Privacy Policy – Key Points

SCREENPRO SECURITY LTD. (“Company”, “We”, “Us” and similar terms) understands that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Policy (the “Policy”). You can obtain more information about how we collect, use, disclose and protect your personal information by reviewing our full Policy or clicking on the links provided below. We encourage you to read the full Policy, as it contains important information for you.

We will only collect, use and disclose your personal information lawfully and responsibly in order to provide our services to you.

What personal information do we collect?

  • We collect personal information that Tested Persons or Requisitionists provide to us directly, when such individuals download or register for the Screenpro testing online booking website (the “Website”), including: full name, phone number, email address, date of birth, address, and passport number; 

  • We collect personal information when Tested Persons and Requisitionists scan a QR code, including the date, time and place of such scan; and  

  • We collect personal information We receive in relation to the services We provide to Tested Persons when Tested Persons attend a Collection Station for a Screening Test, including the Results. 

Why do we collect personal information and how is it used?

We only collect and use the personal information We require to provide Our services to Tested Persons and Requisitionists. We collect and use personal information:

  • To verify Tested Persons identifies (e.g. when you visit a Collection Station;

  • To provide Tested Persons and Requisitionists quality services;

  • To match Tested Persons QR codes to their specimens collected at a Collection Station, as well as with their Results; 

  • To confirm and provide Results to Tested Persons and Requisitionists;

  • To help Tested Persons and Requisitionists meet their legal obligations;

  • To communicate with Tested Persons and Requisitionists, including to provide service notifications, customer support, or any information, products, or services requested;

  • To evaluate and improve the Website and ensure the Website functions as it should;

  • For any other purpose that may be identified to Tested Persons and Requisitionists before or at the time the personal information is collected; and 

  • For purposes as mandated by law.

Is personal information shared or disclosed?

  • We disclose personal information to Our third party service providers and affiliates as necessary. Such persons may use such personal information for the same purposes that We use such personal information, including to conduct and process Screening Tests] and provide Results;

  • We disclose personal information to Requisitionists that either provide or scan a Tested Persons’] QR code. Requisitionists may use such personal information for their own purposes and may further disclose such personal information, in accordance with its own policies, procedures, and practices. 

  • We may also disclose personal information in the event of a business transaction, or as required or permitted to comply with any legal requirement, court order or regulatory demand/request (including to public health authorities). We also reserve the right to voluntarily provide personal information to public health authorities in a de-identified and aggregated form.

  • We may also disclose your personal information where permitted by applicable law, if We believe disclosure is necessary or appropriate to protect the rights, property, health or safety of the Company, our affiliates and subsidiaries, our clients, or others.   

What are the risks / consequences? 

  • The personal information that is provided via the Website may be used by Requisitionists to make certain decisions about Tested Persons. For example, a Requisitionist may deny entry to Tested Person to their establishments based on a ‘positive’ Result, which could result in loss of income or other consequences. In addition, Requisitionists may use personal information that you provide via the Website in connection with disciplinary actions or legal proceedings, including if you provide false or misleading personal information. Requisitionists may also retain, use or disclose your personal information for a purpose other than those described in this Policy.

  • Although We take steps to safeguard the personal information under our control, "perfect security" does not exist online. It is possible that third parties may unlawfully intercept or access such personal information.

What else should you know?

  • Personal information collected via the Website will be stored in Canada, and therefore, may be accessible to courts, law enforcement, and national security authorities in either or both of these countries.

  • Personal information will be accessible to the following categories of individuals within our organization: the Customer Success Team; the Database Management Team; the IT Operations Team; the Quality Assurance Team; the Account Management Team; and the Product Development Team.

  • Tested Persons and Requisitionists have the right to access and rectify their personal information, subject to certain permitted and required exceptions under applicable law. 

  • Tested Persons and Requisitionists can contact Us with questions, including questions about Our collection of personal information, and if such Tested Person or Requisitionist is located in Canada, questions regarding collection, use, disclosure or storage of personal information by Our service providers and affiliates outside Canada (or to obtain written information about Our policies and practices with respect to such service providers and affiliates).

Privacy Policy

Last modified: November 2, 2020

Introduction

SCREENPRO SECURITY LTD. (“Company”, “We”, “Us” and similar terms) respects your privacy and takes steps to protect it through our compliance with this Privacy Policy (the “Policy”). This Policy describes: 

  • The types of personal information collected, accessed, used, or otherwise processed through the  website (the “Website”);

  • Our practices for collecting, using, maintaining, protecting, and disclosing that personal information; and

  • How personal information is shared, including (without limitation) with you as our employee or visitor (“Tested Persons”) or as an employer or proprietor (a “Requisitionist”), with your Requisitionist if you’re a Tested Person, and with third parties in connection with a Tested Person’s attendance at a collection station (a “Collection Station”) for screening and medical diagnostic testing for infectious diseases (a “Screening Test”). 

This Policy applies only to information about identifiable individuals (“personal information”), which We collect through the Website and other electronic communications sent through or in connection with the Website.

This Policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through the Website; 

  • You provide to, or is collected by, any third-party (including your Requisitionist); and 

  • Information that is not about an identifiable individual, where there is no serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.

Our websites, our other apps, and other third-parties may have their own privacy policies, which We encourage you to read before providing personal information on or through them.

Please read this Policy carefully to understand our policies and practices regarding personal information and how We will handle it. If you do not agree with our policies and practices, do not download, register with, or use the Website. By downloading, registering with, or using the Website, you agree to this Policy. This Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of the Website after We revise this Policy means you accept those changes, so please check the Policy periodically for updates.

Users Under the Age of 18 

The Website is not intended for use by individuals under 18 years of age, and We do not knowingly collect personal information from individuals under the age of 18. If We learn we have collected or received personal information from a user under the age of 18 without verification of parental consent, We will delete that personal information.

Information We Collect and How We Collect It 

We collect personal information from and about users of the Website, on behalf of Requisitionists, as follows:

  • We collect personal information about Tested Persons, directly from Tested Persons or Requisitionists when it is provided to Us when downloading and registering to use the Website ;

  • We collect personal information about Tested Persons, from such persons’ Requisitionist when that Requisitionist causes them to use the Website or to provide personal information required for the Website to function; 

  • We collect personal information when a QR code is scanned by a Tested Persons or a Requisitionists; 

  • Certain personal information is collected automatically when you use the Website; and 

  • We keep records and copies of correspondence with you and your representative(s), including email addresses and phone numbers, if you contact Us. We may also ask you for personal information when you report a problem with the Website.

Registration Information

When a Tested Person or a Requisitionist accesses, downloads, registers with, or uses the Website, We may ask for certain personal information, including: full name, phone number, email address, date of birth, address, and passport number. 

Scanning of QR Code 

When a Tested Person scans a QR code at a Collection Station to submit to a Screening Test, we will record the date, time, and place of Collection Station.  The QR code will attach to that Tested Person’s Screening Test. 

Screening Test Results

When we receive the results to a Screening Test (the “Results”), we will record the Result as either “positive” or “negative” and any other personal information deemed necessary. The Results of a Screening Test will be linked to the QR code initially scanned at the Collection Station. The Tested Person and Requisitionist will be notified of the Results when they become available on the ScreenPro Testing Platform/Pandimik Dashboard. 

Our system will store a copy of the Tested Person’s personal information (i.e., name and a “positive” or “negative” depending on the Results) as well as a copy of the interaction between a Tested Person’s or Requisitionists device and the QR code with the Website. 

Automatic Information Collection and Tracking 

When Tested Persons or Requisitionists download, access, and use the Website, the Website may use technology to automatically collect: 

  • Usage Details: When an individual accesses or uses the Website, we may automatically collect certain details, including page views, clicks, communication data and any other resources accessed or used on or through the Website.

  • Device Information: We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and mobile network information.

The technologies we use for automatic information collection may include: 

  • Cookies (or mobile cookies): A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App. 

  • Web Beacons: Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, verifying system and server integrity).

Such technologies are required for the Website to function.  The Website does not currently use cookies for purposes other than functionality (e.g., for advertising purposes). 

How We Use Personal Information

We use the personal information that We collect, or that is provided to Us, in order to:

  • Complete and analyze a Tested Persons’ Screening Test and record the Results;

  • Provide our services to Tested Persons and Requisitionists, as the case may be, including providing Results on the ScreenPro Testing Platform/Pandimik Dashboard;

  • Assist Tested Persons and Requisitionists, as the case may be, to meet their legal obligations, including with respect to screening Tested Persons for risk factors associated with contagious illnesses, logging their personal information, and complying with any reporting obligations associated with health risks; and

  • The usage details and device information collected via the Website is used to ensure that the Website functions as it should, and to evaluate and improve the Website.

Disclosure of Your Information

We only use the Tested Persons’ personal information that such individuals or their Requisitionists provide to Us as required to provide Our services and for the operation of the Website. We may disclose personal information that We collect or that is provided to Us, as follows:

  • We limit access to any of your personal information to qualified medical and service provider professionals as required. Laboratory technologists, technicians and scientists will see your personal information as necessary for the testing process; 

  • Results may be reviewed by a Medical Professional before they are released; 

  • We share Results with Tested Persons and their Requisitionists on the Screenpro testing online booking website ; 

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding;

  • For any other purpose disclosed by Us when you provide the personal information, with your consent or the consent or the relevant individual (express or implied, as appropriate, in accordance with applicable laws);

  • Where required by applicable law, including to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

  • To government and regulatory bodies and institutions when required by law, including public health authorities.  We also reserve the right to voluntarily provide personal information to public health authorities in a de-identified and aggregated form; and 

  • Where permitted by applicable law, including, without limitation, to the extent permitted if We believe disclosure is necessary or appropriate to protect the rights, property, health or safety of the Company, our affiliates and subsidiaries, our clients, or others. 

Personal information that is disclosed to Requisitionists will be handled in accordance with the privacy and data protection policies, procedures and practices of that Requisitionist. Requisitionists may also further disclose your personal information to third parties at their discretion. We are not responsible for the actions or omissions of Requisitionists, including for any use or disclosure of your personal information (or failure to protect your personal information) by Requisitionists. If you have any questions regarding how your personal information will be handled by a Requisitionist, you should contact that Requisitionist directly.

Some of our affiliates, subsidiaries and service providers may be located outside the country in which you reside.  Personal information will be stored in Canada, and therefore, may be accessible to courts, law enforcement, and national security authorities in either or both of these countries. 

The personal information that We collect, store or otherwise process, is accessible to the following categories of individuals within our organization: the Customer Success Team; the Database Management Team; the IT Operations Team; the Quality Assurance Team; the Account Management Team; and the Product Development Team.

Risks and Consequences

The personal information that you provide to Us may be used by a Requisitionist to make certain decisions about you. For example, a Requisitionist may deny you entry into their establishment, which could result in loss of income or other consequences. In addition, a Requisitionist may use personal information that you provide via the Website in connection with disciplinary actions or legal proceedings, including if you provide false or misleading personal information. As noted above, a Requisitionist may also use or disclose your personal information for a purpose other than those described in this Policy.

Consent

We operate on the order of a Screening Test by Tested Persons or a Requisitionist. Therefore, consent may be implied for some defined circumstances. When you visit a Collection Station for a Screening Test and scan your QR code, we rely on implied consent, not only to carry out those tests but to collect, use, and disclose personal information as necessary to provide Tested Persons and Requisitionists Our services. 

Retention of Your Information

Your personal information will be kept in Canada. We will retain your personal information for as long as necessary for the purposes set out in this policy. We will also retain your personal information to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise required or permitted by applicable law. If you no longer want us to use your personal information you may close your account by contacting us to make such a request as set out below (see Contact Information), subject to providing satisfactory proof of identity where applicable.

Please note that Requisitionists may retain and continue to use and disclose any personal information about you that was disclosed to such third parties by Us prior to closure of your account.  Requisitionists should be contacted directly to withdraw a Tested Persons consent to their continued use or disclosure of their personal information.  

Accessing and Correcting Your Personal Information

Individuals who wish to access, erase, change, rectify, update or restrict the processing or object to the processing of any personal information, may contact us to make such a request as set out below (see “Contact Information”), subject to providing satisfactory proof of identity where applicable. Such requests will be considered, and handled in accordance with the applicable laws in the relevant jurisdiction. 

Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  We will not use the information obtained from the Website for those purposes. 

Data Security

We have implemented measures designed to secure personal information from theft, accidental loss, and from unauthorized access, use, alteration, and disclosure. All personal information that you provide to Us, or that We otherwise collect in connection with the Website, is encrypted and stored on our secure servers behind firewalls. 

The safety and security of the personal information also depends on you. Where We have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential and secure. We recommend that you choose a secure password, and We ask you not to share your password with anyone. 

Unfortunately, the transmission of personal information via the internet and mobile platforms is not completely secure. Although We take steps to protect the personal information that is provided to Us, We cannot guarantee the security of personal information transmitted through the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures We implement.

Changes to Our Privacy Policy

We may update this Policy from time to time. If We make material changes to how We treat the personal information, We will post the new privacy policy on this page with a notice that the Policy has been updated, and We will also notify you of material changes by email at the email address specified in your account.

The date the Policy was last revised is identified 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 this Policy to check for any changes.

Contact Information

You may contact our General Counsel at , 625 Howe st, Suite 260, Vancouver, BC, V6C 2T6 or  (+1) 416-803-0698 in order to:

  • Ask questions, make a complaint, or otherwise comment about this Policy, our collection, use or disclosure of your personal information, or our privacy and personal information handling practices;

  • Access, correct or update your personal information, to the extent you are not able to do this by logging into the Website or the web portal and visiting your account profile page; 

  • Withdraw consent to continued use and disclosure of personal information, subject to any legal restrictions and reasonable notice; and

  • If you are located in Canada, obtain written information about our policies and practices with respect to our service providers outside Canada (including affiliates that provide a service to Us), or to ask questions about the collection, use, disclosure or storage of personal information by such service providers and affiliates.