings, sleep patterns or other similar information provided by you through connected devices or through any Assessment you complete |
|
Lifestyle information |
Your alcohol consumption, tobacco/nicotine use, eating and nutrition (e.g., number of servings of food groups and nutrition related questions), cardiovascular disease risk, emotional well-being (e.g., depression and stress), and readiness to change. This information is provided by you through Assessments you may complete |
Storage of Your Information
TELUS Health may store your personal information in its databases located in the United States, Canada, the United Kingdom, or other countries. Some of our service providers may also store or access personal information from countries other than where you reside or receive services, and in those circumstances, are subject to the laws of that jurisdiction. Because of this, there may be circumstances where other foreign governments, courts, law enforcement agencies or regulatory agencies are entitled to access the personal information collected and held by TELUS Health or our subcontractors. If you are visiting our website from a country other than Canada, your communication through our website or any of its services may result in the transfer of information across international boundaries.
Retention of Your Information
We only keep your information as long as it is contractually, operationally or legally necessary. When we no longer need the information, it is either destroyed or anonymized.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
For further information on retention periods, please see our Retention Policy for TELUS Health One or if you have any other questions contact us using the details provided at the end of this Privacy Policy.
Safeguards
We use reasonable physical, technological, organizational, and contractual safeguards, appropriate to the sensitivity of the information, to protect personal information in our possession or under our control, from unauthorized access, disclosure or use.
Accessing Your Information
When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain. We may not be able to provide you with all the information you request, depending on prescribed circumstances, and there may be a charge for copies of your personal information.
Correcting Your Information
We will make reasonable efforts to keep your information accurate and up to date. If a change or correction is required, let us know right away. We’ll make appropriate updates needed to keep things running smoothly. You can review your personal information by looking at the correspondence we send to you, through your online accounts with us, or by requesting access to your personal information, as described above.
Other Data Subject Rights
Depending on the country in which you are based in, you may have additional rights over your personal information, including:
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Right to delete personal information. You may have the right to request the deletion of your personal information upon the withdrawal of your consent for us to process such information or other circumstances provided under applicable law, provided that such data no longer needs to be processed by us to fulfil our legal and regulatory obligations.
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Right to restrict or object to processing. You may have the right to request us to anonymize, delete or otherwise restrict or object to the processing of your personal information in certain circumstances, such as where you establish that the information collected by us is unnecessary or excessive.
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Right to data portability. You may have the right to request us to provide you with your personal information in a structured, commonly used, and machine-readable format and a right to request that we transfer such information to another party.
- Right to lodge a complaint. You may have the right to lodge a complaint about the way we handle or process your personal information with the relevant authorities.
Note for French data subjects only: you have a right to define guidelines relating to the fate of your personal data in the event of death.
If you would like to exercise any of these rights, please use the contact details below.
Marketing
We may occasionally send you email notices concerning our Website, App or Services, which may include emails tailored to you based on your activity on our Website or App. You may also receive emails from us arising from your use of particular Services requiring email communication. Where possible, you will be given the option to choose a different method of communication or to opt out of receiving such communications, although it may adversely affect or otherwise prevent you from receiving the full scope of Services you signed up to receive.
Contact Information
If you have any questions or concerns about this policy or TELUS Health’s handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Officer
TELUS Health (Canada) Ltd.
25 York Street
Floor 30
Toronto, ON M5J 2V5
Canada
By electronic mail: privacyhealth@telus.com
Please note that we may need to confirm your identity, request additional details and work with other TELUS Health departments to respond to you or to look into your concerns or complaint.
Changes to Our Privacy Policy
We may modify this notice from time to time and will post the most current version online.
Last updated: March 2024
Cookie Policy for TELUS Health One
What is a Cookie?
A cookie is a small data file that a website may place on your device. A cookie file can contain technical information (such as a user ID) that the website can use to track the pages you have visited and to record your preferences for future visits. For example, when you visit our website, we may collect information from you automatically through cookies or similar technology.
Cookies We Use and Why We Use Them
TELUS Health One uses cookies and related technologies to distinguish you from other users, to understand how you use our websites, to monitor and improve the performance of our websites, and to personalize your experience.
A number of cookies on TELUS Health websites last only for the duration of your web session and expire when you close your browser. Other cookies (known as “persistent cookies”) remain on your device because they are used to remember you when you return to the website.
Essential Cookies
|
Cookie Name |
Type |
Description |
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WAM_AUTH |
User session maintenance cookie |
This helps you maintain your browsing session between webpages and between the website or app and API (“application programming interface”). |
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wamToken |
User session maintenance cookie |
This helps you maintain your browsing session between webpages and between the website or app and API (“application programming interface”). |
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lw_language |
User language cookie |
This cookie tracks the language in which our website or app are displayed. It's stored locally and is not transmitted with each HTTP request. |
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wamMe |
User session identification cookie |
Keeps you logged in between webpage changes. |
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wamT |
User session identification cookie |
Keeps you logged in between webpage changes. |
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persistence |
Whether to persist a login |
This cookie is used to identify whether to keep the user logged in after closing the browser window. |
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AWSELB |
OneHippo CMS cookie for client |
The AWS Load Balancer cookie is used to map the Hippo CMS session to the instance to ensure the user's experience remains consistent. |
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Cloudfront-* |
Cloudfront config cookie |
CloudFront authentication cookies are used to access audio and video content from our CMS articles. |
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_help_center_session |
Provides a better experience in the TELUS Health Helpdesk area. |
A ZenDesk - Customer Help and Support system that provides answers to common questions and allows users to raise support tickets. |
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_zendesk* |
Provides a better experience in the TELUS Health Helpdesk area. |
A ZenDesk - Customer Help and Support system that provides answers to common questions and allows users to raise support tickets. |
Functional Cookies
|
Cookie Name |
Type |
Description |
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walkthroughExcludeList |
User Preference |
Controls whether to provide a walkthrough for first time users. This cookie is stored locally and is not transmitted with each HTTP request. |
Analytics Cookies
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Cookie Name |
Type |
Description |
|
_ga |
Non personal tracking cookie |
Collects non-personal information about how visitors use the TELUS Health Website or App that we will use to monitor their performance to improve them where necessary. |
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_gat |
Non personal tracking cookie |
Collects non-personal information about how visitors use the TELUS Health Website or App that we will use to monitor their performance to improve them where necessary. |
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_gid |
Non personal tracking cookie |
Collects non-personal information about how visitors use the TELUS Health Website or App that we will use to monitor their performance to improve them where necessary. |
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CONSENT |
Non personal tracking cookie |
These are cookies stored by Google relating to the Google services we use such as Google Fonts and Google Analytics. |
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DV |
Google cookie |
These cookies are set via embedded Google scripts such as Google Fonts, Google Analytics and embedded YouTube videos. They register anonymous statistical data on for example how many times a video is displayed and what settings are used for playback. No sensitive data is collected unless the user has logged in to their Google account, in that case your choices are linked with your account, for example if you click “like” on a video. |
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1P_JAR |
Google cookie |
These cookies are set via embedded Google scripts such as Google Fonts, Google Analytics and embedded YouTube videos. They register anonymous statistical data on for example how many times a video is displayed and what settings are used for playback. No sensitive data is collected unless the user has logged in to their Google account, in that case your choices are linked with your account, for example if you click “like” on a video. |
|
giftCards* |
Gift card order |
Tracks an order when the connection to the website or app is interrupted. These cookies are stored locally and are not transmitted with each HTTP request. |
Third Party Cookies
In addition to the cookies that TELUS Health delivers to your device through our websites, third parties may also place cookies for a variety of reasons. For example, we use Google Analytics, a web analytics tool that helps us understand how visitors engage with our websites. To learn more about Google Analytics, click here.
Other third parties may deliver cookies to your device for the purpose of understanding your online behaviors across non-affiliated websites and delivering targeted advertisements either on our websites or on other websites.
Blocking Cookies
You can block cookies by adjusting your internet browser settings, although this may interfere with the functionality of TELUS Health websites. For more information on blocking cookies or targeted advertising check your browser’s instructions.
Do-Not-Track Mechanisms
Because of the rapidly changing state of technology, we cannot make any guarantees that our systems will be able to honor Do-Not-Track requests sent by your browser.
How to Manage Cookies
You can set your browser not to accept cookies or adjust your browsers cookie settings appropriately. However, in a few cases, some of our website features may not function as a result. Should you choose to disable or block our cookies on your computer you will need to do this through your browser. Click on the 'Help' menu to learn how to manage your cookie preferences.
Contact Information
If you have any questions or concerns about this policy or TELUS Health’s handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Officer
TELUS Health (Canada) Ltd.
25 York Street
Floor 30
Toronto, ON M5J 2V5
Canada
By electronic mail: privacyhealth@telus.com
Please note that we may need to confirm your identity, request additional details and work with other TELUS Health departments to respond to you or to look into your concerns or complaint.
Changes to Our Cookie Policy
We may modify this notice from time to time and will post the most current version online.
Last updated: March 2024
Mobile Applications Privacy Policy
TELUS Health collects, uses, and shares information when you download, register with or use our mobile applications (“Apps”). For more detailed information on how TELUS Health processes your information, please review the TELUS Health Privacy Policy and if you are located in:
- The European Economic Area (EEA) or Switzerland, you should read this Privacy Policy together with the Privacy Policy Addendum for Europe to understand your rights and options.
- Barbados, you should read this Privacy Policy together with the Privacy Policy Addendum for Barbados.
- South Africa, you should read this Privacy Policy together with the Privacy Policy Addendum for South Africa.
- Ukraine, you should read this Privacy Policy together with the Privacy Policy Addendum for Ukraine.
Information We Collect
TELUS Health may collect:
- Personal information, such as contact, employment or health information you provide to register and use our Apps; and
- Technical information, such as data about your usage of an App (e.g., crash logs), data about your device (device type, operating system etc.) and its interaction with an App, and device geolocation information.
How We Use Your Information
TELUS Health may use information collected through our Apps to:
- Complete registrations, transactions or services requested through our Apps;
- Contact you in connection with services or inquiries requested through our Apps;
- Keep you posted on latest announcements and offerings;
- Personalize the content and features of our Apps;
- Review the quality of our Apps, and improve their functionality;
- Develop products and services, including new Apps and features;
- Create de-identified information for data analytics and other purposes;
- Generate and share anonymized analytics and industry benchmarking; and
- Comply with laws and regulations and lawful requests or orders.
As a global organization, TELUS Health and our third-party service providers process and store personal information in various countries around the world. We only keep your information as long as it is contractually, operationally or legally necessary. When we no longer need the information, it is either destroyed or made anonymous.
Your Choices
You may access, modify, or delete your personal information by logging into our Apps using your username and password and visiting your account settings. You may opt-out of all future collection of information by TELUS Health by uninstalling our App from your mobile device.
- Notifications and location data. When you access our Apps, you may be asked whether you will allow us to access your location while you are not using the App and/or whether you would like to receive notifications on your device. If you click “allow”, you can later opt-out by updating the privacy settings on your device or in the App itself. If you block the use of location information, some parts of our Apps may not function properly.
- Information on your device. The ability to collect certain personal information is controlled by your device settings (e.g., access to contacts, photos). If you choose not to allow this access, some services may not operate effectively. Refer to the documentation for your device regarding how to allow or block the collection of certain device information.
Contact Information
If you have any questions or concerns about this policy or TELUS Health’s handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Officer
TELUS Health (Canada) Ltd.
25 York Street
Floor 30
Toronto, ON M5J 2V5
Canada
By electronic mail: privacyhealth@telus.com
Please note that we may need to confirm your identity, request additional details and work with other TELUS Health departments to respond to you or to look into your concerns or complaint.
Changes to Our Privacy Policy
We may modify this notice from time to time and will post the most current version online.
Last updated: March 2024
Privacy Policy Addendum for Europe
This Privacy Policy Addendum for Europe (“Privacy Policy for Europe”) is for users of TELUS Health services who are located in the EEA and Switzerland. If you’re located in the EEA or Switzerland, you should read both the TELUS Health Privacy Policy and this Privacy Policy Addendum for Europe to understand your rights and options.
Basis of Lawful Processing
European data protection laws require us to be specific about our reasons or grounds for using your personal information. TELUS Health processes the personal information of users in the EEA or Switzerland on these grounds:
- Consent. When you have provided your consent or, in the case of sensitive personal information, when you have provided your explicit consent, to our collection of your information;
- Performance of a contract with you. When we need to perform the service you are seeking or have agreed to, according to the Terms of Use you agree to when you create an account with TELUS Health;
- Legitimate interests. When we have a legitimate business or commercial reason for using your information, and your interests and your fundamental rights do not override those interests. We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.; and/or
- Legal obligation. When we need to comply with a legal or regulatory obligation.
Before collecting or using any special categories of data (referred to as sensitive personal information in the Privacy Policy), we will only use that information:
- With your explicit consent;
- For the establishment, exercise or defense by us or third parties of legal claims; or
- If there is an exemption under local law that allows us to use it, such as in relation to the processing of special categories of data for insurance purposes, or for determining benefits under an occupational pension scheme.
TELUS Health may process your personal information on more than one ground depending on the reason or grounds for using your personal information. Please contact us if you need details about the specific grounds we are relying on to process your personal information.
Transfer of Personal Information Outside the EEA
TELUS Health will ensure that adequate safeguards are implemented if and when we need to transfer personal information outside of the EEA so that a similar degree of protection is afforded to it. Please contact us if you want more information on how we transfer and protect your personal information out of the EEA.
Contact Information
If you have any questions or concerns about this policy or TELUS Health’s handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Officer
TELUS Health (Canada) Ltd.
25 York Street
Floor 30
Toronto, ON M5J 2V5
Canada
By electronic mail: privacyhealth@telus.com
Please note that we may need to confirm your identity, request additional details and work with other TELUS Health departments to respond to you or to look into your concerns or complaint.
Changes to Our Privacy Policy
We may modify this notice from time to time and will post the most current version online. If we make significant changes to our Privacy Policy, we will communicate these changes appropriately.
Last updated: March 2024
Privacy Policy Addendum for South Africa
Data Subject Rights
If you reside in South Africa, you have the right to lodge a complaint with a supervisory authority, in addition to those set out in the Privacy Policy, and the details of the supervisory authority is set out below:
- Email: POPIAComplaints@inforegulator.org.za
- Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, Gauteng, South Africa, 2017
Privacy Policy Addendum for Ukraine
Data Subject Rights
If you reside in Ukraine, you may have certain rights in addition to those set out in the Privacy Policy, including:
- The right to know about the sources of collecting and the location of your personal data, the purpose of its processing, location of controller or empower the authorised parties for obtaining such information;
- The right to obtain information on conditions for providing access to their personal data, in particular information about third parties to whom their personal data is transferred to;
- The right to obtain information on whether their personal data is being processed and the content of such data within 30 calendar days;
- The right to protect their personal data from unlawful processing and accidental loss, destruction, damage, as well as from provision of information that is inaccurate or discredit honour, dignity and business reputation;
- The right to private action;
- The right to restrict the processing of your personal data;
- The right to be informed of the logic of automatic processing (if applicable); and
- The right to protect yourself from automated decision-making (if applicable) that results in legal consequences.
Privacy Policy Addendum for Barbados
This Privacy Policy Addendum for Barbados is for users of TELUS Health services who are located in Barbados. If you’re located in Barbados, you should read both the TELUS Health Privacy Policy and this Privacy Policy Addendum for Barbados to understand your rights and options.
Basis of Lawful Processing
Barbados data protection laws require us to be specific about our reasons or grounds for using your personal information. TELUS Health processes the personal information of users in Barbados on these grounds:
- Consent. When you have provided your consent or, in the case of sensitive personal information, when you have provided your explicit consent, to our collection of your information;
- Performance of a contract with you. When we need to perform the service you are seeking or have agreed to, according to the Terms of Use you agree to when you create an account with TELUS Health;
- Legitimate interests. When we have a legitimate business or commercial reason for using your information, and your interests and your fundamental rights do not override those interests. We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice; and/or
- Legal obligation. When we need to comply with a legal or regulatory obligation.
Before collecting or using any special categories of data (referred to as sensitive personal information in the Privacy Policy), we will only use that information:
- With your explicit consent;
- For the establishment, exercise or defence by us or third parties of legal claims; or
- If there is an exemption under local law that allows us to use it, such as in relation to the processing of special categories of data for insurance purposes, or for determining benefits under an occupational pension scheme.
TELUS Health may process your personal information on more than one ground depending on the reason or grounds for using your personal information. Please contact us if you need details about the specific grounds we are relying on to process your personal information.
Transfer of Personal Information Outside Barbados
TELUS Health will ensure that adequate safeguards are implemented if and when we need to transfer personal information outside of Barbados so that a similar degree of protection is afforded to it. Please contact us if you want more information on how we transfer and protect your personal information out of Barbados.
Contact Information
If you have any questions or concerns about this policy or TELUS Health’s handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Office
TELUS Health (Canada) Ltd.
25 York Street
Floor 30
Toronto, ON M5J 2V5
Canada
By electronic mail: privacyhealth@telus.com
Please note that we may need to confirm your identity, request additional details and work with other TELUS Health departments to respond to you or to look into your concerns or complaint.
Changes to Our Privacy Policy
We may modify this notice from time to time and will post the most current version online. If we make significant changes to our Privacy Policy, we will communicate these changes appropriately.
Last updated: March 2024