Capsana’s personal information protection policy
Last modified on 2023-03-07
Current version: 2023-10-17
Previous version: 2023-03-08
This Privacy Policy (hereinafter the “Policy”) describes the practices of Capsana Inc. (hereinafter “Capsana”) regarding the collection, use, disclosure and retention of your personal information, including in connection with the campaigns, challenges and contests it administers or in the management of its activities. To facilitate the reading of the Policy, we frequently use the word “we” when referring to Capsana and its affiliates.
Our Policy applies regardless of how we collect your personal information, such as in person, by telephone, by email or through our websites.
In certain situations, we may provide you with additional information regarding the processing of your personal information at the time we collect it, in particular by means of a consent form, if applicable, which would complement this Policy.
By accepting our Policy or providing us with personal information after you have had an opportunity to review our Policy or any supplemental notices, you consent to the processing of your personal information in accordance with our Policy and any supplemental consent forms, if applicable.
1 How can I contact your Privacy Officer?
You can contact our Privacy Officer:
- By email at [email protected] to the attention of the Privacy Officer.
- By mail at 6833 de l’Épée Avenue, Suite 201, Montréal, Quebec H3N 2C7 to the attention of the Privacy Officer.
2 What personal information do we collect and how do we use it?
2.1 In connection with our activities and our campaigns, challenges and contests administered by Capsana:
We process, use, disclose and retain the personal information of our clients and participants in Capsana contests and promotional events for the purposes of, but not limited to, administering our programs, campaigns, challenges and promotional contests and those of our partners, tracking and optimizing our advertising campaigns, communicating with winners, when applicable, and transmitting certain promotional information. Examples of such programs or campaigns are the Quit to Win! Challenge, the 24h of PAUSE unplugging events, and the TOUGO web platform. Capsana uses personal information, among other things, to enable participation in contests in accordance with rules and regulations.
The personal information collected in this way includes, depending on the program, but is not limited to: email address, postal address, telephone number, first and last name, number of people in the household, children’s age group, age group and year of birth, gender, occupation, name of organization, number of employees, weight, height, and certain information about participants’ lifestyle habits and personal preferences.
2.2 In connection with the creation of an account or subscription to one of our mailing lists:
We process, use, disclose and retain the personal information of users who choose to create an account or subscribe to a Capsana or partner mailing list for the purpose of, but not limited to, producing and sending occasional communications, certain promotions, newsletters, public service announcements, and commercial email messages.
The personal information collected is: email address, password, first and last name, telephone number, postal address.
Such messages may originate from Capsana or Capsana’s partners associated with such a subscription or account creation. Users may opt out of such communication of information or receipt of promotional messages by contacting Capsana at the email address listed at the end of this Policy.
2.3 In connection with the use of websites owned by Capsana or one of its affiliates:
We process, use, disclose and retain personal information of users of Capsana’s and its affiliates’ websites for purposes including, but not limited to, analyzing traffic patterns on Capsana’s and its affiliates’ websites. The personal information thus collected includes, but is not limited to: browsing data, IP address and browser type, demographic data and logs.
We invite you to consult our Policy on the use of cookies and identification, location and profiling technologies attached hereto (Appendix A) to learn more about the treatment of your personal information in connection with the use of Capsana’s websites.
3 How do we collect your personal information?
3.1 We collect your personal information directly from you in the following contexts:
3.1.1 as part of Capsana’s general activities, when you voluntarily provide your personal information by participating in our contests, events or promotional campaigns, or when you use our services, including, but not limited to, by filling out our forms, or when you communicate with us by email, in person, by telephone or in writing;
3.1.2 when you complete a questionnaire, such as the Health Questionnaire;
3.1.3 when you create an account and subscribe to one of our mailing lists, when you voluntarily provide your personal information by filling out our forms or when you communicate with us by email, in person, by telephone or in writing;
3.1.4 in connection with the use of our websites, when you voluntarily provide your personal information by filling out our forms, when you communicate with us by email, in person, by telephone or in writing, or when you visit our websites (see attached our Policy on the use of cookies and identification, location and profiling technologies – Appendix A).
We would like to bring to your attention that the information you provide directly to us in one of the ways mentioned in the present section 3.1 may be exchanged between various internal Capsana stakeholders when necessary for the proper conduct of Capsana’s activities. To this end, section 4 describes in more detail who, within Capsana, will have access to your personal information.
3.2 Minors under the age of 14
In connection with promotional activities specifically designed for minors, we may collect personal information from persons under the age of 14 when the campaign is clearly in their interest, particularly during our health promotion campaigns.
Other than in these specific cases, minors under the age of 14 may not provide us with personal information without the express consent of a parent or guardian.
If you are a parent or guardian and you are aware that your children have provided us with personal information without your consent, please contact us.
If we discover that we have collected personal information from a person under the age of 14 without the consent of the parent or guardian, we will take the necessary steps to delete that information from our systems.
4 Who will have access to your personal information at Capsana and to whom do we disclose your personal information?
4.1 Within Capsana
At Capsana, employees who require access to your personal information in the performance of their duties will have access to your personal information only when necessary to accomplish the purposes to which you have consented.
4.2 Our partners
We may share your personal information with our partners in connection with our campaigns and receive certain personal information from them when necessary to ensure the smooth running of Capsana’s activities and campaigns.
4.3 Service providers
We may transfer your personal information to service providers and other third parties we use to support our activities. To this end, here are the third parties and the categories of personal information may be transferred:
- Unicorne (IT Consultant)
- Categories of personal information: any personal information that may be collected by Capsana or its affiliates.
- Purposes: to optimize our databases.
- Léger (marketing research firm)
- Categories of personal information: information on general activities as specified in section 2.1.
- Purposes: to conduct awareness and program evaluation surveys.
- Dialog Insight (mass emailing tools)
- Categories of personal information: information on general activities as specified in section 2.2.
- Purposes: to inform you of our current programs, promotions, contests or campaigns.
- Cossette media and Jungle (advertising agencies)
- Categories of personal information: information on general activities as specified in section 2.3.
- Purposes: to optimize our advertising campaigns.
5 What identification, location and profiling technologies do we use?
We use technologies to identify you, locate you, or profile you through the use of cookies.
You can activate these technologies by accepting cookies used for identification, profiling or localization on the relevant banner on our websites.
For more information, please refer to the attached Policy on the use of cookies and identification, location and profiling technologies – Appendix A.
6 How long do we keep your personal information?
We will retain your personal information until the purposes for which it was collected have been fulfilled and in accordance with our policies and internal processes to that effect. However, we may retain your personal information for a longer period when required to comply with our legal and regulatory obligations to retain or preserve information or records.
To find out more about how long we keep personal information, please contact our Privacy Officer, whose contact details can be found in section 1.
You understand that your consent is therefore valid for this period, unless you exercise your right to withdraw your consent, with the consequences that such a request entails, as described below in section 9.
7 Where do we store personal information, and is it transferred outside Quebec?
Your personal information is currently held virtually on Capsana or its affiliates’ servers hosted in Canada and on service provider platforms such as AWS Canada. In relation to the use of these platforms, your personal information may be transferred and hosted outside of Quebec by its suppliers, and for the following reasons, the company operates various sites in regional offices across Canada.
Some of your personal information is also archived and kept on paper at our head office. All physically-held personal information is protected by secure access and is restricted to its physical location, and in accordance with section 4.1 hereof, only persons authorized in the course of their duties will have access to it.
When we consider that the disclosure of your personal information outside Quebec would be necessary to support our activities, we assess whether your personal information would benefit from adequate protection in the event of disclosure. We will only disclose your personal information if we are satisfied that it is adequately protected. Disclosure will also be governed by an appropriate contractual agreement.
8 Protective measures and inherent risks
We take appropriate security measures to protect your personal information. In particular, we have implemented appropriate physical, technical and administrative safeguards to ensure the protection of personal information.
Despite these measures, given the risks inherent in the use of computer systems, we cannot ensure or guarantee the security and confidentiality of the personal information you transmit or provide to us. You do so at your own risk.
If you have reason to believe that personal information has been compromised, please contact our Privacy Officer.
9 What are your rights regarding your personal information?
By law, you have various rights with respect to your personal information. In particular, you have the following rights:
9.1 Access to your personal information
You can ask us if we have any personal information about you and, if so, you can request access to that personal information.
You can access and review your personal information in your member account, if applicable.
9.2 Rectification
You can ask us to correct any incomplete or inaccurate personal information we hold about you.
You can correct your personal information yourself in your member account.
9.3 Withdrawal of consent
You may withdraw your consent to the disclosure or use of the personal information we hold about you.
However, you understand that in such a case, you may no longer be able to benefit from our products and services. We may also de-identify the information or delete your account.
9.4 Portability
As of September 22, 2024, you may request that your personal information be disclosed to you or transferred to another organization in a structured, commonly used technological format.
You will be able to request a copy of the personal information you have provided to us by making a request to the Privacy Officer at the contact details set out in section 1.
9.5 Cessation of dissemination and de-indexation
You may ask us to cease disseminating your personal information or to de-index any hyperlink attached to your name allowing access to this information by a technological means, when the dissemination of this information contravenes the law or a court order.
You may also request that the hyperlink providing access to this information be de-indexed if the dissemination of this information causes you serious harm with regard to the right to respect of your reputation or privacy and if certain conditions provided for by law are met.
10 How can you exercise your rights?
To exercise any of your rights above, please contact our Privacy Officer at the contact details set out in section 1.
11 How can you file a complaint about our handling of your personal information?
Capsana takes inquiries, complaints and comments about how your personal information is handled very seriously. We invite you to contact our Privacy Officer with any complaints or comments you may have about our privacy practices.
Your complaint will be reviewed by our Privacy Officer, who will determine whether the handling of your personal information complies with our privacy program and any applicable laws.
You may also file a complaint with the Commission d’accès à l’information du Québec by completing the form available here. However, we invite you to first contact our Privacy Officer before undertaking such a procedure.
12 External sites or services
This Policy does not apply to, and we are not responsible for, any third-party websites, pages or applications accessible through our services, including, but not limited to, our website and member portal. If you follow such links, these third-party sites or services will likely have their own privacy policies that you should review before submitting your personal information.
Some of the content, advertising and functionality of the services offered (portals, websites and applications) may be provided by third parties that are not affiliated with Capsana. These third parties include, for example: content providers, advertising providers, audience measurement companies or social networking services (Google, Facebook, X (formerly Twitter), Instagram, etc.). They may collect information about your use of Capsana services through the use of cookies, web beacons (pixel tags) and other technologies. This information may be collected and combined with various online services to present offers based on your interests in order to provide various services (targeted advertising, login or functionality). These technologies and the information they collect can also be used on all types of devices.
The use of third-party cookies is not covered by this privacy policy, as these third parties are subject to their own privacy policies. To learn more about the use of this data, please consult the following sites: the Digital Advertising Alliance of Canada, Facebook’s Privacy Policy, Facebook’s list of social plugins, Google’s Privacy Policy. You can stop the collection and use of information intended for targeted advertising by visiting www.aboutads.info/choices.
13 How do we update this Policy?
We may change our Policy occasionally at our sole discretion.
Prior to coming into effect, proposed changes will be posted on the Capsana website with a notice of change. The proposed changes will take effect on the date specified in the relevant notice of change.
APPENDIX A
Policy on the use of cookies and identification, location and profiling technologies
Current version: 2023-10-17
This policy regarding the use of analytics and cookies (“Cookie Policy”) describes how and why Capsana Inc. and its affiliated entities, brands or trade names listed in Appendix A (“Capsana” or “we”) use cookies, web beacons and other identification, location or profiling technologies on their websites and in their promotional electronic communications.
Our Cookie Policy complements our Privacy Policy and should be read in conjunction with it.
1 What you need to know about cookies and web beacons
1.1 What are cookies and web beacons?
Cookies are small text files that are downloaded to your device when you visit a website, use a mobile application, or download an email. Cookies enable a website to recognize a device and store information (e.g., on your preferences, your use of the website) and to read this information each time you access the website.
There are two types of cookies: (i) primary; and (ii) third party. Essentially, both types are technically identical and perform the same functions; the main difference lies in how they are created and then used.
Primary cookies. Primary cookies are created by the website you are visiting. A website can only access the cookies it has placed on your device, so, for example, cookies placed when you visit a search engine are not accessible by our websites.
Third-party cookies. Third-party cookies are created by a site other than the one you are visiting and are mainly used for profiling purposes and behavioural advertising. They also allow website owners to provide certain services. This type of cookie may be placed by what is known as a web beacon (more on this below). Since a website can only access cookies it has placed itself, we cannot access third-party cookies placed on any of our websites.
A web beacon, often referred to as a pixel tag, is a transparent image, usually 1 pixel x 1 pixel, that is placed on a website or in an email to evaluate how a user interacts with specific content. Web beacons work by sending information with the request to the third-party web server when the request to display the web beacon is made.
1.2 What can you do to control cookies placed on your computer?
Most browsers allow you to configure how cookies are accepted by your browser. Keep in mind that changing your cookie settings may prevent certain websites from functioning properly. Please consult your browser developer’s documentation to find out how to configure your cookie settings.
You can also use your browser’s private or incognito mode, which will automatically delete any cookies placed while you are in private mode when all private mode tabs are closed. Visit your browser’s help section for more information on how private mode works.
Some recent browsers have built-in functionality to block or control profiling content. Please consult your browser’s help section to see if such functionality is available.
Some browsers may have extensions created by third parties that can be used to manage and delete cookies. If you decide to use extensions, please pay particular attention to the extensions you install and the permissions they require.
You can also disable our use of cookies and similar technologies that allow us to profile and display banner ads on third-party sites.
2 How we use cookies on our websites
2.1 Why do we use cookies on our websites?
We wish to use cookies and web beacons to:
- analyze traffic on our website in general;
- adjust website settings to suit your device;
- display ads via services provided by third parties;
- help us understand who uses our services and interacts with our promotional material and how they do so, so that we can improve them;
- analyze your interaction with other pages and websites;
- help us personalize our approach, responses and services by remembering your preferences.
2.2 What types of cookies are used on our websites?
On our websites, we use both primary and third-party cookies, some of which are essential to the proper functioning of our websites, while others are used for analysis and marketing purposes.
Cookies and web beacons will only be placed if you have consented to them being placed on your device.
Security. We use cookies to enable the proper functioning of our security measures and the security measures of third parties.
Preferences and features. We use cookies to store your preferences and enable our video player to function properly.
Traffic analysis. We use cookies to understand how you interact with our websites. Our partners may also use cookies to analyze your use of our websites and to provide us with information about your use of our websites.
Marketing. We use cookies to display ads based on your interests and use of our websites. Our partners may also use cookies to determine whether our ads have reached you and, if so, whether you have interacted with them. In such cases, our partners provide us with data and statistics on the performance of our advertisements. These cookies and web beacons allow us to display promotional material on websites that do not belong to Capsana.
We use web beacons in our promotional emails to collect statistics on the opening of emails and the interaction with the content of emails in order to analyze the performance of our promotional campaigns. We use your interaction with our promotional emails as an indicator of your interest in our products and services. We may adjust the way we contact you based on your interaction with our promotional emails.
3 Analytics tools to measure interaction with our website and promotional material
3.1 What you need to know about analytics
Analytics tools are used to collect, analyze and measure data about web traffic and user visits to our websites in order to better understand and optimize their use. Analytics tools work by collecting information about a visitor’s interactions with one or more web pages. This information includes, for example, the visitor’s IP address.
3.2 What analytics tools do we use on our websites?
3.2.1 Google Analytics 4
We use the Google Analytics 4 tool offered by Google Inc. to collect information about how visitors use our websites. We use the reports compiled by Google Analytics 4 to help us improve our websites.
The information is collected anonymously and includes:
- the country and city from which you access our websites;
- demographic information based on information Google already has about you from your interactions with other websites;
- the number of visitors to our websites and the pages visited.
Further information on the information made available to us by Google Analytics 4 can be found on this page.
In addition, we also use the following services offered by Google Analytics:
- Google Analytics Demographics and Interest Reporting;
- Google Display Network Impression Reporting; and
- Remarketing with Google Analytics.
For more information on how Google treats the personal information it may hold about you as a result of the Google Analytics services it provides to us, please read Google’s Privacy Policy by clicking here.
3.3 How will we use the information we have obtained from the analytics tools?
We rely on analytics tools to obtain information about you for five main purposes:
- to improve our websites based on visitor interactions;
- to evaluate the effectiveness of our promotional campaigns;
- to better understand the path taken by our visitors: from the original campaign to becoming clients;
- to establish marketing profiles and qualify potential clients; and
- to carry out targeted advertising on search engines and social media.
3.4 What can you do to prevent websites from collecting analytics information?
You can take various steps to prevent our websites from collecting details about your visits, including:
- control the cookies accepted by your browser (see section 2.2);
- disable service profiling by installing browser extensions:
4 Updates to this Policy
We may, at our sole discretion, occasionally change our Cookie Policy. Prior to becoming effective, proposed changes will be posted on Capsana’s website along with a notice of change. The proposed changes will become effective on the date specified in the relevant notice of change.