Privacy Policy

Portia is committed to maintaining the integrity and privacy of its users, including you (you). This Privacy Policy explains how Portia collects, uses, shares, retains and protects personal information that may identify you or other individuals, including in connection with your use of Portia’s services (the Services), including its website at app.portiapro.com (the Website).

If you have an account with Portia, you may be permitted upload and submit information, data, comments, photos or other materials to the Website (collectively, Data).

Portia only collects, uses and discloses your personal information in order to develop and provide you and other Portia users with the services you request and improve your online experience. Portia only collects, uses, discloses and stores your personal information as described in this privacy policy (the Privacy Policy).

Your Acceptance of Privacy Policy

By agreeing to the Terms of Service, or by using the Website and/or the Services, you signify your acceptance of this Privacy Policy.

If you do not agree to the terms of this Privacy Policy, please do not use the Services. Your continued use of the Services following the posting of changes to this Privacy Policy will mean that you accept those changes.

You cannot open an account with Portia if you are under the age of 18. If you are under 18 year of age, please do not attempt to register for Portia or send any information to Portia. If Portia learns that information from a person under the age of 18 has been submitted to Portia or uploaded to the Website, Portia will delete the information as soon as possible.

How Portia Collects Personal Information

Personal information you provide

Portia collects your personal information through the Website when you choose to provide such information as discussed below. When you choose to share it, Portia may collect your e-mail address when you sign-up for a Portia account. As well, Portia collects your e-mail address when you contact Portia with any questions, comments, requests or feedback. Portia will collect your credit card information and billing address when you purchase certain of Portia’s services with your credit card or enter into certain agreements with Portia where it is necessary to complete a sales transaction on re-occurring basis.

Personal information obtained from administrators

In order to use the some of the Services, you must: (i) enter into a separate license agreement with Portia as an “customer” (an Administrator) to access and use the software underlying the Services for your commercial purposes and to allow certain third parties to access and use the software through the Services; or (ii) be invited to use the Services by Portia and/or an applicable Administrator and to set up an account with Portia.

If you are invited to use the Services by an Administrator, such Administrator will have provided to Portia your name and email address. If Portia collects any of your personal information from an Administrator, it will have entered into a contract with that Administrator which requires that Administrator to ensure, and provide assurances to Portia, that it has your consent to disclose your personal information to Portia. If any of your personal information has been provided to Portia by an Administrator, it will be used, disclosed and stored in accordance with this Privacy Policy, and it will be connected and linked with you, your account and your personal information you voluntarily provided to Portia.

If you want to know if Portia has obtained any of your personal information from an Administrator, or if you want Portia to stop using personal information collected from an Administrator, or if you want Portia to delete this personal information, you can contact Portia anytime as described in this Privacy Policy.

Personal information of third parties provided through use of the Services

Portia does not collect personal information about an Administrator’s individual patient(s) or personal health information about such individuals, including: information related to the physical or mental health of the individual, including information that consists of the health history of the individual’s family; the providing of health care to the individual, including the identification of a person as a provider of health care to the individual; the individual’s health number; that identifies an individual’s substitute decision-maker, parent or guardian (which Portia calls “Patient Data”).

Users of the Services, including Administrators, senior therapists, instructional therapists and parents or guardians of a patient of an Administrator, may input, submit and upload Patient Date to and through the Services. Every user of the Services enters into a contract with Portia which requires that user to ensure, and provide assurances to Portia, that it has the necessary consent to input, submit or upload any personal information to or through the Services, including any Patient Data, and that such disclosure in in compliance with all applicable laws, including the Personal Information Protection and Electronic Documents Act (Canada), the Personal Health Information Protection Act, 2004 (Ontario) and any similar laws governing the protection of personal information or personal health information. The applicable Administrator is responsible for the collection, use and disclosure of Patient Data and any collection, use or disclosure of Patient Data is not the responsibility of Portia and is not covered by this Privacy Policy. Any use of Patient Data by an applicable Administrator and its authorized and invited users of the Services is subject to the privacy policy of the Administrator and is not governed by this Privacy Policy.

Personal information Portia obtains through your use of the Website

Each time you visit the Website, Portia may collect information, including some of your personal information, through your IP address, and by using cookies and web beacons, as described below.

  • An Internet Protocol (“IP”) address is a number that automatically identifies the computer/machine you have used to access the Internet. Portia uses your IP address to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. Portia may use IP addresses to conduct Website analyses and performance reviews and to administer the Website.
  • A “cookie” is a piece of information that a website transfers to a user’s computer for purposes of storing information about a user’s preferences. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer and can qualify as personal information. Portia uses cookies to provide useful features when you visit the Website. You can set your browser to refuse cookies, but some portions of the Website may not work properly if you refuse cookies.
  • A “web beacon” is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of websites. Some web beacons may be unusable if you elect to reject their associated cookies. Some of the Website’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about your use of the Website.

How Portia Uses Personal Information

Personal information you provide

Portia uses the personal information you voluntarily provide in order to address your requests for information about Portia’s products or services (including the Services), to maintain your account and your profile, and to offer and deliver a variety of products and services to certain users of the Website and to third parties as set out in this Privacy Policy, as described below. Portia will not use your personal information other than as specified in this Privacy Policy.

  • When you contact Portia with questions, comments, requests or feedback, Portia will use your name and e-mail address to communicate with you and respond to you.
  • When you purchase certain Services with your credit card, Portia uses your name, credit card information and billing address to process and complete the sales transaction on a re-occurring basis, but will not retain this credit card and billing information longer than is necessary to process or complete the transaction. Portia may also use your personal information to contact you to confirm your purchase and provide you access to the Services purchased.
  • If you have created an account, Portia will use your e-mail address to identify you and maintain your account in order to provide you with the Services by using your e-mail address to link to all of Data provided to Portia or an Administrator through your account. Portia retains all of this information (including your personal information) for as long as you have a Portia account.
  • If you have created an account, Portia may also use your e-mail address to communicate with you by e-mail about Portia’s Services, certain changes to Portia’s Services, certain changes to the Website terms of use, your use of the Services, or Portia’s promotional or marketing efforts.

In some cases, Portia may remove personal identifiers, such as your name, from your personal information and maintain the information in non-personalized, aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information.

Personal information Portia collects automatically (cookies and web beacons)

Portia uses cookies and web beacons to improve your online experience when you visit the Website by recognizing you when you return to the Website, and studying how you navigate through the Website and which products you request in site searches so that Portia can improve the design, content and function of the Website and the Services. Portia may hire third-party service providers to assist in the collection and analysis of cookies and web beacons, but none of your personal information is disclosed to these third party service providers.

Personal information Portia collects from administrators

If Portia collects any of your personal information from an Administrator, Portia will use your e-mail address to identify you, maintain your account in order to provide you with the Services, and link to all of Data provided to Portia or an Administrator through your account.

Personal information about third parties provided through use of the Services

If any Patient Data is provided by users of the Services to or through the Services, only the applicable Administrator, and its authorized and invited users of the Services, will be able to access and use such Patient Data and only to the extent necessary to use the Services. Any use of Patient Data by an applicable Administrator and its authorized and invited users of the Services is subject to the privacy policy of the Administrator and is not governed by this Privacy Policy. Portia is not responsible for any use or disclosure of Patient Data by the applicable Administrator, and its authorized and invited users of the Services.

If any Patient Data is provided by users of the Services to or through the Services, Portia will not have any access to such Patient Data and will only obtain access to such Patient Data in anonymous, aggregated form with the express consent of the applicable Administrator (who remains at all times responsible for the collection, use and disclosure of such Patient Data). Portia may use this anonymous, aggregated statistical information in order to improve the online experience for users of the Services and studying how you use the Services so that Portia can improve the design, content and function of the Services and the Website.

How Portia Shares Personal Information

Portia will not sell, rent, license, or trade your personal information or Patient Data with third parties for their own direct promotional or marketing use unless Portia receives your express consent to do so. Unless you provide consent to do so, Portia will not share your personal information other than as specified in this Privacy Policy.

Disclosing personal information to other Portia users

Portia will not disclose your name or email address to third parties other than to the applicable Administrator. Portia will only disclose your name or email address to the applicable Administrator in order to allow such Administrator to use the Services and identify what users have registered for the Services through its account, and how such users are using the Services.

Portia will never disclose Patient Data. Portia is not responsible for any disclosure of your name or email address or any Patient Data to any third party by an Administrator or another user of the Services. Any such disclosure is not permitted by Portia or governed by this Privacy Policy. For more information about the use of personal information or Patient Data by any particular Administrator or user of the Services, you should contact that Administrator or user directly.

Sharing personal information with third parties assisting Portia

Portia may share your personal information with trusted third parties that work with, or on behalf of, Portia to process information, including payment processing companies and information processing companies. These companies do not have any independent right to use, share, disclose or retain your personal information.

Sharing anonymous information with third parties

Portia may remove personal identifiers, such names, from personal information and Data and maintain the information in non-personalized, aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Portia may give or sell such anonymous, aggregated group data to Portia’s affiliates, business partners, service providers and vendors; if it does so, Portia will not disclose any personal information. Unless Portia seeks and receives your express approval, Portia will not share your personal information with third parties (other than other Portia users as set out in this Privacy Policy).

Disclosing personal information under special circumstances

Portia may disclose information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise Portia’s legal rights or to defend against legal claims, or if Portia believes it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

If Portia is to be sold, merged or amalgamated or is to sell or dispose of substantially all of its assets, your personal information may be transferred to a potential purchaser if, and to the extent, necessary for the purposes of deciding whether to proceed with the sale and completing the sale. If such a sale, merger, acquisition or disposal is completed, the purchaser may use and disclose your personal information only to the extent described in this Privacy Policy if the information relates solely to the carrying on of the business or activity or the carrying out of the objects for which the sale, merger or acquisition took place.

How Portia Stores Personal Information

Portia will store and retain your name, e-mail address for as a long as you maintain a Portia account so that Portia can offer you and its other users the services you and they want and expect to receive from Portia.

Portia will only store payment information (including credit card information and the related billing address), if any is collected, for as long as is necessary to process and complete a transaction on a reoccurring basis.

If Portia has disclosed your personal information to a third party (including an Administrator) in accordance with this Privacy Policy, Portia has no control over, and is not responsible for, how long and how such third party stores that personal information.

Patient Data may be stored and maintained through the Services for as a long as the applicable Administrator maintains a Portia account and such Administrator decides and instructs Portia to store and maintain such Patient Data on the Services. Portia is not responsible for this storage and has no control over, and is not responsible for, how long and how an Administrator stores Patient Data. Portia does not have any access to any Patient Data except as described in this Privacy Policy.

Your Decisions about your Personal Information

Amending and updating your personal information and your consents

By sending Portia an e-mail to info@portiapro.com or by mailing Portia at Portia International Inc. 50 Steacie Dr. Ottawa, Ontario K2K 2A9 Canada or calling Portia at 1-855-297-6431 you can quickly, at no cost, and at any time:

  • ¥. review the personal information you provided to Portia;
  • ¥. withdraw your consent for Portia’s use and disclosure of your personal information;
  • ¥. update or amend your account information, including your name or e-mail address;
  • ¥. cancel your Portia account, as described below.

When inquiring about or updating your personal information, Portia may ask you to verify your identity before it can act on your request.

Cancelling your account

You can cancel your Portia account at any time by contacting Portia as shown above or by following Portia’s then current cancellation procedure set out on the Website. If you cancel your Portia account, all of your personal information will be removed from Portia’s databases as quickly as is reasonably possible and will no longer be used or disclosed by Portia. If you cancel your Portia account you will not be able to use any of the Services.

Referrals and Links

The Website may contain links to third-party websites that may offer information of interest. This Privacy Policy does not apply to those websites, and Portia recommends reviewing those websites’ privacy policies individually.

Security

Portia understands that storing data, including personal information and Patient Data, in a secure manner is essential.

Personal information, Patient Data and other data is stored using industry standard physical, technical, organization and administrative safeguards to secure data against foreseeable risks, such as theft, unauthorized use, access, disclosure, copying, destruction or modification. While Portia attempts to create a secure and reliable Website for users, the confidentiality of any communication or material transmitted to or from the Website or via e-mail cannot be guaranteed.

Portia limits access to your personal information within Portia to individuals on a need-to-know basis. Portia makes its employees, agents and contractors aware of the importance of protecting your personal information. Portia does not have, and does not give any of its employees, agents and contractors, access to any Patient Data except in anonymous, aggregated form in accordance with this Privacy Policy. Portia makes its employees, agents and contractors aware of the importance of protecting Patient Data.

Your personal information and Patient Data may be transferred, processed and stored on servers in countries outside of Canada, including the United States, and may therefore be subject to different laws than those applicable in Canada. While Portia undertakes to protect your personal information when it is transferred outside of Canada, the laws of other jurisdictions may require the disclosure of your personal information to governmental authorities under circumstances that are different than those that apply in Canada and are contemplated under this Privacy Policy.

Children’s Privacy Protection

Portia understands the importance of protecting the privacy of children in the interactive online world. The use of the Website and the Services are not designed for, or intentionally targeted at, anyone eighteen (18) years of age or younger. Users of the Services may collect and maintain, and input, submit and upload to the Services, Patient Data about people under the age of eighteen (18), but only with the express consent of such person’s parent or guardian. No one under the age of eighteen (18) should submit any personal information or Patient Data to Portia or the Website or to or through the Services.

Policy Updates

This Privacy Policy may be revised from time to time as Portia adds new features and services, as laws change, and as industry privacy and security best practices evolve. If Portia makes any change to this Privacy Policy regarding collection, use, disclosure or storage of personal information, Portia will provide advance notice on the Website. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Portia recommends that you check this webpage periodically in order to review the current Privacy Policy. You can tell if this Privacy Policy has changed by checking the effective date that appears at the bottom of this Policy.

Questions?

If you have any questions, inquiries or complaints about this Privacy Policy or about Portia’s handling of your personal information, please contact Portia as follows.

Portia International Inc.

50 Steacie Drive
Ottawa ON K2K 2A9
Canada

Attention: Privacy Officer

Telephone: 1-855-297-6431

E-mail: privacyofficer (at) portiapro (dot) com

Update

Privacy Policy last updated: April 14, 2017

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