Effective Date: October 29, 2018

Nevvon Inc. Privacy Policy

Nevvon Inc. and its Affiliates (“Company”, “we”, “our” or “us”) values our customers, including you (“you” or “your”) and we respect your privacy and personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws). This privacy policy (this “Policy”) applies to your use of our websites, hardware, software, apps and/or services (“Products”) and describes the kinds of personal information we collect about you, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information. You may require us to change, amend, or delete the personal information that you have provided to us at any time. “Affiliates” means any entity directly or indirectly controlling or controlled by, or under control with, the Company.

If this Policy changes in the future, we will post an updated version on our website at www.nevvon.com (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways in our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Products after the Policy changed or notice of the change has been given, you will be deemed to have accepted such changes.

1. How We Collect Information

We may collect personal data from various sources, including:

•   Directly from you, at your direction or with your consent
•   Information and content you provide
•   From our vendors and other third parties
•   Automatically, from devices that you use to connect to our ProductsFrom time to time, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use such third party information to verify professional affiliations or to better understand your interests by associating demographic information with the information you have provided.

2. Information We Collect

When you use our Products, we collect the following types of information:

(a)  Account information: When you use our Products you may need to create an account with us. In order to create an account, you will need to provide us with login credentials (which include your username and password), your full name, email address, zip/postal code and postal address, mobile phone number, and social security number (if applicable).

1. (b)  General usage data: When you use our Products we may collect technical properties of hardware and software utilized in conjunction with our Products. For example, we may collect the type and model of hardware and/or web browser you are using, referring or exit web pages, and the operating system version you are using.
2. (c)  Third party information: If necessary to fulfill our identified purposes, we may combine the information you submit to us with information obtained from other sources or third party offerings. For example, we may receive personal information about you from third parties involved in providing you with the products, services, hardware, software, and websites you are utilizing, such as from your email, calendar, and online file storage provider to facilitate the integration of those products, services, software, and websites with our Products. We treat all such personal information in accordance with this Policy and the terms and conditions between us and such third parties, if any, may also apply. However, the third party’s own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is one of our service providers.

4. (d)  Quality assurance and customer service: Your customer service telephone calls, instant messages through the Nevvon App, and emails with us and our service providers, if any, may be recorded, logged, and/or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to our Products and customer service. As part of the recording and logging of the calls and emails, we will collect information like the identity of the caller or sender of email, the date and time of the call or email, and the subject and resolution of the issue.
5. (e)  Cookies: In addition, when you visit our Website, we collect certain information about your activity on our Website, as described below under the heading “Our Use of Cookies, Log Files, Web Beacons, and Embedded Scripts.
6. (f)  Information about use of our Products: We collect information about how Nevvon users interact with our products and services. For example, we may collect information about your purchase history, program completion, and information about how you engage with our Website. When you use our Products, we will collect the following information:
   1. (i)  date of onboarding
   2. (ii)  picture
   3. (iii)  agencies you are working for (if a caregiver)
   4. (iv)  what lessons were purchased
   5. (v)  name of managers
   6. (vi)  the programs a care agency has purchased on behalf of caregivers
   7. (vii)  behavioural data gathered while the caregiver is using the system (lessons taken, test scores, questions asked etc.)

Some information we collect would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.

3. Our Use of Information We Collect

We use the personal information we collect about you:
(a) for purposes related to providing lessons with respect to long-term patient care;

2. (b)  to understand and meet your needs and preferences, and/or to provide you with our Products, for example:
   1. (i)  for purposes related to providing lessons with respect to long-term care through our Products;
   2. (ii)  for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, upgrade, or update of Products;
   3. (iii)  to ensure Products are technically functioning as intended and to help identify and troubleshoot issues;
   4. (iv)  to fulfill or enforce any agreements or notices we provide and are associated with a particular Product (“Notices”);
   5. (v)  to manage or respond to your inquiries;
3. (c)  to develop new and enhance existing Products including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or notices of upgrades or updates of Products;
4. (d)  to manage and develop our business and operations, for example;
   1. (i)  to allow for business continuity and disaster recovery operations;
   2. (ii)  to enforce our legal rights;
   3. (iii)  for statistical purposes;
   4. (iv)  to meet legal and regulatory requirements and to respond to emergency situations
5. (e)  to respond to court orders, warrants or other lawful requests or legal processes;
6. (f)  to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
7. (g)  for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.

Notwithstanding anything to the contrary contained in this Policy, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information. We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.

You may update your communication preferences anytime by writing us at getintouch@newsite.nevvon.com

4. To whom we Disclose your Personal Information

In accordance with this Policy, we may share your personal information:

1. (a)  within Company and/or with our service providers such as a cloud service provider in Canada, the United States, and the European Economic Area for data storage;
2. (b)  with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
3. (c)  if we have your consent;
4. (d)  with third parties involved in providing our Products to you which may include authorized resellers, distributors, and merchants of record or payment processors;
5. (e)  and any and all information about your use of the Products with your employer or its agents if your employer has provided you with access to the Products;
6. (f)  as necessary to complete any transactions while using our Products;
7. (g)  respond to a subpoena, order, legal process, or government request;
8. (h)  protect, establish or exercise our legal rights or defend against legal claims;
9. (i)  investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;
10. (j)  as otherwise required by law; or
11. (k)  if we are to be sold, merged, or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

5. Your Decisions About Your Personal Information

At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information, by writing to us at 1140 Sheppard Avenue West, Unit 12, Toronto Ontario M3K2A2 Canada. You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us. However, even if you opt out of receiving such communications, we retain the right to send you certain other types of communications (such as information about your purchases or changes to our Privacy Policy or Terms of Use).

If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Please note that we may need to retain certain personal data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

Generally, you may withdraw at any time your consent for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your personal information as may be required to provide you with our Products, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Products.

6. Our Use of Cookies, Log Files, Web Beacons, and Embedded Scripts

When you visit the Website or use the Nevon App, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Website), and embedded scripts (programming code that is designed to collect information about your interactions with the Website, such as the links you click on, and which is active only when you are accessing the Website).

The information we collect in this manner may include details about the computer, mobile phone, or other device used to access the Website (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.

We may use third-party web analytics services to help us analyze how visitors use the Website. We may permit these third parties to operate directly on the Website, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.

The information we collect in this manner is collected to enhance your user experience. For example, this information allows us to pre-fill form fields as well as provide you with contextual recommendations while using the Website.

When you visit our Website or use the Nevvon App, we may allow some third parties (such as advertising networks and data analytics companies) to collect information about your online activities over time and across different websites.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please note that not all tracking will stop even if you delete cookies.

In some instances, we may also combine information we receive about you from third parties with information we collect through the Website.

7. Security

We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.

We limit access to your personal information within Nevvon to individuals with a need to know.

8. International Data Transfers

We may transfer your personal data for processing in countries other than the country in which you initially provided the information for the purposes described in this Policy. For example, if you are located outside of Canada, we typically transfer and process all personal data in the Canada, where we are headquartered. The countries to which we transfer personal data may not guarantee the same level of protection for personal data as the one in which you reside. Where required by certain jurisdictions, we will transfer your information subject to jurisdiction-approved safeguards, such as standard contractual clauses.

If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, by using our Products, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of us.

9. Links to Other Sites

We provide links on our Website to third party sites we think you will enjoy. These sites operate independently of us and may have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is subject to that third party’s privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

10. Children’s Online Privacy Protection

The Website and Products are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.

11. California Residents – Your California Privacy Rights

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request by email to getintouch@newsite.nevvon.com or write to us at Nevvon Inc., 1140 Sheppard Avenue West, Unit 12 Toronto Ontario M3K2A2. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

12.

Our site uses technologies of  third-party partners to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the products and/or services that are likely to be of more interest to you. Specifically, our partner collects information about your activity on our site(s) to enable us to:

• measure and analyze traffic and browsing activity on our site(s);

We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with our advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross device capabilities please refer to NextRoll’s Privacy Notice.  

13. Questions or Comments

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by delivery in person, by courier or by the mail, to us at Nevvon Inc., 1140 Sheppard Avenue West, Unit 12 Toronto Ontario M3K2A2, or by calling us at 1-855-963-8866. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).