TheKey Canada Caregiver App Privacy Policy
Revised March 29, 2022

This Privacy Policy describes how TheKey, LLC and its affiliated entities, including HCA Home Care Assistance Canada, Inc. and other affiliated entities operating in Canada (collectively, “TheKey”) collects, stores, uses and distributes information through the Caregiver App (the “App”) in Canada. Capitalized terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Conditions for the App, which can be accessed from the menu in the top-right corner of the Caregiver App.
1. Consent.
By using the App, you consent to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy.
2. Collection of Information.
Contact Information

When registering for or accessing the App, you will be required to provide certain information. Such information consists of:
  • Your phone number; and
  • Your Account password.
3. Such information (known as “Contact Information”) ...
Together with any other information we gather through the App that may be used to identify, contact, or locate you individually, are collectively referred to herein as your “Personal Information.” The Personal Information we collect using the App includes:
  • Your self reported “Clock-in” and “Clock-out” times for your workday, and your hours worked; and
  • Your work activities you record in the App.
Data, Diagnostic & Login Information
You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using our App (this is collectively referred to below as “Data”). Some of this Data may be stored and maintained on our servers. If you run into technical errors in the course of using the App, we may obtain a crash report along with certain logging information from your system documenting the error (“Diagnostic Information”). Such information may contain information regarding your Operating System version, hardware, browser version, and your email address, if provided. Additionally, certain login information may be maintained in a cookie stored locally on your personal computing device (i.e. not on a server) in order to streamline the login process (“Login Information”).
Usage & Analytics Information
As you use our App, we may also standard information regarding your mobile device, browser type, browser language, Operating System, and Internet Protocol (“IP”) address. Collectively, this information is referred to as “Usage and Analytics Information.”
Geo-Location Information
When you use our App, we will periodically use GPS technology (or other similar technology) to determine your physical location. This information will be collected only when using the “clock in” and “clock out” functionality. Such information is referred to as “Geo-Location Information.”
4. Use of Information.
We use the information we collect in the following ways:
Use of Information
We use the information we collect in the following ways:
Use of Information
Personal Information
We use this information for identification and authentication purposes, to establish, manage and/or potentially terminate the employment relationship (for example, by determining your clock-in and clock-out times, and provision of client services), to manage your Account, to provide the App, for service improvement, and to address issues like malicious use of the App.
Data, Diagnostic Information and Login Information
We use this information for the purpose of administering services to our clients. We may also use this information to monitor and analyze your use of the App, for the App’ technical administration, and to increase the App’s functionality and user-friendliness.
Usage and Analytics Information
We may use this information to monitor and analyze your use of the App, for the App’ technical administration, to increase the App’s functionality and user-friendliness, and to verify users have the authorization needed for the App to process their requests.
Geo-Location Information
We use this information for the purpose of determining your location when you clock in and clock out in real time when arriving to and leaving from a client’s location. This allows us to ensure you are where you report yourself to be, and supports our management, and/or potentially termination of our employment relationship.
5. Disclosures & Transfers.
Please note that because you are using the App as an employee of TheKey, other TheKey employees may be able to view certain activity and content associated with your use of the App, including, but not limited to, elements of your Personal Information.

From time to time we may employ third parties to help us provide and/or improve the App. These third parties may have access to databases of user information for the purpose of helping us to provide and/or improve the App, or carry out the other purposes we describe in this Privacy Policy.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, our clients, other users of the App, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate reorganization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same.
6. Non-US Users.
The App is hosted in the United States and is intended solely for users located within the United States or Canada working as employees of TheKey. You may not use the App if you are not located within the United States or Canada and working as an employee of TheKey.

Personal Information that we collect may be stored and processed in the United States, Canada, 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 using App or by providing us with Personal Information, you consent to any such transfer of information outside of your country. If you have any questions about our use of service providers outside of Canada, you may contact us using the information below.
7. Security.
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 you provide to us. 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.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your password and personal credentials when you are using the App, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the App.

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.
8. Sharing Information with Third Parties.
You may be able to share Personal Information with third parties through use of the App. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.
9. Retention.
We will keep your Personal Information for as long as it remains necessary for the identified purpose(s), as required by law, or as reasonably permitted as your employer. We may retain certain data as permitted by applicable law, including when necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.
10. Amendment of this Privacy Policy.
We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is updated in the app or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account on the App. The date on which the latest update was made is indicated at the top of this document. We recommend that you revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the App signifies your acceptance of any changes.
11. Access and Accuracy.
We will make reasonable efforts to keep your Personal Information as accurate and up-to-date as needed for the purposes for which we process it, and we will provide you with mechanisms to access, update, correct, or add to your Personal Information as appropriate.

Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where prevented by law or where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and corrections in a timely manner. To request access to your Personal Information, please contact our HR representative at or with your immediate supervisor.
12. Contact Us
If you have any questions regarding this Privacy Policy, any Personal Information you have submitted to us, or if you would like to:
  • access Personal Information that you have already provided to us so that you can correct or update it; or
  • to submit a complaint.
Please advise us by contacting our Privacy Officer by emailing