This Canada Privacy Policy describes the personal information TheKey, LLC and TheKey affiliated companies, including HCA Home Care Assistance Canada, Inc. and other affiliated entities operating in Canada (collectively, “TheKey”) collect online and offline, and how we use and disclose this information. By using our Services or by choosing to give us personal information, you signify your consent to this Privacy Policy and to the collection, use and disclosure of your personal information as set out in this Privacy Policy. This policy does not apply to (i) TheKey personnel or job applicants seeking employment opportunities at TheKey or (ii) personnel working on behalf of business partners with whom we are conducting business.

Our Privacy Officer is our Senior Regulatory, Compliance Manager. The Privacy Officer is generally responsible for ensuring compliance with applicable privacy legislation. The Privacy Officer must approve the policies and practices regulating the governance of personal information. More specifically, this person is responsible for implementing this Privacy Policy and ensuring that it is known, understood and applied.

Our employees who have access to personal information or are otherwise involved in the management of such information must ensure its protection and comply with this Privacy Policy. The roles and responsibilities of our employees throughout the life cycle of personal information may be specified by other policies as well.

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), email address, and other similar identifiers
  
• Additional Data such as: signature, physical characteristics or description, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  
• Personal Classifications: personal characteristics such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical genetic information, disability, citizenship status, and veteran status
  
• Commercial Information: commercial information, including records of account and payment history with TheKey
  
• Online Activity: Internet and other electronic network activity information, including, but not limited to websites, applications or advertisements
  
• Geolocation Data
  
• Sensory Information: audio, electronic, visual, and similar information
  
• Employment Information: professional or employment-related information
  
• Inferences: information about you reflecting your preferences, characteristics, behaviour, or abilities

We may use the categories of personal information listed above for the purposes described in this Privacy policy. In addition, we may use these categories of personal information for certain purposes permitted or required by applicable law.

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this Privacy Policy. For the personal information collected during that time frame, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have shared, and (d) the categories of personal information we may have disclosed for a business purpose.

We may have obtained personal information about you from various sources, as described below.

We may have shared your personal information with certain categories of third parties, as described below.

Our website uses cookies and similar web technologies. Some of these technologies are set by us or third parties and may track you when you leave our website. For more information on the web technologies we use and how you can manage them, please see our Cookie Policy found here [insert Canada cookies policy.]

Some of our digital services, including TheKey website, use Google Analytics Advertising Features and its associated tracking technologies to help display TheKey ads you see on other sites, and to help us manage and optimize our digital advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page. Website users can also access the Google Analytics Opt Out Browser Add-on.

We use commercially reasonable efforts to store and maintain your personal information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to help protect personal information that we control. We have implemented procedures designed to limit the dissemination of your personal information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you, or such purposes required or permitted by law.

Even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

Personal Information that we collect may be stored and processed in Canada, the United States or any other country in which we or our service providers maintain facilities. Personal Information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

By providing us with Personal Information, you consent to any such transfer of information outside of your province or residence (if Quebec) and your country. If you have any questions about our use of service providers outside of Quebec or Canada, you may contact us using the information below.

You have certain choices regarding our use and disclosure of your personal information, as described below:

• Access: You have the right to request that we disclose to you the personal information we have collected, used, or disclosed about you.

• Setting your preferences: You have the right to opt-out of the use of your personal information or restrict the use of your personal information by contacting us for marketing purposes. See below for information on compliance with Canadian anti-spam laws.

• Correction: You have an ability to request correction of your personal information if you believe it is inaccurate.

• Deletion: You may ask us to delete all personal information held about you. In certain cases, this may impact our ability to provide you with services.

To submit a request, or if you have any questions or would like to submit a complaint (additional information set out below) , email us at hcaprivacy@thekey.com, or call us at (888) 601-8638.

We routinely destroy personal information that is no longer required for the purposes for which it was collected, in accordance with applicable laws. We will delete your personal information when it is no longer required to retain the personal information as set out in this Privacy Policy.

We comply with Canada’s anti-spam legislation. You may sign up to receive marketing or promotional communications from us. Where you have expressly opted-in or it is lawful to do so, we may use your personal information to inform you about us and our products and our services, including promotional offers and events. Such information may be sent to you by post, email, telephone or SMS.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

• using the unsubscribe feature found in our emails and other electronic communications;
• if you have created an account on our website, logging into your account and changing your contact preferences; or
• contacting us via email at hcaprivacy@thekey.com.

However, we reserve the right to send you transactional or informational emails such as customer service communications in connection with the website or any services you have received or requested, or changes to our website or our policies.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or correction of your personal information, we may require you to provide certain information to help us identify you. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf

• we may require you to provide the authorized agent written permission to do so, and

• for access and correction requests, we may require you to verify your own identity directly with us (as described above).

Please note that in some cases, we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons.



Complaint Handling Process

Any person who wishes to make a complaint concerning the application of this Policy or, more generally, the protection of their personal information by us, must do so in writing to our Privacy Officer at the e-mail address indicated in the following section.

The individual must provide their name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for the complaint, in sufficient detail to us to evaluate the complaint. If the complaint is not specific enough, the Privacy Officer may request any additional information deemed necessary to assess the complaint.

We undertake to treat all complaints received as confidential. Within thirty (30) days following receipt of the complaint or of all additional information deemed necessary and required by our Privacy Officer in order to process the complaint, the Privacy Officer shall evaluate the complaint and provide a written response. The purpose of this assessment will be to determine whether our handling of personal information complies with this Policy, any other policies and practices in place within the organization, and applicable legislation or regulations.

We shall maintain a separate file for each complaint received, each of them containing the complaint, the analysis and documentation supporting the assessment, as well as the response sent to the person who filed the complaint.

It is also possible to file a complaint with the Commisson d’accès à l’information du Québec in Quebec or any other privacy oversight body responsible for the applicable law. However, we invite any interested party to first contact our Privacy Officer and wait for our process to be completed.

We will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under any applicable Canadian privacy law. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This policy is available in alternative formats upon request. Please contact hcaprivacy@thekey.com to request this policy in an alternative format.