ETA Support Privacy Policy

Please read this privacy policy carefully as it contains important information on how and why your personal information is collected and used in connection with your use of www.etaontario.ca (website) (“we”, “us”, “our”), as well as your rights in relation to your personal information. This privacy policy also contains important information about how to contact the administrators of this website if you have questions.

Data Protection Legislation

The collection and use of any personal information via this website is subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), the Ontario Personal Health Information Protection Act (PHIPA), the General Data Protection Regulation (EU) 2016/679 (GDPR), the UK Data Protection Act 2019 (DPA) and other European privacy and data protection laws (European Data Protection Legislation).

Personal information

We define “personal information” as any information or set of information that identifies or could be used to identify you, either directly or indirectly. Generally speaking, personal information does not include business contact information such as your name, title, business address or telephone number.

The collection and use of your personal information

Certain personal information about you may be collected when you use and engage with this website. The personal information collected depends on your use and engagement with this website. This information includes:

• Usage Data includes information about how you use our page and services.
• Communications Data includes your preferences in receiving communications from us and selected third parties.
• Technical Data includes information about your browser, method of reaching the website, and device features, such as the type of device used to access the website.
• Additional Volunteered Data includes any additional information you choose to volunteer about yourself through the on-site features, such as the chat plug-in, email, text service or contact forms. This may include identity data, contact data, and health data – specifically your name, email, telephone number, and any preliminary information relating to your health that you choose to disclose in contemplation of using our services.

This personal information may be used to:

• Facilitate direct communications and booking services, should you choose to engage with them.
• Provide an appropriate service offering to you based on the preferences you express.
• Customize the page and its content to ensure the most relevant and appropriate user experience.
• Communicate directly with you should you express a preference to engage with our services.

This page is not intended for use by children and no personal information relating to children is knowingly collected or used.

Legal basis for processing your personal information

It is necessary for us to have a legal basis for the collection and use of your personal information, including special categories of your personal information.

There are a number of different legal bases in the UK and the EU on which personal information may be collected and used, including:

• Consent: where you have given clear consent to the processing of your personal information for a specific purpose;
• Explicit consent: where you have given explicit consent to the processing of special categories of your personal data (including health data) for a specific purpose; and
• Legitimate interests: where the use of your personal information is necessary for a legitimate interest (unless there is a good reason to protect your personal information which overrides that legitimate interest).
• Vital interests: where the processing of your is necessary in order to protect your vital interests those or of another person (e.g. where there is a threat to your life or the life of another person and processing cannot manifestly be based on another legal basis).

In Canada, organizations are required to obtain meaningful consent for the collection, use and disclosure of personal information. Therefore, only the above-mentioned “consent” and “explicit consent” may be considered as a valid legal basis where PIPEDA and PHIPA apply. Furthermore, organizations may only collect, use, or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances. By providing us with personal information, you consent to its processing in accordance with this policy. Generally, we will obtain the necessary personal information directly from you, with your consent, subject to the exceptions provided by law. Note that you have the right, if you so choose, to refuse the collection, use and disclosure of your personal information. For more details, please see the section below Your rights.

Please note, however, that anonymized, non-identifying information will be retained.

Further details concerning the collection and use of your personal information in connection with your use of the website are set out in the table below:

Who we are

The website is controlled by Yorktown Family Services, a multi-disciplinary team of social workers, psychologists, psychiatrists and child psychiatrists based in the province of Ontario. Website visitors are offered consultations with Yorktown’s clinical team.  These consultations are free of charge, voluntary, and strictly confidential.

Sharing your information with Third Parties

Your Usage, Communications and Technical data will be shared with our Trusted Partner Moonshot CVE Ltd (hereinafter “Moonshot” or “Trusted Partner”), a company based in London, UK. Moonshot will use this data to help us provide services, customise the website and its contents, and to communicate with you. Additional Volunteered Data that you share with us will not be shared with Moonshot or other third parties, except where that has been data aggregated, anonymized, and it is necessary to share this data to provide our services.

Sharing your information without explicit consent

In certain cases, we may disclose categories of personal data listed above in order to prevent an act of violence.  Acts of violence include suicide, and occasions where there is reasonable cause to believe that there is a serious risk of death or serious bodily injury threatening a person or an identifiable group of persons, and where the nature of the threat generates a sense of urgency. Where we process your personal data for this purpose, our legal basis for processing will be the vital interests basis. We will report this data to the Ontario Provincial Police, the Royal Canadian Mounted Police or any other competent municipal, provincial or federal law enforcement agency.

Sharing and disclosing of your personal information

In the course of our activities, we may need to disclose and share your personal information with various stakeholders. We will only disclose and share your personal information as described below:

• Our Employees and Multi-disciplinary Team: In the course of their work, our employees and multi-disciplinary team may need to access your personal information, for example, when you call us, or chat with us. Their access is limited to what is necessary to perform their duties.
• Third Party Agents and Service Providers: From time to time, we may need to share your personal information with agents or service providers to assist us in making available all of the features of our website (maintenance, analysis, legal requirements, fraud detection, marketing and development). Please note that these service providers may be located in Canada or in other jurisdictions or countries. They will only have access to personal information that is necessary to perform these functions on our behalf and are required not to disclose or use it for any other purpose. Please be aware that we have contractual agreements with these vendors to ensure the security of your data.
• We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
• When required by law, to enforce compliance or to protect the property or safety of our rights or those of others: By way of example, we may disclose personal information to legal or regulatory authorities in the event that we suspect criminal activity, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental bodies, regulatory agencies or other self-regulatory organizations. We may also need to disclose personal information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts).

Collection and use of your information out of Canada

Your personal information will be processed both within Canada and the UK. Any processing of your personal data will be carried out in accordance with PIPEDA, PHIPA and the European Data Protection Legislation. Note that Canada and Europe have different but equivalent data protection laws meaning that adequate data protection safeguards are (and will be) in place to safeguard your personal information.

Cookies and other tracking technologies

Details on the collection, use and disclosure of data on our site through cookies and other social media features:

We may use various tools to improve your experience on our site, to better understand our users’ behaviour, and in particular in connection with our marketing strategies. The following section is intended to provide you with more information about how we and our Trusted Partner use these tools, including profiling, if any.

By using cookies and similar technologies, we are able to provide you with advertising that is more relevant to your needs, as it is targeted to your interests and preferences. When you visit our site, cookies tell us, among other things, which pages you are interested in and, as a result, we may subsequently display advertising or recommendations that match your interests.

These technologies do not contain any personally identifiable information per se. They may, however, contain a unique identifier necessary for profiling. When you click on one of these ads, we may also track the response rate of the campaign. We mainly use cookies and web beacons as they are defined as follows:

Web beacons

Web beacons are tiny images that we can place on our web pages or in our emails. They can be used, for example, to anonymously track how many times a particular page has been visited by a user or whether an email has been read. As the name implies, web beacons are invisible and any part of our Site, including the advertisements displayed on them, may contain web beacons. Unlike cookies, web beacons are not placed on your computer.

Cookies

Cookies are small data files that are commonly stored on your device when using websites and online services. They are used for the efficient operation of websites and can provide information and help customize services. We collect the information provided by cookies.

We use different types of cookies (collectively referred to as cookies here):

Necessary cookies: These cookies are essential to the operation of our site. Without them, services such as the shopping cart do not work.

Performance and functionality cookies : These cookies are not essential to the provision of our services. They help personalize and enhance the user experience. For example, we may use performance cookies to learn which pages on our Site are most popular, which method of linking between pages is most effective, and to determine why certain pages display error messages.

Cookies for advertising purposes: These cookies are not essential to the provision of our services. They help us show you relevant advertisements, both on and off our site, measure the performance of those advertisements, and generate subject matter reports. We use these cookies to track whether you were able to view content or whether someone who saw an ad later returned to perform an action (such as ordering a product) on another site.

We use two main types of cookies:

The session cookie: This type of cookie is kept in memory for the duration of your visit to our site, after which it is erased from your device. It allows you to be identified and is then deleted when you leave our site.

The persistent cookie: This cookie is stored on your device until it expires, or is deleted by you, and will be retrieved the next time you visit our Site. Our persistent cookies therefore have a variable duration.

Please note that the use of cookies only identifies you as a user and does not recognize you by name or address.

Disabling cookies

It is possible to prevent the personalization features of our site by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device, often found in your browser’s “Tools” or “Preferences” menu.

However, if you choose to decline cookies, certain pages or sections of our site may not display properly or certain features may not be available.

For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as http://www.allaboutcookies.org.

Do other websites have access to cookies when you browse our site?

We sometimes use third-party service providers.

Indeed, when you access our site, either directly or through an advertisement redirecting you to our site, a cookie is automatically created on your computer or mobile device. At that time, a web analytics tool (for example, Google Analytics) and possibly external ad servers have access to this cookie, which allows us to provide you with a better experience on our site or, in some cases, to track your activity to promote some of our products. Although a code in the cookie file identifies you as a user, it does not recognize you by name or address.

Our service providers may also need to collect your IP address or mobile device identifier when you visit a site. This information may be transmitted to and stored on servers located in Canada or elsewhere, such as the United States and the UK. We do not combine any information collected by these third parties with information we hold about you. Please be aware, however, that certain suppliers may be required to disclose the data collected to third parties if they are required to do so by law or if they wish to entrust the processing of certain data to third parties. No information that would allow these suppliers to identify you is transmitted to them.

Please note that third-party service providers have their own cookies and privacy policies.

Use of Google Analytics

We use Google Analytics, which is provided by Google Inc. (Google), in order to analyze the browsing behaviours of visitors to its site, which are tools for analyzing the frequentation and use of Web sites.

The information collected by Google Analytics is used to analyze the use of our site and to generate statistical reports on visitor activity. You can obtain more information about Google Analytics here.

Targeted Advertising

We also work with third-party advertising companies, such as Facebook or Google Ads, that collect and use information about your visits to our site in order to provide you with advertising that may be of interest to you. We do not disclose any information that would allow the advertising companies to identify you.

Please note that our advertising partners and other third parties may also set cookies or pixels when you click on their advertisements or links to their websites or services on our site. This Privacy Policy does not apply to third-party websites or third-party advertising providers.

You can disable Google Analytics while browsing by selecting the appropriate settings for your browser or computer tool, as well as ad settings. You may opt out of sharing your information with these third parties by installing an add-on to opt out of receiving interest-targeted ads. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance of Canada’s opt-out portal at: https://youradchoices.ca/en/tools.

We also use Facebook’s personalized audience feature to target advertising related to the interests of its current and potential customers. We invite you to check your Facebook privacy settings if you wish to manage your advertising settings. You can get more information here.

Please note that even if you choose not to receive ads targeted to your interests, you will still be able to see our ads. In this case, these ads will simply not be adapted to your real needs and may be displayed more frequently.

For more information on how targeted advertising works, you can visit the Digital Advertising Alliance of Canada (“DAAC”) education page at: https://youradchoices.ca/en/faq.

Social Media Features

Our services include social media features such as the Twitter share button or interactive mini-programs that work on our site. If you use these features, they collect your IP address, the page you visit on our site and create a cookie to enable these features to function properly. These features may be hosted by a third party or directly on our site. Your interaction with these features is governed by the company’s privacy policy that proves the feature and not by this policy.

Your rights

You have the right to know whether we hold personal information about you and to have access to that personal Information. You also have the right to ask questions about how we have collected, used and retained your personal information and to whom it has been disclosed.

We will provide you with such information or make the corrections promptly where personal information is inaccurate and no later than 30 days from the date when we receive the written request. A reasonable fee may also be charged to process your request.

In some situations, it may not be possible for us to disclose all of the personal information we hold about you. Exceptions to the access requirements are limited and specific. The reasons for denying access are provided upon request.

These exceptions include information that is prohibitively costly to provide, information that contains details about other individuals, the existence of legal, security or business reasons that prevent the provision of the information and the fact that the information is protected by solicitor-client or litigation privilege.

If you would like to exercise any of your other rights or ask any questions, please contact privacy@etaontartio.ca

Keeping your personal information secure

Appropriate security measures in place to prevent your personal information from being accidentally lost, or used or accessed in an unauthorised way. Access to your personal information is limited to people who have a genuine need to know it. Any use of your personal information will only be done by an authorised person who is subject to a duty of confidentiality.

Retention of your personal information

To find out how long we keep your information, please refer to the table in the Legal basis for processing your personal information section of this privacy policy.

Link to other web site

It is important to understand that this Policy does not apply to other third-party websites that may be accessed through links on our site. We are not responsible for those third-party sites, their content or access. Therefore, any personal information you transmit through these sites is subject to the privacy policies of those sites. It is your responsibility to review their privacy policies to ensure the protection of your personal information.

Changes to this privacy policy

This website privacy policy was published on 1 September 2021.

This website policy may change from time to time and you should check it regularly for updates.

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact information and challenging compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer

Email: outreach1@etaontario.ca

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

Accessibility

ETA Connect (ETA) is committed to excellence in serving all clients (“you”), including individuals with disabilities, in accordance with the requirements of the Customer Service Standard Regulation 429/07 of the Accessibility for Ontarians with Disabilities Act, 2005.

We are committed to provide accessible and equitable customer service to you. This Plan has been prepared to ensure a consistent approach to service and includes the core principles of independence, dignity and integration of individuals with disabilities.

Communication

Our interactions and communications with you will take into account their disabilities. Our staff, volunteers and third party contractors are trained to communicate with persons with various disabilities. Requests for alternative methods of communication (large print documents, etc.) will be fulfilled in a timely manner. If an accommodation is not readily available, you will be advised of the reasons.

Assistive Devices

You are welcome to use your own personal assistive devices to access our programs and services. We will make every effort to ensure that our staff are trained on how to interact with individuals using various assistive devices.

Service Animals

We welcome people with disabilities and their service animals on the parts of our premises that are open to the public. All staff, volunteers and third party contractors will be trained on how to interact with clients/members who require service animals.

Support Person

A person with a disability who requires a support person will be allowed to have that person accompany them on our premises. All staff, volunteers and third party contractors will be trained on how to interact with clients who require a support person. Your consent will be obtained prior to discussing any of your confidential personal information in the presence of a support person.