NexJ Health Inc. Privacy Notice

NexJ Health Inc. (“NexJ Health”) is committed to respecting the privacy of our website users. This document describes our practices regarding the collection, use and sharing of your personal data, which are defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

This statement applies with respect to personal contact information we collect from www.nexjhealth.com. This statement is part of our Terms of Use and is subject to all of its terms. Below is information regarding the commitment of NexJ Health to protect the personal data of its website users. For the NexJ Connected Wellness application (www.connectedwellness.com), the Privacy Notice can be found at https://www.connectedwellness.com/privacy-notice/.

About NexJ Health

NexJ Health is a provider of patient-facing population health management solutions that support patient engagement for chronic disease management. At NexJ Health, we believe that the most efficient and cost-effective way to offset the rise in chronic disease is to empower patients, with the support of their families, friends, and healthcare professionals, to actively participate in managing their own chronic condition(s). By engaging patients through our PHIPA, PIPEDA and GDPR compliant platform NexJ Connected Wellness, patients are more likely to achieve their health goals, payers can lower costs, providers can improve care to patients, and pharmaceutical manufacturers and pharmacies can improve medication adherence. For the Privacy Notice for NexJ Connected Wellness see https://www.connectedwellness.com/privacy-notice/. For more information about NexJ Health visit www.nexjhealth.com, e-mail info@nexjhealth.com, or call 416-227-3700.

Data Protection Officer

NexJ Health’s Data Protection Officer (DPO) is Christopher Parisien. The DPO is responsible for overseeing the data protection strategy and implementation according to current legislation at NexJ Health. His contact information is at the bottom of this statement.

Personal Data

NexJ Health uses the information collected from you to send you marketing and product information which NexJ Health believes may be of interest to you or your company.  You will be given an opportunity to opt-in to receiving information about NexJ Health’s promotions and products.

How do we collect personal information?

NexJ Health collects personal contact information (“Personal Contact Information”) when you register for an account on https://community.nexjhealth.com to access customer-facing documentation or submit a form on www.nexjhealth.com to attend a seminar or participate in an online forum or survey, when you ask to be included in an email or other mailing list, or you submit an entry for promotions, or when you submit your personal contact information to NexJ Health for any other reason.

NexJ Health may supplement the Personal Contact Information that you provide to us via the website or we receive from third parties with public information available on the internet from your employer’s website, from business networking websites like LinkedIn and from information gathered by communicating with you by telephone, email or in person.

When you access our website NexJ Health tracks your IP address. We may also associate information with your IP address including geographical, corporate, network information and the identity of individuals who have accessed our website from the same or similar IP addresses in the past provided they have provided this information to us as outlined above. NexJ Health may also store information on how you found our website. NexJ Health gathers certain information about you based upon the pages that you access in our website. This information may include the URL of the website that you just came from, which URL you next go to and what browser you are using (“IP Information”).

What personal information do we collect from individuals?

Generally, Personal Contact Information is contact information like your name, title, address, email and telephone number. NexJ Health may also collect publically available information like biographical information from your employer’s website or information from your profile on business networking sites like LinkedIn. If you have a publically available photograph or you provide us with a photograph NexJ Health may store a photograph with your Personal Contact Information. NexJ Health may also store additional personal information like interests with your Personal Contact Information.

NexJ Health collects IP information related to your use of our website including how you found the website, what pages you view and how long you spend on the website.

How do we use your Personal Contact Information?

The primary use of your Personal Contact Information and IP Information is to maintain strong business relationships with our customers, partners and potential customers and partners. During the sales process NexJ Health uses a strategic selling methodology to identify sales opportunities and establish and maintain the relationships with the employees and agents of the potential customer required to manage a complex sales process.

NexJ Health also uses Personal Contact Information and IP Information to verify compliance with customer contracts, track downloads and use of information, to enforce terms of service, to ensure security of its website and systems and detect inappropriate or illegal conduct.

NexJ Health uses individual and aggregated non-identifiable personal information to provide better customer service and improve its marketing. NexJ Health uses Google Analytics to get insight into its web traffic and marketing effectiveness. More information on Google Analytics can be found at: http://www.google.com/analytics/

With whom do we share your Personal Contact Information?

Your Personal Contact Information may be shared with NexJ Health offices or subsidiaries around the world. All such entities are governed by this Privacy Notice and any other rules or agreements required to comply with applicable law.

Your Personal Contact Information is never shared outside NexJ Health without your permission, except under conditions explained below.

NexJ Health may send your Personal Contact Information to other companies or people under any of the following circumstances: when we have your consent to share the information; we need to share your information to provide the product or service you have requested; we need to send the information to companies who work on behalf of NexJ Health to provide a product or service to you (we will only provide those companies the information they need to deliver the service); or we want to keep you up to date on the latest product announcements, software updates, special offers or other information we think you’d like to hear about either from us or from our business partners (unless you have opted out of these types of communications). We will also disclose your Personal Contact Information if required to do so by law, to enforce our Terms of Use or other contractual agreements, or in urgent circumstances, to protect personal safety, the public or our websites.

How do we use cookies?

Like many other websites, our website utilizes a standard technology called a “cookie” to collect information about how our website is used. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Cookies were designed to help a website recognize a user’s browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site. For example, cookies can securely store a user’s password, personalize home pages, identify which parts of a site have been visited or keep track of past selections.

We use cookies for the limited purposes of enhancing your visit to our website and to enable us to track and target the interests of our users. A cookie cannot be read by a website other than the one that set the cookie. No other company will have access to our cookies. A cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your email address.

Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. It is important to note that you may not be able to use certain features on our website if you choose not to accept cookies.

Legal basis for processing any personal data

The legal basis for the collection and processing of any personal data is to meet NexJ Health’s obligations to potential clients, clients and employees.

Consent

By agreeing to this privacy notice you are consenting to NexJ Health collecting and processing your personal data for the purposes outlined.  You further consent to the disclosure of personal data and any other privacy practices set out in this privacy notice.  NexJ Health expressly reserves the right to change this privacy notice at any time. Please check here regularly to see the latest version of this policy.

You can withdraw consent at any time by emailing dataprotection@nexjhealth.com with subject:  Web Privacy or by writing to the Data Protection Officer at the contact details below.

Social Media

If you are using NexJ Health’s social media, please remember that NexJ Health’s social media are provided via social media sites, which have their own functionality, terms and privacy policies.  You should be aware that these functions are part of the social media site and are subject to the social media site’s terms and privacy policy and not those of NexJ Health.  Please ensure you have read these carefully and have checked your personal settings to ensure you are content with how your information will be used by the social media site.  NexJ Health’s social media may make use of these functions, but NexJ Health does not control them and is not responsible for them.  NexJ Health will not assume responsibility for data shared or the responsibility of a data controller, that responsibility will remain with the social media provider.

NexJ Health will monitor the social media site on occasion and, as soon as practically possible, any inappropriate entries will be removed.

Disclosure

NexJ Health may, on occasion, pass your personal data to third parties exclusively to process work on its behalf.  NexJ Health requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and any other applicable laws or regulations.

NexJ Health does not broker or pass on information gained from your engagement with NexJ Health without your consent.  However, NexJ Health may disclose your personal data to meet legal obligations, regulations, or valid governmental request.  NexJ Health may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of NexJ Health, its clients and/or the wider community.

Retention Policy

NexJ Health will process personal data and will continue to store only the personal data needed unless otherwise requested by the data subject.

Data Storage

Data is held in secure cloud-based servers managed by NexJ Health. Physical and electronic access to these servers is strictly controlled.

Your rights as a Data Subject

At any point while NexJ Health is in possession of or processing your personal data, all Data Subjects have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

If NexJ Health refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to challenge legally.

NexJ Health, at your request, will confirm what information it holds about you and how it is processed.

You can request the following information

  • Identity and the contact details of the person or organisation that has determined how and why to process your data.
  • Contact details of the Data Protection Advisor, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of NexJ Health or a third party such as one of its clients, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients to whom the data are/will be disclosed.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the Office of the Information Commissioner (Data Protection Regulator).
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access personal data held, identification will be required

NexJ Health will accept the following forms of identification when information on your personal data is requested.  A copy of your driver’s license, passport, birth certificate and utility bill, bank statement, or credit card statement not older than three months old.  A minimum of one piece of photographic identification listed above and a supporting document is required.  If NexJ Health is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to dataprotection@nexjhealth.com with subject: Data Access Request.

Complaints

If you wish to make a complaint about how your personal data is being processed by NexJ Health or its partners, you have the right to complain.  If you do not get a response within 30 days, you can complain to your local supervisory authority.

How do I update, change or delete my personal information or contact you with concerns?

For questions or concerns regarding your personal information and our website privacy policy, or to update, correct or delete your personal information, please contact:

Christopher Parisien
Data Protection Officer
NexJ Health
10 York Mills Road, Suite 700, Toronto, ON M2P 2G4

Or by email: dataprotection@nexjhealth.com
Subject: Web Privacy

Note that we may retain changed or deleted information for archival, contractual or regulatory purposes.