PRIVACY POLICY

LAST UPDATE OF THIS PRIVACY POLICY – September 21, 2021

BEFORE USING OUR SITES, PLEASE READ THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy is applicable to Xpan Interactive Ltd. (“Company”) and sets out our policy on the gathering and use of information on this site and our other sites (collectively “Sites”). Xpan Interactive Ltd. is committed to providing safe web sites for visitors of all ages and has implemented this Privacy Policy to demonstrate our firm commitment to your privacy. Xpan Interactive Ltd. complies with Canadian Federal and Provincial privacy laws and regulations including the Personal Information and Electronic Documents Act.

There may be links from our Sites to other web sites; note that this Privacy Policy applies only to our Sites and not to web sites of other companies or organizations to which our Sites may be linked. You must check on any linked sites for the privacy policy that applies to that site and/or make any necessary inquiries in respect of that privacy policy with the operator of the linked site. These links to third party websites are provided as a convenience and are for informational purposes only. The Company does not endorse and is not responsible for, these linked websites.

Although you are not required to register to access our Sites, you may be asked to provide us with personal information when you visit certain sections of our Sites. Your use of our Sites signifies your acknowledgment and consent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not continue to use our Sites. Your continued use of the Sites signifies your acceptance of these terms and any changes in effect at the time of use.

 

COLLECTION OF PERSONAL INFORMATION

Personal Information is information about you that identifies you as an individual, for example, your name, address, email address, or telephone number.

We collect information that you voluntarily provide to us through responses to surveys, search functions, questionnaires, feedback, Tell Your Story forms and the like. On some of our Sites, we may offer health assessment tools that ask you to provide self-assessment information. We may also ask you to provide additional information such as your email address if you want to obtain additional services, information, participate in a contest or to resolve complaints or concerns.

 

MANAGEMENT OF PERSONAL INFORMATION

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.

Your Choices:
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. Where the Services are administered for you by an administrator, you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact menu to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Access and update your information: In certain applications, the My Profile menu gives you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

Deactivate your account: If you no longer wish to use our Services, you or your administrator may be able to deactivate your account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact us through support@xpan.ca. Please be aware that deactivating your account does not delete your information; your information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.

Delete your information: Some optional information can be deleted from your account by you or an administrator. Some information is required to maintain your account. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

 

HOW DOES COMPANY USE INFORMATION GATHERED ABOUT ONLINE VISITORS?

Before forwarding us any personal information, please be advised that any information gathered on our Sites may be used in the aggregate for research and development relating to our Sites and/or for future site development and, if you ask us to, to send you promotional materials. In particular, we may use information gathered about you for the following purposes: to monitor interest in our range of products and to assist us to tailor the content of our Sites to your needs by: i) collecting information about your preferences through tracking of patterns page views on our Sites, ii) to create a profile relating to you in order to show you the content that might be of interest to you and to display the content according to your preferences, and, iii) in circumstances where you have indicated that you wish to receive additional information, to send you information about us and promotional material about our products together with details of any offers we may have available from time to time.

 

PROMOTIONAL AND INFORMATIONAL OFFERS

With the permission of an online visitor, information submitted at the time of registration or submission may be used for marketing and promotional purposes by Xpan Interactive Ltd. provided notice of this fact is made available online. If a visitor objects to such use for any reason, he/she may prevent that use, either by email request or by modifying the registration information provided. Xpan Interactive Ltd. uses reasonable efforts to maintain visitors’ information in a secure environment. If you have submitted personal information and want to change it or opt-out, please contact us as described below.

 

DISCLOSURE OF INFORMATION

Xpan Interactive Ltd. will not disclose personal information that you provide on its Sites to any third parties other than to a Company agent except: i) in accordance with the terms of this Privacy Policy, or ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order, and/or iii) if you are reporting an adverse event/side effect, in which case Xpan Interactive Ltd. may be required to disclose such information to bodies such as, but not limited to, Canadian and/or international regulatory authorities. Please note that any of these disclosures may involve the storage or processing of personal information outside of Canada and may therefore be subject to different privacy laws than those applicable in Canada, including laws that require the disclosure of personal information to governmental authorities under circumstances that are different than those that apply in Canada.

 

COOKIES

Xpan Interactive Ltd. in common with many web site operators, may use standard technology called “cookies” on its Sites. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. You can disable cookies by turning them off in your browser; however, some areas of the Sites may not function properly if you do so.

 

PROTECTION OF CHILDREN ONLINE

Xpan Interactive Ltd. considers the protection of children’s privacy, especially online, to be of the utmost importance. We do not knowingly collect or solicit personal information from children nor do we allow them to become registered users of, or to request information through, our Sites or help-seeking information lines.

 

ADDITIONAL TERMS FOR CERTAIN WEBSITES

The following additional information applies to our Sites that require registration. Generally, you are not required to provide personal information as a condition of using our Sites, except as may be necessary to provide you with a product or service that you have requested. However, some of our Sites are restricted to certain individuals such as healthcare professionals or our prescription drug patients and we may require these individuals to register upon entry by providing us with certain information.

 

PROTECTION OF INFORMATION:

Our Commitment to Security

We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. Xpan Interactive Ltd. applies security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.

Storage of Information:

Personal information you share with us is stored on our database servers at Xpan Interactive Ltd. data centres (in whatever country they may be located), or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy.

 

POLICY CHANGE

If we alter our Privacy Policy, any changes will be posted on this page of our Site so that you are always informed of the information we collect about you, how we use it and the circumstances under which we may disclose it.

 

ACCEPTANCE OF OUR PRIVACY POLICY

By using this Site or any other Xpan Interactive Ltd. Site or interactive banner ads, you signify your acceptance of our Privacy Policy, and you adhere to the terms and conditions posted on the Site. By submitting your information, you agree that it will be governed by our Privacy Policy.