INOVA GROUP EQUINE SOFTWARE CANADA INC.
Inova Group Equine Software Canada Inc. (“Inova Group Equine Software Canada Inc.“, “we“, “our“, or “us“) is committed to complying with privacy laws and legislation applicable to us, and to protecting the privacy and security of personal information in our custody or control. We are based in Calgary, Alberta, Canada, and we are subject to Canadian law, so we are generally subject to Alberta’s Personal Information Protection Act (PIPA), and there may be circumstances in which Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) may be applicable.
We own and operate a cloud-based veterinary practice management solution available on a software as a service basis via our website (our “Website”) including software.vet, all subdomains and through a mobile application, as well as other products and services that we make available (collectively the “Services”). This Policy applies to the Services, and describes how we collect, use, store, process, transfer, share, and disclose personal information in providing the Services.
Before accessing or using our Website or the Services, we ask that you please ensure that you have read and understood this Policy, and how we collect, use, store, process, transfer, share, and disclose your personal information as described in this Policy. By accessing or using the Services, you are accepting and consenting to our practices as described in this Policy.
It is our policy to only collect, use, store, process, transfer, share, and disclose your personal information for reasonable purposes and with your consent, except where consent is not required by law. However, we do reserve all our rights under all available exceptions or exclusions under applicable privacy law and this applies to all our activities as described in this Policy, and to all provisions stated in this Policy.
When we collect, use or disclose personal information, we make reasonable efforts to ensure that it is accurate, up to date, and complete.
The laws and legislation applicable to us may change, or our policies and procedures related to our collection, use, and disclosure of personal information may change (in response to changes in the law, or due to changes in how we carry on business and improvements we may make), or both, so we may occasionally modify this Policy to reflect such changes.
Please be advised that the Internet and email are inherently insecure media, and we cannot take responsibility for the security or privacy of personal information in transit over the Internet.
Please also note that our Website may contain links to other websites which are provided as a convenience for visitors to our website only. Any third-party websites will have their own privacy policies and practices, and we cannot be responsible for such third parties or their websites.
Our Website and Services are not directed at persons under 16 and we do not intend to collect personal information from children under 16. If you become aware that a child has provided us with personal information without appropriate consent, then please contact us using the details at the end of this Policy so that we can take the appropriate steps in accordance with our legal obligations and this Policy.
If we need to contact or notify you, or provide you with information, we will select what we believe is the best way to do so. We will usually do this through email or by placing a notice on our Website or in the Services.
2. Personal information we collect
We generally collect personal information for reasonable purposes related to carrying on our business.
Disclosure of personal information is voluntary. You may choose to not provide personal information, but as a result we may not be able to provide the Services to you or respond to your other requests.
When you voluntarily submit information directly to us, such as by corresponding or communicating with use by email, text, phone or other means, or by filling in forms, we collect the personal information you provide. This may include information you provide when you register to use our Website or subscribe to the Services, or participate in any discussion boards, forums or other social media functions on our Website, or enter a competition, promotion or survey, or when you report a problem with our Website or the Services, or use some other feature of the Services as may be available from time to time.
We may receive personal information about you from third parties such as individuals or corporate entities which are subscribers to the Services. For example, this may occur where you are to be designated a user of the Services, which requires that you be authorized by a subscriber or become a subscriber yourself. We require subscribers to only provide personal information to us with consent.
We may also work with third parties (including, for example, subcontractors in the provision of technical services, or in procuring and processing payments, providers of analytics services, advertising networks, search information providers, and credit reporting or reference agencies) and we may receive information about you from them, subject to your agreements with them, and your consent to their disclosing your personal information to us.
Personal Information we collect includes the following:
- Contact information and personal details, such as name, phone number, email address, physical or street address, location, IP address and, where applicable, professional details and credentials such as information about your status as a veterinarian or other staff member of a clinic or equestrian facility.
- Login credentials to the Services, such as email account, username, and password.
- Correspondence, comments, and another information you may choose to send or disclose to us.
- Payment information.
- Recruiting and employment details such as contact information and personal details (described above), professional and educational information, employment history, resume, profiles on social media such as LinkedIn that you may voluntarily provide in seeking employment with us.
- We may also automatically collect information about how you access and use the Services and/or our Website, including, for example, the device you use, the website you came from and the website to which you go after accessing the Services or our Website, the times at which, how frequently and for how long you access the Services, whether you open emails from us or click the links contained in those emails, whether you access the Services from multiple devices, and generally your activities in using the Services.
- Internet Protocol or IP addresses, browser type and version, Internet Service Provider or ISP, referring or exit web pages, date/time stamp, operating system, and some types of “clickstream” data may also be collected automatically.
We may link or combine the personal information we collect or receive about you with the information we collect automatically. We use this information to help us provide you with a personalized experience regardless of how you interact with us or use the Services
We may anonymize and aggregate any of the personal information we collect (“anonymize” means that we remove any identifiers so that the information no longer identifies you, and “aggregation” means that we combine that anonymized information with other anonymized information). We may use anonymized information for purposes that include improving the Services, developing new features or components to the Services, data analysis, testing our software and information technology systems, and research for internal purposes. We may also share such anonymized information with others, but you cannot be identified from such anonymized information.
3. Use of personal information
We use personal information for purposes including the following:
- To communicate with you, respond to your inquiries and requests, including to deal with customer service issues, technical support, and inquiries related to the Services, and to send you statements, alerts, notifications, news, and marketing information.
- To operate, maintain, support, enhance, improve and provide the Services and the features and functionality of the Services.
- To host and make available information you choose to upload or store in the Services (defined as “Content” in our services contract – we do not claim any intellectual property rights or proprietary rights in such Content).
- To process payment for the Services, to assess your credit score (with your consent), and to detect and prevent fraud and misuse of the Services.
- To facilitate recruiting and establishing employment and independent contractor relationships, as well as managing and terminating such relationships.
- To operate our business, including to monitor and improve our Website and the Services.
- For internal operations, including data analysis, testing, troubleshooting, bug fixes, statistical and survey purposes, to keep the Services and the Website secure and safe, and to assist us in developing new products and services.
4. Disclosure of personal information
We may share personal information with any member of our corporate group, which may include subsidiaries. We will not share personal information with any third parties except as described in this Policy or in connection with the Services, or otherwise after obtaining your consent.
We may share your information with selected third parties, including:
- Payment processors for the purpose of fulfilling relevant payment transactions.
- Credit reference agencies for the purpose of assessing your credit score related to our entering into a contract with you or continuing to extend credit or payment terms.
- Our service providers, business partners, vendors, suppliers, licensors, and subcontractors who perform services on our behalf (but we use contractual measures to protect and maintain the confidentiality and security of personal information shared with these entities, and these entities are authorized to use your personal information only as necessary to provide these services to us).
- Providers of search engine and analytic services providers that assist us in the improvement and optimization of our Website.
We may also be under a duty to disclose or share your personal data in order to comply with contractual or legal obligations, or in order to enforce or apply our terms and conditions of service or the terms and conditions of our end user license agreement and other contracts, or to protect the legal or proprietary rights, intellectual property rights, property, or safety of Inova Group ULC, our customers, user, or subscribers, or others.
We may exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction, or to conduct legal investigations or carry on legal proceedings, or to protect the property, safety, or rights of Inova Group ULC, our customers, licensees, users, subscribers, or others.
We may enable our Website or the Services to include publicly accessible blogs or community forums. Any information you provide in these areas, if made available, may be read, collected, used, and disclosed by others who access them. This includes information posted on any public social media account we may maintain. To request removal of your personal information from any blog or community forum we may maintain or implement, you may contact us using the information at the end of this Policy. There may be situations in which we may not be able to remove your personal information (such as where a third party controls the forum or platform on which you have chosen to post it), in which case we will let you know if we are unable to do so and why.
With consent, we may display personal testimonials of satisfied customers on our site, along with other endorsements. If you wish to update or delete a testimonial, you can contact us using the contact information at the end of this Policy.
We may disclose personal information to third parties in connection with a potential or actual business transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. If we proceed to be involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership that impacts the use of your personal information, as well as any choices you may have regarding your personal information.
From time to time we may contact you with relevant information about the Services and our other products and services. Most messages will be sent electronically. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you. If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can also change your marketing preferences at any time by following the unsubscribe link at the bottom of our emails.
5. Lawful Exceptions to Consent
Under Alberta law, we may collect, use or disclose personal information without consent in circumstances that may include but are not limited to the following:
- Where a reasonable person would consider that the collection, use or disclosure of the information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way or the individual would not reasonably be expected to withhold consent;
- Where the collection, use, or disclosure of the information is pursuant to a statute or regulation of either Alberta or Canada that authorizes or requires the collection;
- Where the collection of the information is from a public body and that public body is authorized or required by an enactment of Alberta or Canada to disclose the personal information to us;
- Where the collection, use or disclosure of the information is reasonable for the purposes of an investigation or a legal proceeding;
- Where the information is publicly available;
- Where the collection of the information is necessary in order to collect a debt owed to us or for us to repay to an individual money owed by us;
- In certain situations, we may be required by law to disclose personal information in response to lawful requests by governmental or public authorities, including to meet law enforcement requirements. It is our policy to comply with all such legal requirements.
6. Cookies and Related Technologies
Some pages on our Website and aspects of our Services may use a technology called “cookies”. A cookie is a small file that a server provides to your browser when you access a Website or our Services. Cookies can provide additional functionality to our Website and Services and can help us analyze and understand usage of our Website and Services more fully and accurately.
We do not collect any personal information from you when you simply visit our Website. However, you should be aware that most web servers do collect some information about visitors, such as the browser and version you are using, your operating system, and your “IP” or internet address, which may identify your Internet Service Provider or computer but typically not the person using it.
If you voluntarily submit personal information to us by email or other electronic means for purposes of obtaining information, we will consider that you have done so with your consent for purposes reasonably related to your providing the information. If reasonable to do so, after our initial response, we may send further information to you with information that may be useful, but we will include instructions on how to terminate receiving such further information.
Cookies may enhance user experiences, such as avoiding the necessity to enter a password or other identifier on return visits, or customizing the way the website displays to you to provide you with similar information to what you previously required. In all cases in which cookies are used, we will not collect personally identifiable information except with your permission.
We may use the following types of cookies:
- Essential cookies. These cookies are required for the essential operation of our Website or Services such as to authenticate you and prevent fraudulent use.
- Analytical cookies. Use of these cookies enables us to recognize and count the number of visitors and to see how visitors move around our Website and the Services while using it. This helps us to improve the functionality and operation of our Website and the Services, and responsiveness to your requirements.
- Functionality cookies. These cookies are used to recognize you when you return to our Service. This enables us to personalize content for you and avoid the necessity for you to log in on every occasion from the same computer and browser. It also allows us to remember certain preferences that you may have.
- Targeting cookies. These cookies record your visit to our Website and the Services, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information, usually anonymously except with your consent, with third parties for this purpose.
We recognize our legal obligations to protect the personal information we have gathered about individuals. We have therefore made arrangements to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information. These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.
8. Notification of Loss or Unauthorized Access or Disclosure
Where an incident occurs involving the loss of or unauthorized access to or disclosure of personal information under our control, where a reasonable person would consider that there exists a real risk of significant harm to an individual as a result of the loss or unauthorized access or disclosure, we will, without unreasonable delay, provide notice to the Information and Privacy Commissioner for Alberta of the incident, or, in some situations, to the Privacy Commissioner for Canada, including any information required by law at the time to be provided to the applicable Commissioner. While Alberta law provides that the Commissioner has the authority to require us to notify individuals of the unauthorized access or disclosure, Canadian federal law generally requires notification. We therefore may elect to immediately notify you of any incident in the event we consider it reasonable in the circumstances.
9. Retention and destruction of personal information
Alberta law allows us, for legal or business purposes, to retain personal information for as long as is reasonable. We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, personal information will either be destroyed in a secure manner or made anonymous.
Should consent to our collection, use, disclosure or retention of personal information be revoked by the individual in question, the law also allows us to continue to retain the information for as long as is reasonable for legal or business purposes. In the event that revocation of consent may have consequences to the individual concerned, we will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.
10. Legal Holds
There are situations where records scheduled for destruction must be preserved and not destroyed. In those cases, we may implement and enforce a “legal hold”. Those situations include audits, investigations, government or regulatory action and actual or potential civil litigation. In addition, where an individual has requested access to their personal information, it is illegal to destroy that information. It is therefore our policy to retain all records required for legal purposes for as long as those records, which may include personal information, may be required.
11. Outsourcing and Data Hosting Outside of Canada
We may use third party service providers to process or deal with records, documents, data and information on our behalf, and such records, documents, data and information may include personal information. In order to protect the confidentiality and security of personal information processed on our behalf by our service providers, we will use contractual and similar measures with such service providers, including contractual non-disclosure provisions.
We may use “cloud computing” third party service providers, and those providers may be either in or outside Canada, and the data housed, hosted and processed by such providers may reside in or outside of Canada, and may include personal information about individuals. Where consent or notification is legally required, it is our policy to notify individuals about such service providers outside of Canada, and such notification will include the way in which the individual may obtain access to written information about our policies and practices with respect to service providers outside of Canada and the name or tile of a person who can answer any questions about the collection, use, disclosure or storage of personal information by any service providers outside Canada.
If you are located in the European Union, your personal information may be processed outside of the EU including in Canada or in the United States. Such international transfers of your personal information are made pursuant to appropriate safeguards, and, we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the EU and under the General Data Protection Regulation (“GDPR”). Such measures shall include, but are not limited to, having Data Processing Agreements with applicable sub-processors and ensuring that such sub-processors have adequate security and data protection procedures in place aligned with the GDPR or any other applicable data protection law. If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of this policy.
12. CASL Compliance
Canada has implemented legislation (Generally referred to as Canadian Anti-Spam Legislation, or “CASL”) prohibiting commercial electronic communications without adequate consent, and without an adequate unsubscribe mechanism. Commercial electronic communications (“CEM’s”) are defined as emails and text messages. It is our policy to not send CEMs without valid legal consent from the recipient, and it is our policy to always use the unsubscribe mechanisms prescribed by CASL. CASL limits how long we can keep and use your information so, unless you have given us a permanent and express consent to contact you or send messages to you regularly, we may cease corresponding with you without notice once applicable time limits have passed.
13. Requests for Access
Alberta law permits individuals to submit written requests to us to provide them with:
- access to their personal information under our custody or control;
- information about the purposes for which their personal information under our custody or control has been and is being used; and
- the names of organizations or persons to whom and the circumstances in which personal information has been and is being disclosed by us.
Requests for access are subject to the following:
- Any requests must be in writing.
- We reserve the right to not accept such requests or respond to such requests via email in order to be certain of the identity of persons with which we communicate and to protect the privacy of individuals.
- In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.
- We will respond to requests in the time allowed by Alberta law, which is generally 45 days.
- We will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible.
- All requests may be subject to any fees and disbursements the law permits us to charge.
- Where appropriate to do so, we may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.
Please note that an individual’s ability to access his or her personal information under our control is not an absolute right. Alberta law provides that we must not disclose personal information where:
- The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
- The disclosure would reveal personal information about another individual; or
- The disclosure would reveal the identity of an individual who has in confidence provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity.
Alberta law also provides that we may choose not to disclose personal information where:
- The personal information is protected by any legal privilege;
- The disclosure of the information would reveal confidential commercial information and it is not unreasonable to withhold that information;
- The personal information was collected by us for an investigation or legal proceeding;
- The disclosure of the personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided;
- The personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act
- under an agreement,
- under an enactment, or
- by a court; or
- The personal information relates to or may be used in the exercise of prosecutorial discretion.
14. Responses to Requests for Access
Our responses to requests for access to personal information will be in writing, and will confirm:
- Whether we are providing all or part of the requested information,
- Whether or not we are allowing access or providing copies, and,
- If access is being provided, when and how that will be given.
If access to information or copies are refused by us, we will provide written reasons for such refusal and the section of PIPA (the Personal Information Protection Act, Alberta) on which that refusal is based. We will also provide the name of an individual at Inova Group ULC who can answer questions about the refusal, and particulars of how the requesting individual can ask the Information and Privacy Commissioner of Alberta to review our decision. In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.
15. Requests for Correction
Alberta law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. If an individual alleges errors or omissions in the personal information in our custody or control, we will either:
- Correct the personal information and, if reasonable to do so, and if not contrary to law, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
- Decide not to correct the personal information but annotate the personal information that a correction was requested but not made.
Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.
16. Certain Additional Rights
Applicable privacy law may also provide you with rights including the following (some of which are also applicable under Alberta law as described above):
- Right of access and portability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it ported to another data controller.
- Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed, or where we have no other lawful basis for retaining the information.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you.
- Right to object. The right to object, on grounds relating to your particular circumstances, to the processing of your personal information, and to object to the processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
- Right to non-discrimination. The right to non-discrimination for exercising your rights as outlined in this policy. This includes, but is not limited to, denying you goods or services, charging you different prices for similar services, or providing a different level or quality of service as a result of your exercising your lawful rights.
If you wish to exercise one of these rights, subject to it being available to you under applicable privacy law, please contact us using the contact details at the end of this Policy.
17. Contacting Inova Group ULC
If you have any questions with respect to our policies concerning the collection, use, disclosure or handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, or if you are dissatisfied with how we handle your personal information, please contact our Privacy Officer at:
Phone (403) 831 2912
Fax (800) 517 7560
#317, 612 500 COUNTRY HILLS BLVD NE CALGARY ALBERTA T3K5K3
If you remain dissatisfied after our Privacy Officer has reviewed and responded to your concern, or have other concerns or questions, you have the right at any time to contact the Office of the Information and Privacy Commissioner at:
Office of the Information and Privacy Commissioner
# 410, 9925 – 109 Street