TELUS Health MyCare Wellness Privacy Commitment

 

Effective as of September 8, 2022. 

TELUS Health MyCareTM Wellness is a virtual platform that enables Users to access wellness workshops, webinars, tools and resources to help manage their wellbeing. 

We are passionate about the protection of your Personal Information and committed to respecting your privacy. 

TELUS Health MyCare Wellness policy to protect your privacy

Here’s the summary:

By accessing or using the TELUS Health MyCare Wellness Services, you understand that your information will be treated in accordance with this TELUS Health MyCare Wellness Privacy Commitment (“Privacy Commitment”). Our Privacy Commitment and practices are consistent with the 10 Fair Information Principles and we strive to apply the principles of Privacy by Design in the development and review of our products and services.

If you do not want us to collect, use or disclose your Personal Information in the ways identified in this Privacy Commitment, you may choose not to use TELUS Health MyCare Wellness Services.‬‬‬‬‬‬‬‬‬‬‬‬‬‬

Here’s the detail:

We have developed this Privacy Commitment to provide you with specific details about how TELUS Health MyCare Wellness collects, uses, discloses and stores your Personal Information when you use the Wellness Platform (defined below) or otherwise interact with us. This Privacy Commitment reflects the requirements of applicable Canadian privacy legislation, including provincial and federal privacy laws, and our own continuing commitment to privacy. 

Definitions

Attendee - A User, as defined below, who attends a live wellness workshop or session. 

Personal Information - Any information about an identifiable individual, other than business contact information used to contact the individual in their business or professional capacity. Personal Information includes your TELUS Health MyCare Wellness account profile. Personal Information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.

Submissions - Reviews, questions, comments, suggestions, ideas or similar information shared by a User through the Wellness Platform in connection with the Wellness Services, including that which is shared by an Attendee during a live wellness workshop and/or session. Submissions may be shared with other Users: please review the ‘Sharing and Disclosure of Personal Information’ section of this Privacy Commitment and the ‘Submissions’ section of the TELUS Health MyCare Wellness Terms and Conditions for more information.

TELUS Health MyCare - The operational name used herein for TELUS Health Solutions Inc. and may also be referred to synonymously as "we", "us", "our" or "TELUS".

TELUS Family - In this Privacy Commitment, “TELUS Family” means TELUS Communications Inc. and its subsidiary companies and corporate affiliates, as they may exist from time to time.

User - An individual who uses or registers to use the Wellness Services, including Attendee(s) as defined above.  

Wellness Platform - The TELUS Health MyCare online Wellness Platform, including through the TELUS Health MyCare Wellness website. 

Wellness Services - TELUS Health MyCare Wellness is a virtual platform that enables Users to access live wellness workshops; live group coaching / progress check in sessions; on-demand wellness workshops; and other potential membership perks (collectively  the “Wellness Services” or “Services”) through the use of the Wellness Platform. Use of the service is subscription based and a valid credit card will be required. 

you - An individual User, who uses or registers to use the Wellness Services.

Accountability

Here’s the summary:

TELUS Health MyCare Wellness has overall responsibility for protecting the privacy of the Personal Information we collect about you through the Wellness Services, and we are directly accountable to you with respect to the handling of that information. 

Here’s the detail:

The Wellness Services are available in Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island, Saskatchewan, Northwest Territories, Nunavut, and Yukon. In these provinces and territories, TELUS has overall responsibility for protecting your Personal Information and we are directly accountable to you. 

The Wellness Services are not offered in Quebec.  

Consent

Here’s the summary:

When you access or use the Wellness Services, you consent to our collection, use, disclosure, and storage of your Personal Information as described in this Privacy Commitment.‬‬‬‬‬‬

You can withdraw your consent at any time, subject to limited restrictions.‬‬ 

Here’s the detail:

When you use the Wellness Services, you consent to our collection, use, disclosure, and storage of your Personal Information in accordance with this Privacy Commitment.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

You can withdraw your consent to the collection, use and disclosure of your Personal Information, subject to our legal or contractual restrictions. However, if you refuse to provide certain information or withdraw your consent, this may limit our ability to provide you with the Wellness Services. 

If you request deletion of your account, we may retain certain information to meet our legal or regulatory obligations. Please review the ‘Retention’ section below for more information on our retention practices.  

To collect, use or disclose Personal Information outside of the purposes contemplated in this Privacy Commitment, we will seek additional consent from you. 

Individuals under the age of majority in their jurisdiction of residence may not create an account with TELUS Health MyCare Wellness.

Collection and Use of Personal Information

Here’s the summary:

We collect only the Personal Information required for us to establish and maintain a relationship with you, to provide the Wellness Services, to develop, enhance or market our products and services (including to send you relevant information about products and services that may be of interest to you), and to maintain and improve the security and functionality of the TELUS Health MyCare Wellness Platform.‬  

We collect Personal Information to set up an account for you on the TELUS Health MyCare Wellness Platform so that you can access and use the Wellness Services.

We also collect other information from you as you use the Wellness Services:

‬‬‬‬‬‬‬We may use Personal Information to send you relevant marketing messages. You can opt out of receiving marketing messages at any time.

Here’s the detail:

We only collect and use Personal Information for the following purposes:

To establish our relationship with you 

TELUS Health MyCare Wellness Account Creation: In order to use the Wellness Services, you will need to create an account on the Wellness Platform by providing the requested Personal Information, including your name, email address, Wellness Platform password,* payment information, country, and province/territory of residence or postal code. 

The Wellness Services are subscription based; therefore, payment information is collected upon account creation. 

The location information you provide will be used to verify that you are using the Services in a province or territory within which the Services are offered, as well as sales tax remittance.

*A tip on good password practices: 1) do not share your password with others; 2) use a unique password for the Wellness Platform - don’t reuse the same password from other sites that you use; 3) use a strong password.  

To provide you with the Services and maintain our relationship with you 

Wellness Services, Including Live Workshops and Sessions: Your User account  will be used to enable you to sign up to attend live wellness workshops and sessions, keep track of the workshops or sessions you have attended or viewed, view on-demand/recorded wellness workshops or sessions; and other Service-related account activity. 

In order to attend live wellness workshops and sessions, you will be required to provide your name and email address in order to use the video conferencing service. Attending a live workshop or session allows you to communicate directly with the instructor and other Attendees. Live workshops and sessions will be recorded and posted on the Wellness Platform for future on-demand review by other Users. 

Please review the ‘Sharing and Disclosure of Personal Information’ and “Retention and Requesting Deletion of your Personal Information” sections below for more information.

Service Messages: We may contact you to provide you with helpful information related to the Services, such as to advise you of payment processing, workshop/session reservation confirmations and reminders, updates to or information about our services, to respond to your inquiries, and other important information or updates. 

Payment Processing: We collect your payment information such as your billing name, payment method, payment card number, CVV code and payment card expiry date. This information is used to process your payments. We use a third-party service provider who is Payment Card Industry Data Security Standard (PCI DSS) compliant to facilitate secure payment processing.

Compliance with Applicable Laws and Regulations: For example, we will use your province or territory of residence to remit sales tax to the appropriate provincial or territorial government. 

Providing Technical Support: Personal Information may be required by or accessible to technical support staff in order to resolve technical issues. Where possible, our support team will resolve issues without viewing Personal Information. 

To develop, enhance or market our products and services

Developing and Enhancing our Services: We analyze actions you take on the Wellness Platform to enhance your experience and better understand what programs or services to provide. This information is not identifiable. For example, when you use a Service on the Wellness Platform, a user event is captured under a unique, randomly generated identifier that cannot be linked back to you. This helps us determine successful implementations of features and guides us towards improvements. 

Satisfaction and Experience Surveys and Questionnaires: Your name and email address may be used by us to contact you regarding your experience when using the Services. We may ask for additional information to follow up. We may share this information with a third-party to address an issue or concern and to improve our service offerings.

Sending Marketing Communications: Your contact details, including your name and email address, may be used so that TELUS and the TELUS Family  can provide you with news and offers by email about TELUS and/or our third-party partners. These communications may be tailored based on data in your account profile and Wellness Platform activity. We may send you offers for a TELUS or TELUS Family service you may not currently subscribe to, or send you offers for a TELUS and/or TELUS Family third-party partner that may be of interest to you. For example, a company that offers fitness or lifestyle services.

We may use your email address to digitally deliver ads about our services and offers on third-party websites and apps where we purchase advertising from our partners. We only share anonymized and aggregated information with our third-party partners.

You can opt out of receiving marketing messages from us at any time by following the unsubscribe instructions included in each of our marketing messages or by contacting us as set out below.

To maintain the security and/or functionality of the TELUS Health MyCare Wellness Plan Website  

Visiting the Wellness Platform: In general, you can visit our website without telling us who you are or submitting any Personal Information. However, we collect the IP (Internet protocol) addresses of all visitors to our website and other related information such as device type, page requests, browser type, operating system, the date and time the website accesses our servers, and average time spent on our website. We use this information to help us understand our website activity and to monitor and improve our website. We also use your IP address to help ensure a secure experience and detect anomalous behaviour.

Device Information: As with many applications, certain limited technical data is required for theTELUS Health MyCare Wellness Plan website to function. The information we collect includes information about your device and operating system, such as the type of browser and operating system, unique device identifier, IP address, language settings, and the date and time the website accesses our servers. This information is used to deliver content appropriate for your browser’s capabilities, to deliver push notifications, for debugging and to help ensure a secure experience and detect anomalous behaviour in order to protect Personal Information from unauthorized access. 

Platform Usage Information: We may collect and analyze information about the actions you take on the Wellness Platform to enhance your experience and better understand what care programs or services to provide. 

Cookies: We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept first-party cookies used for the purpose of authentication, you will not be able to login to the TELUS Health MyCare Wellness Plan platform. Please see our Cookies Notice for information on our use of Cookies.

De-Identification and Aggregation 

De-Identifying and Aggregating Information: We may de-identify or aggregate your Personal Information such that it cannot reasonably be associated with you for the following purposes: 

  1. To protect your privacy and the security of your Personal Information;

  2. To conduct analytics and/or research in a privacy protective manner to:

    1. better understand and improve Wellness Services; 

    2. To operate and expand our business opportunities; and

    3. To improve and expand Wellness Services.

We may share such aggregated de-identified information or insights with our partners to assist in research, planning, or product and service development. 

For the purposes of disclosing your personal information as stated in the “Sharing and Disclosure of Personal Information” section below.  

Sharing and Disclosure of Personal Information

Here’s the summary:

By attending a live workshop or session you acknowledge and accept that the Submission(s) you voluntarily share during a live workshop may be shared with other Users. Therefore, we advise you to carefully consider what information you share during a live workshop or session prior to doing so.

We will not disclose your Personal Information for any purpose other than what has been outlined in this Privacy Commitment or as permitted under applicable law unless we obtain your consent. We disclose only the limited amount of Personal Information reasonably necessary to meet these purposes. 

We may share your Personal Information with our service providers who are contracted to perform services or functions on our behalf where they require the information to assist us in serving you. We use contractual controls to protect this information and limit its use to what is necessary for the service provider to perform the service.

We do not sell your Personal Information to any third parties.

Here’s the detail:

We may share or disclose Personal Information for the following purposes:

Other Users: If you attend live wellness workshops and/or sessions, you will be required to provide your name and email address in order to use the video conferencing service. The name that you enter will appear in the chat window and will be visible to all Attendees and the instructor. Therefore, you may consider using only your first name, an initial, or a tasteful pseudonym when joining the video workshop. your email address will not appear in the chat window. 

If you make a Submission during a live workshop or session (e.g.  by speaking while unmuted or writing in the chat window), you acknowledge and accept that your Submission, which may include your Personal Information, is shared by you on a voluntary basis and will be disclosed to instructors and other Attendees. 

Live workshops and sessions will be recorded and posted to the Wellness Platform for future on-demand review by other Users; therefore, your Submissions may also be shared with other Users. For example, if you write a Submission in the chat window which is subsequently read aloud by the instructor, that Submission will be disclosed to other Users. The chat window itself is not visible in the recording. 

You are fully responsible for the content of your Submissions. Therefore, we advise you to carefully consider what information you share during a live workshop or session prior to doing so. 

If you have any questions or concerns, please contact mycareprivacy@telus.com.   

Service Providers: We may share Personal Information with our suppliers, agents or other organizations or individuals who are contracted to perform services or functions on our behalf, where they require the information to assist us in serving you. For example, we may use service providers to process payments, provide video conferencing services, host our website and store and dispose of information on our behalf. We strive to minimize the amount of Personal Information that we share with our service providers and partners and require that it not be used for any other purpose.

Within the TELUS Family: Your name and email address may be shared within the TELUS Family and matched to your existing TELUS customer profile (if applicable) to identify other services that you have with the TELUS Family. This information may be used to:

Disclosures Required or Permitted Under Law: We may disclose Personal Information to the extent necessary where we are required or permitted under applicable law. We or our service providers will also share Personal Information with law enforcement, courts, other government agencies or other parties if we are required to do so to meet our legal and regulatory requirements in the jurisdictions in which we or our service providers operate.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of TELUS Health MyCare Wellness or as part of a corporate reorganization or other change in corporate control.

Third Party Links: The TELUS website and/or Wellness Platform may contain links to other websites or platforms that TELUS does not own or operate. Also, links to the Services may be featured on third party websites or platforms as advertisements. Except as provided in this Privacy Commitment, we will not share Personal Information with these third parties without your consent. We provide links to third party websites or platforms as a convenience to our users. These links are not intended as an endorsement of, or referral to, the linked websites or platforms. The linked websites or platforms have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites or platforms, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use, disclose, secure and otherwise handle Personal Information.

Access, Corrections, and Accuracy of your Personal Information

Here’s the summary:

You can request access to or correction of your Personal Information by contacting us at mycareprivacy@telus.com. We rely on you to keep your Personal Information up-to-date and accurate so that we can serve you.

Here’s the detail:

Accessing your Personal Information

You may request access and corrections to the Personal Information we hold about you at any time, subject to limited exceptions. Upon written request, we will also provide you with a list of individuals or entities (e.g. service providers) with whom we have shared or disclosed your Personal Information, if applicable. 

We rely on you to ensure that the Personal Information you provide through the Wellness Platform is accurate, complete and up-to-date. You are welcome to make changes or request deletions or corrections to Personal Information we collect about you at any time by updating your account profile on the Wellness Platform or by contacting us at mycareprivacy@telus.com.

For a copy of your Personal Information, please contact us at mycareprivacy@telus.com. We will take reasonable steps to verify your identity before granting access or making corrections. In addition, your right to access or correct your Personal Information is subject to certain legal restrictions.

Please contact mycareprivacy@telus.com for additional information.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

Storage and Location of your Personal Information

Here’s the summary:

Personal Information collected by TELUS Health MyCare Wellness will be stored and processed in Canada or other countries. 

Here’s the detail:   

Personal information collected by TELUS Health MyCare Wellness will be stored and processed in Canada or other countries. In either case, the information is protected with appropriate security safeguards, but may be available to foreign government agencies under applicable law. In particular, your personal information may be stored in the cloud, which may include transfers of data outside of Canada. 

Where appropriate, we use de-identification and other means to protect and minimize the amount of Personal Information we transfer. We also employ contractual controls to protect Personal Information in the event that we use a service provider. 

Retention and Requesting Deletion of your Personal Information

Here’s the summary:

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Commitment or as required to meet legitimate business, legal, or regulatory requirements.

Here’s the detail:

We will retain your Personal Information only for as long as is necessary to fulfill the purposes described in this Privacy Commitment or as required to meet legitimate business, legal, or regulatory requirements. 

Live workshops and sessions will be recorded and posted on the Wellness Platform indefinitely for future on-demand review by other Users. Please review the ‘Sharing and Disclosure of Personal Information’ section of this Privacy Commitment and the ‘Submissions’ section of the TELUS Health MyCare Wellness Terms and Conditions for more information.

If you have any questions or concerns, please contact mycareprivacy@telus.com.    

At your request, we will delete your Personal Information unless we are required to retain it to meet legitimate business, legal, or regulatory requirements. Please send your request to mycareprivacy@telus.com.   

Despite a request for deletion, we will retain de-identified information and continue to use this information in accordance with this Privacy Commitment and the TELUS Health MyCare Wellness Terms and Conditions.

Safeguards

Here’s the summary:

At TELUS, we understand that data security is a critical priority and we are committed to safeguarding your Personal Information. That is why we maintain a comprehensive information security program, employing a variety of security measures. 

Here’s the detail:

TELUS has a comprehensive information security program that includes administrative, technical and physical safeguards to protect against  unauthorized access, use, loss, modification, and disclosure of Personal Information in our custody or control. 

We understand that data security is a critical issue, and we are committed to safeguarding the Personal Information in our custody or control. We have implemented a comprehensive information security program that includes written policies and procedures, and security controls, as well as reasonable administrative, technical and physical safeguards, in an effort to protect against unauthorized access, use, loss, modification, and disclosure of Personal Information in our custody or control.

Our team members must complete privacy and security training before they have access to any Personal Information, and they must complete annual privacy and security training for ongoing access to Personal Information.

TELUS takes steps to ensure that the security policies, procedures, and controls of our service providers meet industry and TELUS best practices and are regularly tested.

Please keep in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you provide to us, but we can assure you that we will use reasonable and appropriate security controls.

It is important for you to play an active role in the protection and safeguarding of your Personal Information, and to guard your privacy when you are online. If the TELUS website or Wellness Platform contains links to other websites, this Privacy Commitment does not govern those websites. You should read their privacy policies and make an informed decision about whether you want to use those websites or their services.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

Changes to this Privacy Commitment

Here’s the summary:

We may make changes to this notice, and we will notify you of the changes to our information practices.

Here’s the detail:

This Privacy Commitment may be updated from time to time to reflect changes to our practices. Any notices regarding modifications to this Privacy Commitment will be in written form and provided to you on the TELUS website. 

If any changes to this Privacy Commitment are significant, we will provide a more prominent notice (including email notification, if appropriate).

We encourage you to periodically review this Privacy Commitment for the latest information on our privacy practices and to contact us if you have any questions or concerns.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

Questions, Complaints, and Contact

Here’s the summary:

You can always reach us at mycareprivacy@telus.com if you have privacy questions, concerns or complaints.

Here’s the detail:

Please contact us if:

Contact Information:

 

Mailing Address: 

TELUS Health MyCare Wellness

c/o Privacy Officer

2280 – 510 West Georgia Street

Vancouver, BC

V6B 0M3 

Email: mycareprivacy@telus.com 

If you wish to access, update, and/or correct inaccuracies in your Personal Information, please contact us at mycareprivacy@telus.com. 

If you have concerns with our Privacy Commitment or privacy practices, we encourage You to first bring your concerns to us at mycareprivacy@telus.com. 

You may also seek advice from the Office of the Privacy Commissioner of Canada or the provincial Privacy Commissioner having jurisdiction, and, if appropriate, file a written complaint with the Commissioner's office. To contact the applicable privacy commissioner, please visit the following websites: