Privacy Policy

Last modified: September 23, 2024

Effective date: September 23, 2024

Canadian Medic-Alert Foundation Incorporated d.b.a MedicAlert Foundation Canada (“us,” “we,” “our” and “MedicAlert”) is a registered Canadian charity. We have protected more than a million people in Canada since 1961 through a variety of our service plans, applications, products, and services.

MedicAlert is subject to the Personal Information and Protection of Electronic Documents Act, S.C. 2000, c. 5 (PIPEDA). In accordance with PIPEDA, MedicAlert is accountable for the protection of the personal information you provide us, and we consider this protection of privacy a vital component of the relationship with our subscribers. To demonstrate our compliance and commitment to protecting your privacy, we have developed this Privacy Policy (“Privacy Policy”). This Privacy Policy explains who we are, how we collect, use, and disclose Personal Information, and how you can exercise your privacy rights.

You must read this Privacy Policy in full to ensure you are fully aware of what information we collect, use, and disclose, and how we go about these practices. It is understood that by agreeing to our Subscriber Agreement (found here:  https://www.medicalert.ca/subscriber-statement), accessing and/or using our website (www.medicalert.ca), its related webpages and application (collectively, the “Website”), Products or Services, or engaging in our Initiatives you agree to all the terms and conditions of this Privacy Policy and the Website Terms of Use (found here: https://www.medicalert.ca/terms-and-conditions), which are incorporated herein by reference. If you do not agree to any of the terms and conditions in this Privacy Policy or the Terms of Use, please refrain from accessing MedicAlert’s Website or Services.

Privacy Policy – Contents

1. 1. How can you control your privacy choices with MedicAlert?

1. Definitions
2. Purposes for Collecting Personal Information
3. Consent
4. Information we Collect
5. Use of Personal Information
6. De-Identification and Aggregation of Data
7. Cookies and Tracking Technology
8. Sharing and Disclosure of Personal Information
9. Transferring Your Personal Information
10. Limiting Disclosure
11. Accuracy of Data
12. Access to Your Personal Information
13. Our Security
14. Data Retention
15. Minors
16. Changes to this Privacy Policy
17. Contact Us

PRIVACY POLICY AT A GLANCE

You have the right to know how MedicAlert collects and uses your Personal Information and to whom we may disclose this Personal Information. The following table provides a summary of the essential details about our Personal Information practices:

HOW CAN YOU CONTROL YOUR PRIVACY CHOICES WITH MEDICALERT?

1. Marketing: You can opt out of receiving marketing messages from us at any time by following the unsubscribe instructions included in each of our marketing messages, by selecting “NO” under the My Communication Preferences section of your online profile, or by contacting us directly using the information below.
2. Access and Corrections: You may contact us at any time to access, update, correct, or delete any information we have about you, subject to any legal or contractual restrictions.
3. Cookies: You may disable cookies and other online tracking by declining cookies when you visit the Website or through the settings in your browser.  

Contact Us: If you wish to discuss our compliance with this policy, your privacy rights, or our use of your information, please contact our Privacy Officer or call us using the contact information below.

PRIVACY POLICY: TERMS AND CONDITIONS

1. DEFINITIONS

In this Privacy Policy, these phrases have the following meanings:

“Authorized Representative” means an individual other than the Subscriber, who has the authority to register a Subscriber for MedicAlert Services and, subsequently, manages the Subscriber’s profile on the Subscriber’s behalf. An Authorized Representative may be a legal guardian of a Subscriber, a close relative of a Subscriber, a professional or other individual with a duty of care to a Subscriber, or a person identified at the time of registration as being an individual that the Subscriber has given consent to engage with MedicAlert on the Subscriber’s behalf. For the purposes of this Privacy Policy, an Authorized Representative may also be referred to as “you”or “your” as applicable.

"Personal Information" means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information. Personal Information does not include de-identified, anonymous, or aggregate information that cannot reasonably be associated with a specific individual. Personal Information includes medical information.

“Product” means a MedicAlert ID, or other item offered from time to time by MedicAlert.

“Profile” means the profile populated by MedicAlert when you register for Services that is updated and kept accurate by you. It contains complete Subscriber information including contact details, medical information, Personal Information, and other relevant information that may be provided for emergency use.

“Service” means MedicAlert’s array of backend and frontend emergency response services provided to its Subscribers, including, but not limited to, the process of providing Responders with Subscriber information during an emergency.

“Initiatives” means educational, growth, and outreach programs, and research activities conducted by MedicAlert or in partnership with another organization in advancement of our charitable mission.

“Responder”means an individual that calls the MedicAlert Hotline or otherwise connects to a MedicAlert system inquiring about a Subscriber and includes, but is not limited to, personnel at police departments, fire departments, dispatch services, emergency health services, and health professionals.

“Subscriber”,“you”, and "your” means any person that visits any of our MedicAlert websites, that is registered with us, either on behalf of themselves or another individual, to use our Products and receive our Services through a service plan or otherwise engages with MedicAlert through an Initiative.

“Subscriber Event”means an emergency, medical, or personal safety event that a Subscriber is experiencing that requires immediate action. This will often involve the use of Services and contact with Responders.

2. PURPOSES FOR COLLECTING PERSONAL INFORMATION:

MedicAlert collects your Personal Information to deliver our Products and Services. These purpose(s) include(s):

• to administer our Products and Services that you request from us;
• to engrave medical information on your MedicAlert ID or print it on a wallet card;
• to provide Responder’s with access to important information during a Subscriber Event;
• to maintain a responsible service relationship with you;
• to conduct, enhance, or market our Initiatives, including processing any related transactions or circulating information;
• to determine eligibility for our subsidized programs;
• to provide claims information to third-party partners;
• to enhance or market our Products and Services;
• to conduct research using data that has been de-identified;
• to maintain and improve the security and functionality of the MedicAlert Website and its related applications;
• to authenticate your identity;
• to allow you to participate in any of our forums or promotions;
• to monitor compliance with our agreements with you;
• to improve the content and operation of the Website;
• to maintain legislative and regulatory compliance;
• to provide newsletters, electronic messages, and information you request from us; and
• for other purposes we may inform you about from time-to-time.

For us to provide our Products, Services, and Initiatives certain information will be requested of you. We only collect the Personal Information that you voluntarily provide to us, however, given the nature of our Services, declining to provide certain Personal Information may negatively impact our ability to administer our Services and provide relevant and vital information to Responders during a Subscriber Event.

3. CONSENT

When purchasing a Medical ID and completing your online profile, registering for our Services, purchasing our Products, or otherwise engaging us, you will be asked to provide Personal Information, including medical information, further, other information, like Website usage, may be collected from time to time. In providing this information, you understand and consent to the collection, use, disclosure, retention, and disposal, where applicable, of that Personal Information, as described herein. If there is any Personal Information that you do not wish to provide consent regarding, you must not provide it on your Medical ID or online profile. However, refusing to provide certain information, may limit our ability to provide you with certain Services.

If you would like to withdraw your consent, and thereby, cancel your MedicAlert services, you can close your account online or by phone at any time. This can be done online on your profile under MyAccount or by calling us at the number below. Cancellation will trigger the removal and/or de-identification of your Personal Information. Please note, upon cancellation you will no longer receive our Services and you must stop wearing your Medical ID.

If MedicAlert wishes to use your Personal Information for any purposes outside those described in this Privacy Policy, we will seek additional consent from you for these purposes.

MedicAlert provides its Products, Services, and Initiatives to individuals of all ages. If you are under the age of 18 (“Minor”), you may not create or manage your own Profile or subscribe to our Services, but a parent or legal guardian may do so on your behalf. The parent or legal guardian will provide consent that they have the authority to create the profile and subscribe to our Services on behalf of the Minor and subsequently shall have access and control of the Personal Information respecting the Minor’s profile until the Minor reaches the age of 18. MedicAlert will contact an Authorized Representative of a Minor when that Minor reaches the age of 17 to discuss the transfer of account ownership.

Consent to Receive Marketing Messages

From time to time, MedicAlert may send you Commercial Electronic Messages or “Marketing Messages”, in accordance with Canada’s Anti Spam Legislation,S.C. 2010, c. 23, if we have your express or implied consent. Upon registering for MedicAlert services, you will be asked for your consent to receive Marketing Messages. Alternatively, if you have made a purchase or inquiry from MedicAlert or donated to or participated in one of our Initiatives, we may also send you Marketing Messages.

If you would like to withdraw your consent, either express or implied, to receive Marketing Messages, you may do so at any time by following the unsubscribe instructions that are contained within every Marketing Message, by updating the Communications Preferences on your online account, or by contacting us directly using the contact information below.

4. INFORMATION WE COLLECT

We collect only the Personal Information required for the purposes set out in Section 2.

The Personal Information that we collect depends on the context of your interactions with MedicAlert, your MedicAlert account settings, and the Products, Services, and features you use. However, the Personal Information we collect is broadly:

1. Information that you provide to us:
   
   You may provide certain Personal Information to us when you sign up for MedicAlert Services, inquire about our Products and Services, attend or be otherwise involved in a MedicAlert Initiative, subscribe to marketing communications, donate money to MedicAlert, consult our customer service team, send us an email or communicate with us in another way, and other user-generated content you provide to us in the normal course of your use of the Website and Services including profile information, comments, suggestions, feedback information, usage information, transaction information and traffic data.
   
   MedicAlert will create an electronic profile with your information when you subscribe to our Services. This information may include Personal Information, such as name and address, gender, age, ethnicity and other socio-demographic information, health information, medical information, payment information, personal description and photograph, phone number(s), phone numbers and email addresses of your emergency contacts and doctors, the content of orders and medical conditions required to be embossed on your MedicAlert products. This profile is managed and updated by you during the course of relationship with MedicAlert.
   
   
2. Information we collect automatically when you use the Website:
   
   When you use the Website, we may automatically collect or receive certain information about your device and usage of the Website (collectively “Service Usage Data”). We use cookies and other tracking technologies to collect some of this information.
   
   Service Usage Data may include:
   • Device information:We collect information about the device and applications you use to access the Website, such as your IP address, your operating system, your browser ID, viewfinder size, and other information about your system and connection.
   • Log data:Our web servers keep log files that record data each time a device accesses the servers and the nature of each access, including originating IP addresses and activity in the Service (such as the date/time stamps associated with the usage, pages and files viewed, searches and other actions taken (for example, which features were used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
   • Usage data:We collect usage data about you whenever you interact with the Website, which may include the dates and times you access the Website and your browsing activities (such as what portions of the Website you used, session duration, links clicked, non-sensitive text entered, and mouse movements). We also collect information regarding the performance of the Website, including metrics related to the deliverability of emails and other communications you send through the Service. This information allows us to improve the content and operation of the Website and facilitate research and analysis of the Website. Service usage data may also be automatically collected by third-party services that MedicAlert uses for the purpose of conducting its business, for example Cloud hosting platforms and Payment processing services. This is limited to collection solely for the purpose of conducting the third party’s business and subject to this Privacy Policy as well as any Privacy Policy that third party has in place.
     
     
3. Information we collect from other sources:
   
   From time to time, we may obtain information about you from third-party sources, such as responders, public databases, social media platforms, third-party data providers, and our joint marketing partners.
   
   Examples of the information we receive from other sources include additional details surrounding a Subscriber event, demographic information (such as age and gender), device information (such as IP addresses), location (such as city, province, and/or postal code), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

5. USE OF PERSONAL INFORMATION

We use the information that we collect about you or that you provide to us, including any Personal Information:

• To present our Website and its contents to you.
• To provide you with information that you request from us about our Products, Services, or Initiatives.
• To fulfill the Purposes for which you provided the information or that were described when it was collected, or any other purposes for which you provide it (including the purposes listed above).
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To determine eligibility for subsidized programs and to properly administer or report on those programs.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• To send you marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions, or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
• To carry out research and development to improve our MedicAlert websites, Products and Services or to conduct research that may be used more broadly to improve health outcomes.
• To de-identify your data as required for organization endeavours.
• To cooperate with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Please note that we may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. We do not disclose your personal information for these purposes without your consent, however, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

6. DE-IDENTIFICATION AND AGGREGATION OF DATA

We may de-identify or aggregate your Personal Information, including such that it cannot reasonably be associated with you, for the following purposes:

1. To protect your privacy and the security of your Personal Information;
2. To conduct analytics and/or research in a privacy protective manner to:
   1. better understand and improve our Products and Services;
   2. operate and expand our business opportunities;
   3. conduct health related research; and
3. Improve health outcomes;
4. Upon termination of your relationship with MedicAlert. For more details see 14. Data Retention below.

We may share such de-identified information or insights with our partners to assist in research, planning, or product and service development. Note that if you cancel your subscription with MedicAlert, your de-identified Personal Information may be maintained for up to two years solely for the purpose of carrying out scholarly research in line with our charitable objectives.

7. COOKIES AND TRACKING TECHNOLOGIES

MedicAlert and other third-party services it uses to process your data may use "cookies" (small text files placed on your devices) and other similar technologiesfor functionality, tracking and advertisement purposes. Cookies are small data files that are stored on a subscriber’s computer for record-keeping purposes. Cookies track where you travel on the website and what you look at. A session ID cookie expires when you close your browser. When you log onto your MedicAlert profile, your browser may ask if you want it to remember that you are a registered subscriber of MedicAlert. If you accept, the session ID becomes a persistent cookie, which remains on your hard drive for an extended period. Cookies are used by most major websites, and you will be asked to consent to their use when you visit the Website. If you wish to disable the use of cookies, you may do so via your browser settings

We use session cookies and usage data to make it possible to navigate the secure environment inside the Website and to keep, and periodically track, information. We may link the information we store in cookies to any personally identifiable information you submit while on the Website. This is for the purpose of creating a personalized experience within the Website, to assist us in understanding our users and subscribers and designing improvements to the website, and for the purpose of collecting usage and performance metrics. Other cookies created by the Website are used to secure your login session and to help ensure the security of your account. These cookies are never shared with third parties.

The Website may from time to time implement other third-party analytics services that also use cookies.  If the use of cookies by any service provider differs materially from the practices already listed, we will revise this document accordingly and notify existing subscribers/users of the change(s).

You may set your preferences through My MedicAlert account.

8. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

Sharing or disclosing information with Responders

If a Subscriber Event occurs, MedicAlert shall share or disclose your Personal Information to Responders that call the MedicAlert Hotline or otherwise connect to a MedicAlert system inquiring about a Subscriber that is experiencing an emergency, medical or personal safety event. Responders are to identify themselves on a call before asking that MedicAlert release any health and medical information.

Responders that connect with MedicAlert may include personnel who act as dispatch for various emergency services or law enforcement agencies at once such as police, including First Nations police, fire, paramedics, etc. Dispatch may inquire about a Subscriber during a Subscriber Event on behalf of any of these emergency services and MedicAlert shall share important information with them, which they, in turn, will disclose to the emergency services. MedicAlert shall only share Personal Information with dispatch in a Subscriber Event and does its best to ensure any third-party Responder who receives information from dispatch acts in accordance with this Privacy Policy.

MedicAlert may also discuss your Subscriber information with the contacts that you have authorized us to do so via your Profile during a Subscriber Event.

MedicAlert may share or disclose your Personal Information for the following purposes:

a) Education and outreach activities, b) Analysis of data and usage trends, c) Accessing your Profile in case of an Subscriber Event, e) Communicating service updates, offers, and promotions, f) Protecting the health and safety of any person, g) Identification purposes as regards to your MedicAlert Identification Product ("ID"), h) Conducting research and analysis for maintaining, protecting, and developing our services, i) Providing and managing your services, responding to your questions, and addressing problems, j) Promoting network integrity and security, quality control, optimizing capacity, and preventing misuse, k) Preventing illegal activities, suspected fraud, and potential threats to our Personal Information database, and l) third-party use cases including, but not limited to, partnership, sponsorship, research, innovation, and community service activities.

9. TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer Personal Information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support our business or administer our services (such as analytics and search engine providers that assist us with Website improvement and optimization). These parties are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, to process the Personal Information with at least the same standards as set out in this Privacy Policy, and to immediately dispose of Personal Information or return it to MedicAlert once its purpose for disclosure is complete. 

10. LIMITING DISCLOSURE

MedicAlert will only share your Personal Information where necessary for fulfilling the purposes outlined within the Privacy Policy. MedicAlert utilizes its best discretion in all cases where the sharing of your Personal Information is necessitated. Often, sharing your Personal Information occurs to enhance the provision of our Services and extend our principal activities, including health and education outreach initiatives.

11. ACCURACY OF DATA

We rely on you to keep your Personal Information up to date, complete and accurate. Please immediately inform MedicAlert if your Personal Information changes or if you become aware of any inaccuracies with the Personal Information you provided to MedicAlert. You must review your Personal Information at least annually to ensure accuracy. You can update your Personal Information through your Subscriber Profile online or by contacting us directly by phone, email, or mail. You are welcome to make changes and request deletions or corrections to your Personal Information at any time.

12. ACCESS TO YOUR PERSONAL INFORMATION

You can request access to your Personal Information at any time, subject to some limited exceptions. You can request access in writing or by calling us with your request. You may also request a list of individuals or entities with whom we have shared or disclosed your Personal Information, if applicable. We will take reasonable steps to authenticate your identity, or the identity of individuals identified on your Subscriber Profile that are authorized to access and change your Personal Information on your behalf. For a copy of your Personal Information please contact us at: infos@medicalert.ca or by letter mail to our office address. Please note that applicable law may allow or require us to refuse to provide you with access to some of or all the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information irreversibly anonymous in accordance with our record retention obligations and practices. . Please note that applicable law may allow or require us to refuse to provide you with access to some of or all the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information irreversibly anonymous in accordance with our record retention obligations and practices.  

12.1. RIGHT TO DATA PORTABILITY   

You can request a copy of your computerized personal information collected directly from you by MedicAlert, subject to limited exceptions. This request must be made to us in writing to infos@medicalert.ca or by letter mail to our office address, along with proof of your identity. Once your identity has been verified, this information will be provided in the form of a structured, commonly used technological format. Please note that applicable law may require that we refuse to provide you with this information. 

13. OUR SECURITY

The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is encrypted for storage.

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

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Your Personal Information will be stored both digitally and, in some instances, in physical copy.

14. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. MedicAlert may de-identify or anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous or de-identified data for any legitimate business purpose without further notice to you or your consent during your Service term.

Once your relationship with MedicAlert expires, is cancelled, or terminated, your MedicAlert profile will either be immediately de-identified or may be maintained for a maximum of 90 days, depending on the circumstances, before your Personal Information is de-identified. After your Personal Information has been de-identified, it will no longer be accessible to Responders in a Subscriber Event. For specific details on expiration, cancellation, and termination, please see our Subscriber Agreement.

MedicAlert may maintain certain Personal Information after expiry, cancellation, or termination for legislative or regulatory purposes, for example, in accordance with Canada’s Anti-Spam Legislation, S.C. 2010, c. 23, Telecommunications Act, S.C. 1993, c. 38, or Limitations Act, 2002, S.O. 2002, c. 24. Further, de-identified Personal Information may be maintained for up to two years for the purpose of scholarly research in line with our charitable objective. 

15. MINORS

Our Products and Services may be used by Minors; however, all Minors are required to have a parent or legal guardian provide MedicAlert with any Personal Information about the Minor. We do not knowingly collect Personal Information from Minors and we will only collect or use Personal Information of a Minor if it is provided to us by, or with the consent of, a parent or legal guardian. If you are a Minor do not use or provide any information on this Website or through any of its features/register on the Website, make any purchases through the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.

When a Minor reaches the age of 17, MedicAlert will notify their parent or guardian that the Minor must take ownership of their account before their 18^th birthday. If, by their 18^th birthday, they have not taken ownership of their account, the capability to update or edit their MedicAlert profile will be locked. The Minor will still have access to MedicAlert services, Responders will still have access to the locked information, and the payment method on file will continue to be charged. MedicAlert cannot collect Personal Information about an individual from their parent or guardian without their consent once they have reached the age of 18. MedicAlert is not liable for any actions or inaction resulting from the locking of a Minor’s profile due to lack of ownership. The Minor must contact us directly and take ownership of their account to restore editing capability. This does not apply for subscribers who are incapacitated in a manner that makes them incapable of taking ownership of their account or providing their informed consent.

16. CHANGES TO THIS PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users' Personal Information or any changes that require subscriber consent, we will notify you by email to the email address specified in your Profile and through a notice on the Website home page.

We include the date the Privacy Policy was last revised 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 our Website and this Privacy Policy to check for any changes.

17. CONTACT US

We strive to be to open and clear about our handling of your Personal Information and data. If there is anything in this Policy you wish to better understand or if you would like to withdraw your consent to an aspect of this Policy, you may forward all comments, questions, concerns, complaints, or other correspondence:

Attn: Subscriber Inquiries
MedicAlert Foundation Canada
Morneau Shepell Centre II
895 Don Mills Road, Suite 405
Toronto, ON M3C 1W3

You may also email or call us. For any customer service inquiries, including unsubscribing from Marketing Messages, please email customerservice@medicalert.ca or call us at 1-800-668-6381.

If you wish to discuss our compliance with this Policy, please contact our Privacy Officer at legal@medicalert.ca.

MedicAlert will work with users to resolve any concerns regarding our Privacy Policy. If we are unable to resolve your concerns, you have the right to complain to the Office of the Privacy Commissioner of Canada or a provincial Information and Privacy Commissioner.