Privacy Policy

POLICY

Your privacy and personal information are very important to us. Our website and all pages thereof, including the website through which you accessed this Privacy Policy (collectively, the “Website”) are each operated by Tactus Therapy Solutions Ltd. (“Tactus” or “we” or “We” or “our” or “Our”). The personal information that Tactus collects about you (“You”, “you”, “Your”, “your”, or the “User”) is managed in accordance with this Privacy Policy (“Policy” or “Privacy Policy”). Tactus makes available cloud-based web application software or mobile application software (the “Software”), including but not limited to Tactus’ mobile and web applications for speech therapy and Tactus’ Virtual Rehab Center. This Privacy Policy applies to the collection, use and disclosure of your personal information, including personal information relating to and collected in connection with your use of the Software and any and all other related services offered by Tactus (the “Services”).

BY SIGNING UP TO USE THE WEBSITE OR THE SOFTWARE, BY CREATING AN ACCOUNT ON THE WEBSITE OR THE SOFTWARE, OR BY MAKING ANY OTHER USE OF THE WEBSITE, THE SOFTWARE OR ANY OTHER SERVICES, YOU AGREE AND CONSENT TO THE PRACTICES AND POLICIES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE TO THE PRACTICES AND POLICIES DESCRIBED IN THIS POLICY, DO NOT SIGN UP TO USE THE WEBSITE OR THE SOFTWARE, CREATE AN ACCOUNT ON THE WEBSITE OR THE SOFTWARE, OR OTHERWISE SIGN UP FOR THE SOFTWARE OR OTHERWISE USE THE WEBSITE, THE SOFTWARE, OR THE SERVICES.

The Services, the Software, and our Website are available only to, and may only be used by persons who can enter into legally binding contracts under applicable law. Without limiting the foregoing, the Services, Software, and our Website are not available to minors. If you are under the age of majority in your jurisdiction, please do not use the Services, Software, or our Website.

Tactus provides the Services to different types of Users that may use Tactus’ Software and Services:

• “Professional User” is a User who is a professional speech therapist or pathologist or other professional who uses the Software to provide speech therapy to patients;
• “Patient User” is a User who is a patient of and is associated with a Professional User, who receives speech therapy from Professional Users; and
• “Home User” is a User who accesses and receives Services directly from Tactus, and not from a Professional User.

1. WHAT DO YOU MEAN BY “PERSONAL INFORMATION”?

Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider personal information to include information that has been de-identified so that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer. Your name, e-mail address, and IP address are all examples of data that may be personal information. “Cookies” may or may not be considered personal information, depending on the law applicable in your jurisdiction and the nature of the cookie. Please see our Cookie Policy below to review detailed information about our use of cookies and similar technology.

We collect, use, and disclose personal information to operate our business and as required by law. Personal information is information about an identifiable individual, or any information that identifies you as an individual, as defined in the Personal Information Protection and Electronic Documents Act and in any applicable provincial legislation, including the Alberta Personal Information Protection Act (PIPA). It includes information that you provide to Tactus or that Tactus collects from any third party.

2. CHANGES TO PRIVACY POLICY

This Policy describes our current privacy practices. We update this Policy on an ongoing basis to ensure consumers, applicants, customers and service providers, are aware of updates to our privacy practices, to streamline those practices and to comply with applicable laws. Please visit the Website regularly for updates.

Tactus may, at any time and from time to time at its sole discretion, update, revise, supplement, replace, and/or otherwise modify this Policy and/or impose new or additional rules, policies, terms, or conditions on You. Such updates, revisions, supplements, replacements, modifications, and additional rules, policies, terms, and conditions (collectively referred to as “Revised Terms”) will be effective immediately upon the Revised Terms being posted to the Website or by Tactus otherwise making them available to You (as the case may be). Any continued use of the Website, the Services, and/or the Software following such posting of the Revised Terms to this Policy or by Tactus otherwise making them available to You (as the case may be), will be deemed to constitute acceptance of and consent to the Revised Terms.

3. INFORMATION WE COLLECT, AND LIMITING COLLECTION

Tactus collects information about identifiable individuals. Except where information is required to fulfill an identified purpose, you get to decide what information you want to share with us. Tactus only collects such personal information as is reasonably necessary for Tactus to fulfill the purposes as set out in this Privacy Policy.

Through the Software and the Website, Tactus collects information about identifiable individuals (“Personal Information”) relating to use of the Software and any related Services by Users, which may include but may not be limited to the following information:

Professional Users

a) contact and biographical information that you provide to us, including your first and last name, and your email address in connection with creating and maintaining an account registered with Tactus or otherwise in connection with your use of features of the Software and any related Services;
b) information regarding your work and credentials, including workplace and type of facility;
c) patient information, including first and last name, date of birth, gender / pronouns, English comprehension level, and personal medical information including medical speech diagnosis, medical diagnosis, and date of onset of diagnosis / disorder;
d) therapy information including progress, goals, interests, dislikes, and assessment results relating to the therapy of your patients;
e) customized exercise information, including meaningful names, locations, phrases and related photos;
f) video and voice recordings of you and your patients;
g) information you provide directly to us when you request that we conduct a specific task on your behalf using the Services, or other information you provide when you communicate with us;
h) usage information, including the information created from your use of the Software, the Website, and related Services, including automatically collected online identifiers such as general geographic location, IP address, and details regarding your use of the Software, the Website, and the Services;
i) information that you provide to us for the purpose of obtaining or receiving updates about new services, and/or obtaining or receiving notifications; and
j) information about your online activity; for example, information about your web browser, Internet Protocol (IP) address, use of the Website, and history;

Patient Users

k) contact and biographical information that you provide to us, including your first and last name, your email address, your phone number, your gender / pronouns in connection with creating and maintaining an account registered with Tactus or otherwise in connection with your use of features of the Software and any related Services;
l) therapy information including progress, goals, interests, dislikes, assessment results relating to your therapy;
m) information you provide directly to us when you request that we conduct a specific task on your behalf using the Services, or other information you provide when you communicate with us;
n) usage information, including the information created from your use of the Software, the Website, and related Services, including automatically collected online identifiers such as general geographic location, IP address, and details regarding your use of the Software, the Website, and the Services;
o) information that you provide to us for the purpose of obtaining or receiving updates about new services, and/or obtaining or receiving notifications; and
p) information about your online activity; for example, information about your web browser, Internet Protocol (IP) address, use of the Website, and history;

Home Users

q) contact and biographical information that you provide to us, including your first and last name, your email address, your phone number, your date of birth, your gender / pronouns, in connection with creating and maintaining an account registered with Tactus or otherwise in connection with your use of features of the Software and any related Services;
r) therapy information including progress, goals, interests, dislikes, assessment results relating to your therapy;
s) customized exercise information, including meaningful names, locations, phrases and related photos;
t) information you provide directly to us when you request that we conduct a specific task on your behalf using the Services, or other information you provide when you communicate with us;
u) usage information, including the information created from your use of the Software, the Website, and related Services, including automatically collected online identifiers such as general geographic location, IP address, and details regarding your use of the Software, the Website, and the Services;
v) information that you provide to us for the purpose of obtaining or receiving updates about new services, and/or obtaining or receiving notifications; and
w) information about your online activity; for example, information about your web browser, Internet Protocol (IP) address, use of the Website, and history.

With respect to the Personal Information of any third parties that you may provide to Tactus in connection with your use of the Website, the Software, or other Services, including the Personal Information of your patients, you are responsible for ensuring that you have any such third party’s consent to the collection, use, and disclosure of their Personal Information in accordance with the terms of this Privacy Policy, and you hereby represent and warrant that you have such consent.

4. IDENTIFYING PURPOSES AND USE OF PERSONAL INFORMATION

We will clearly identify the purposes for which Personal Information is collected, used or disclosed prior to, or at the time of, collection. Personal Information submitted to us, whether through the Software, the Website, and/or any related Services, or otherwise, may be used by us for the purposes specified in this Privacy Policy, and you hereby consent to same. By registering to create an account with Tactus, by using the Software and any related Services, or otherwise using the Website, the Software, and/or the Services, you consent to the use of your Personal Information as indicated in this Privacy Policy.

Tactus may use your Personal Information to (and you hereby consent to each of the following uses):

a) process your applications for setting up an account with us or otherwise registering to use the Software, the Website, and any related Services;
b) provide, update, maintain, administer and operate the Software, the Website, and the Services and deliver and enable your use of the Software, the Website, and the Services, including the development of new product and service offerings;
c) provide the Services to you or other Users and customize and deliver the Services to you or other Users, including use for internal evaluation of User needs, evaluation of progress, customization of exercises, and exclusion of certain stimuli;
d) understand how you and our other users use the Services, the Website, and the Software in order to improve the Website, the Services and Software and our marketing efforts, and to develop tools and features through the use of other information to assess trends in use, search functionality, the Services, and other features of the Software and the Website;
e) inform you of other products, promotions, or services available from Tactus and its partners;
f) deal with inquiries, complaints, submissions and feedback relating to the Software, the Website, and the Services; and
g) manage, administer, maintain, service, and enforce our Privacy Policy and verify compliance with agreements between you and us relating to your use of the Software and related Services, or to otherwise comply with applicable laws and regulations.

Tactus may also anonymize, aggregate, or otherwise strip any Personal Information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purpose we deem appropriate.

We may use your Personal Information to contact you. Your Personal Information allows us to contact you by various methods, including mail, email, SMS message, app push notification, and telephone at the contact points you have provided to us. We will contact you to respond to your questions, proactively provide you with information about the Services that you use, inform you about the Website, the Software, and any related Services and to update you on changes to our Website, our Software, and any related Services. When you communicate online or by email, you should be aware that sending information over the internet is inherently insecure, as it can be intercepted or manipulated and retransmitted.

Personal Information that we collect may be uploaded, moved, stored, processed in, backed up and/or transferred between any of the countries in which we operate or may operate in order to enable us to collect, use, and/or disclose the Personal Information in accordance with this Privacy Policy. Your Personal Information may be uploaded, moved, stored, processed in, backed up and/or transferred in Tactus’s discretion in Canada or in jurisdictions other than Canada, including the United States, and you consent to the same. You also acknowledge and agree that your Personal Information may be transmitted, uploaded, or moved across international borders in Tactus’s discretion, and you consent to the same.

5. DISCLOSURE OF PERSONAL INFORMATION

Any Personal Information provided by you, or that is derived automatically by or through the Website, the Software, and related Services is not sold, rented, or shared by us with any third party without your consent, except in the circumstances described in this Privacy Policy. We may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors, to the extent that such disclosure is reasonably necessary for the purposes set out in this Privacy Policy.

You acknowledge and agree that We may use and/or disclose your Personal Information, without notice, if legally permitted to do so according to the relevant provisions of the Canada Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5, and/or any other relevant privacy enactment (collectively, the “Privacy Acts”). The Privacy Acts may permit the use and/or disclosure of Personal Information without notice if, for example: (a) the Personal Information could be useful in the investigation of a contravention of the laws of Canada, a province or a foreign jurisdiction; (b) the Personal Information is used or disclosed for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual; and (c) the Personal Information is disclosed to comply with the edicts of the law, or to comply with a subpoena or warrant issued or an order made by a court. In any event, Tactus may release personal information when it believes in good faith that such release is necessary to: (i) comply with any law, order, rule, or regulation; (ii) enforce or apply this Privacy Policy or the Terms and Conditions or any other policy of Tactus; and (iii) protect the rights (including intellectual property rights), property, or safety of Tactus, its members, employees, contractors, or others.

We may disclose your Personal Information if Tactus or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets, in accordance with applicable law.

You also acknowledge and agree that we may engage other companies and individuals (“Third Party Service Providers”) to perform some of the foregoing on our behalf, including service providers selected by you in your use of the Website, the Services, and the Software. We may disclose your Personal Information to one or more Third Party Service Providers who provide services for us or perform Services on our behalf. We make every effort to ensure any company with which we may share Personal Information protects that Personal Information and data in a manner similar to this Privacy Policy and to limit the use of such Personal Information to the performance of the services being provided to Tactus.

For example, a Third Party Service Provider may:

• host and administer our Website, process and store data, and fulfill similar technology-related functions on our behalf or carry out any other purpose described in this Privacy Policy; and/or
• provide analytics services to help us understand how our Services are used, and as otherwise required by applicable law, including confirming your identity to comply with “know your client” obligations.

These Third Party Service Providers may be provided with access to your Personal Information for such purposes. We make commercially reasonable efforts to ensure that all Third Party Service Providers acting on our behalf are obligated to provide a comparable level of protection for your Personal Information to the level of protection that we provide.

6. CONSENT

If you apply for registration of an account or otherwise apply to use the Software, the Website, and the Services, provide Personal Information through the Services, or provide your Personal Information to us in any other way, you acknowledge your consent to the collection, use, and disclosure of your Personal Information as set out in this Policy and applicable laws. If we want to use your personal information for a purpose that was not disclosed at the time of initial consent, consent will be sought at the time of this new purpose.

Withdrawal of consent. You may withdraw your consent to the collection, use, and disclosure of your Personal Information as set out in this Privacy Policy at any time. Withdrawal of your consent to the collection, use, and/or disclosure of your Personal Information as set out in this Privacy Policy may result in all or part of the Software, the Website, and/or related Services being unavailable to you. If you withdraw your consent to the collection, use, and/or disclosure of your Personal Information as set out in this Privacy Policy, Tactus reserves the right to limit your access or prevent you from accessing the Software, the Website, and/or any related Services.

Updating consent. Subject to legal and contractual restrictions, you can, with reasonable notice to us, update your consent or withdraw your consent to the collection, use, and disclosure of your Personal Information for specific purposes, other than the collection, use, and disclosure which is required for us to maintain your account with us and to provide Services that you sign up for and for which you were approved.

7. ACCURACY

We take steps to ensure that your personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. If you believe that the personal information we have about you is not accurate or is incomplete, please contact us by updating your information through our Services or the Software, or by email at privacy@tactustherapy.com. If you change your email address, you are required to update your information with us.

8. SAFEGUARDS

We use a variety of procedures and practices appropriate to the sensitivity of personal information to protect against loss, theft, and unauthorized access. Access to your information is restricted to those individuals and parties who require access for the purposes set out in this Privacy Policy. For example, Tactus may secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When Personal Information is transmitted to other web sites or third parties for the purposes specified above, we may also, or in the alternative, protect it through the use of encryption, such as by way of the Secure Socket Layer (SSL) protocol.

Personal Information may be accessed by persons within our organization, or our Third Party Service Providers, who require such access to carry out the purposes described in this Privacy Policy or otherwise permitted or required by applicable law. Personal Information we collect is managed from our offices in Vancouver, British Columbia.

Even though we have taken steps to help protect the Personal Information in our control, you should know that we cannot fully eliminate security risks associated with Personal Information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any Personal Information you provide to us. While we take all reasonable measures to protect data, there is always inherent risk when providing Personal Information. The transmission of Personal Information and data over the Internet is inherently insecure, and there are no security systems that are completely safe or fool-proof against hacking or tampering.

You are solely responsible for controlling access to your account(s) associated with Software, and maintaining the confidentiality and security of your accounts and related password information. You are entirely responsible for all activities that occur on or through your account(s), and Tactus shall not be responsible for any losses arising out of the unauthorized use of any of your account(s) associated with the Software.

Personal Information is not kept by Tactus for any longer than is necessary for the purposes identified in this Privacy Policy. Personal Information that is no longer required to fulfil the purposes identified in this Privacy Policy will be destroyed, erased, or made anonymous.

9. THIRD PARTY POLICIES AND LINKS

The Website may contain links to other third-party sites that are not governed by this Privacy Policy. Our Privacy Policy will no longer apply once you leave our Website and visit another website. Additionally, we are not responsible for the privacy practices employed by third-party websites. Therefore, we suggest you examine those sites’ privacy statements to learn how your information may be collected, used, shared and disclosed. Tactus does not endorse, approve of, verify, attest to, or offer any representation or warranty with Tactus as to, the accuracy of the content of such websites that are linked or Internet resources that are linked from the Website. If you decide to leave the Website and access these third-party sites, you do so at your own risk.

Any links from our Website to other websites, or references to products, services or publications other than those of Tactus, do not imply the endorsement or approval of such websites, products, services or publications by Tactus.

10. COOKIES

A cookie is a small computer file or piece of information that may be stored on your computer’s hard drive when you visit our Website. We may use cookies to improve our Website’s functionality and, in some cases, provide visitors with a customized online experience.

Cookies are widely used, and most web browsers are configured initially to accept cookies automatically. You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, that if you disable cookies, you may not experience the optimal performance of the Website, our Services, and our Software.

If you do not wish to receive cookies, or want to be notified of when they are placed, you may set your web browser to do so, if your browser so permits. If you wish to delete cookies, you may set your web browser to do so, if your browser so permits. You acknowledge and agree that if cookies are turned off or deleted, you may not be able to view certain parts of the Website or use certain of certain Services available through the Website or certain features or functionalities thereof.

You can see our full cookie policy, and manage your cookie preferences here: Cookie Policy

11. OPENNESS, INDIVIDUAL ACCESS, AND CHALLENGING COMPLIANCE

You can write to Tactus to request access to the Personal Information we have on file for you. We will provide you with the Personal Information we have, subject to certain considerations specified by law. If you wish to request access to the Personal Information that we have on file for you, or request that such Personal Information be corrected, please contact Tactus’s designated Privacy Officer at privacy@tactustherapy.com.

Tactus welcomes your comments regarding this Privacy Policy. If you would like more information on this Privacy Policy or Tactus’s organizational privacy policies, or if believe that Tactus has not adhered to the terms of this Privacy Policy, please contact Tactus’s designated Privacy Officer at privacy@tactustherapy.com. We will use commercially reasonable efforts to promptly identify and remedy any failure by Tactus to adhere to the terms of this Privacy Policy.