The Sandbox Privacy Policy

This privacy policy applies to the users of Alberta School Employee Benefit Plan’s (ASEBP) Health and Wellness Portal (the “Site”). This privacy policy is intended to inform you about the information that is collected from you when you visit the Site; how this information may be used and disclosed; how you can control the use and disclosure of your information and how your information is protected. ASEBP’s privacy provisions are based on the ten privacy principles set out in the CSA International Model Code for the Protection of Personal Information which addresses the ways in which organizations collect, use and disclose personal information.

Scope
This privacy policy applies only to the Site. It does not apply to information collected through any other ASEBP website or to the information handling practice of ASEBP outside of the Site. Please note that the Site may contain links to other websites. If you click on a link to another website, this privacy policy will not apply to that website. ASEBP is not responsible for the privacy practices of other websites and we recommend that you read the privacy policies of each website you visit.
This privacy policy does not apply to business contact information including an individual’s name, position name or title, business telephone number, business address, business e-mail address, business fax number and other similar business information.

What Information the Site Collects
ASEBP limits collection of personal information only to what is necessary for the purposes identified. Types of information collected includes:

Information you provide directly to us:
You are not required to provide information directly to us in order to view the Site; however, when you use certain functions, such as when you register for certain services or directly contact the Site, we may ask you to provide information including:
    •    First and last name
    •    School jurisdiction/place of employment
    •    Work email address
    •    Facial photograph (for authorized bloggers only)
Although the Site is publicly available, it is intended for wellness champions participating in the Alberta K-12 education sector, including partners and other stakeholders and other individuals as approved by ASEBP.

Information automatically collected when you visit and interact with the Site:
The Site employs Google Analytics to collect information such as page views, sessions, location, mobile usage, etc. For more information on what is collected through Google Analytics, please visit the Google Analytics privacy policy.  

How We Use Information That We Collect
We collect information for one or more of the following purposes:

Verify Your Eligibility to Register:
We may use the information that we collect to verify that you are an eligible registrant. Registration is required to contribute to the Site’s online community.

Email Communications:
We may use the information that we collect to send you email communication, such as editorial updates, information about your account or changes to the Site. If you signed up for an email newsletter, we will also send you the newsletter that you requested.

User Accounts:
To provide you with an open, but also civil, discussion forum, we track user involvement in our community discussions.

Request Fulfillment:
We may use the information that we collect to fulfill your request for services and information. For example, we may use your contact information to respond to your customer service requests or to enable you to participate in features on the Site such as surveys, polls and message boards.

Statistical Analysis:
In order to learn more about how our Site is used, we aggregate and analyze the data we collect. We may use this information, for example, to monitor and analyze use of the Site, to increase the Site’s functionality and to better tailor the content and design to suit our visitors’ needs.

Enforcement:
We may use the information collected to meet legal and regulatory requirements, to prevent illegal activities, to enforce the Site’s Terms and Conditions and to otherwise protect our rights and the rights of our users.

Information Sharing
ASEBP values your privacy and only shares information about our users under certain circumstances. We will make information about you available to other companies, applications or people in the circumstances listed below:

  • If you are a registered user, your first name, the first letter of your last name and your workplace will appear on all content that you post on the Site.
  • If you choose to engage in public activities on the Site, such as posting comments on community message boards, any information you submit can be read, collected, or used by others. Please exercise caution when deciding to disclose any personal information in public activities or submissions.
  • We may share aggregated information or information that does not directly identify you with third parties to help us develop content and services that we hope you will find of interest.
  • We may employ third parties to perform Site-related services, including database management, maintenance services, analytics and data processing. These third parties have access to your information only to perform these tasks on our behalf.
  • We may share information about you to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of the Site’s Terms and Conditions, or as otherwise required by law.
  • We may share information about you to respond to court orders, search warrants, judicial proceedings, subpoenas, legal processes or other law enforcement measures or to establish or exercise our legal rights or to defend against legal claims.
  • In addition to the scenarios above, we may share information about you for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Your Choices
We are committed to offering you meaningful privacy choices regarding the collection, use and disclosure of your personal information. This includes the opportunity to:

Deactivate your account
You can deactivate your account at any time by visiting the edit profile option. When you deactivate your account, your user profile will be disabled, but your public comments will remain on the Site. ASEBP has no responsibility to take down, remove or edit any of your public activities or submissions that are a result of your public activities. For more information, please review our Terms and Conditions for this Site.

Cookies
“Cookies” are small text files that identify an individual computer’s browser entering a web site and allow the site to track that browser’s movements through the site over several sessions. Through cookies, a web site can recognize repeat users, facilitate the user’s access to and use of the site and allow a site to track usage behavior that will allow content improvements. ASEBP uses cookies only for these purposes and will not use them to identify users or track usage not related to this Site.

If you do not want a cookie placed on your computer by ASEBP, you may disable cookies by modifying the preferences section of your internet browser. Note that it is possible that some aspects of the Site may be unavailable to you if you disable cookies.

Access
Upon written request, we will make available to you any of your personal information that we have collected, used or disclosed. Please contact us. ASEBP may refuse access to personal information as provided by privacy legislation.

Accuracy
We ensure that your personal information is accurate, complete and up-to-date. You can challenge the accuracy of the information and request amendments as appropriating by contacting us.

Confidentiality and Security
We have privacy and security practices in place to safeguard your personal information. We retain personal information only as long as necessary for business purposes or as required by law. We also limit access to your personal information to employees or service providers who reasonably need your information in order to provide the Site’s services or in order to do their jobs. We have adopted reasonable technical, physical and administrative safeguards to help protect your personal information. All sensitive information, such as passwords, is encrypted.
Please note that no data transmission can be guaranteed to be 100 percent secure. We want you to feel confident using the Site, but we cannot ensure or warrant the security of any information you transmit to us.

Collection, Transfer and Storage of Information
ASEBP servers and the server of the webhost used by ASEBP to provide this Site are located within Canada. Information may be transferred to a third party to perform Site related services on our behalf. If information is transferred to a third party, appropriate contracts/arrangements will be in place to ensure confidentiality and security of personal information.

Changes to the Privacy Policy
We reserve the right to update this privacy policy at any time to reflect changes in our practices, services provided and changes in privacy legislation or best practices within Canada. If we modify this privacy policy, we will update the “Effective Date.” We will also notify you of any substantive changes in the way we handle your information by placing a prominent notice on the Site or sending a notice to the email address specified in your account. Your continued use of the Site following notice of a change means that you agree to and accept the new terms of the privacy policy. If you do not agree with any changes made, you must immediately stop using the account and deactivate it.

Addressing Your Concerns
We have implemented policies and practices to give effect to this policy, including training and communicating with our employees on the importance of privacy. We regularly monitor our procedures and security measures to ensure they remain effective. If you have any questions please contact our Privacy Officer as follows:

By Email
In Writing:
                 Attention: Privacy Officer
                 ASEBP
                 700, 5555 Calgary Trail
                 Edmonton  AB  T6H 5P9


Effective Date: September 17, 2015