Privacy Policy

 

Introduction

University of Calgary., is the owner of the Sapphire Program (defined below), (hereinafter “Sapphire” or “we” or “our”) and is the owner and administrator of this Privacy Policy.  We recognize that your right to privacy is an important issue. We understand your interest in maintaining and protecting your private information. As a result, we manage your personal information as described in this Privacy Policy.

“You” means a person who completes the registration process to participate in the Program (defined below) on our mobile application (the “App”) or website.

This Privacy Policy provides you with the safeguards for “personal information” as defined and set forth in applicable provincial and federal privacy legislation (“Privacy Laws”).  Nothing in this Privacy Policy will limit Sapphire’s obligations and rights pursuant to such Privacy Laws. Sapphire is also obliged to comply with provincial and federal legislation, including without limitation consumer protection legislation and anti-spam legislation ("Applicable Legislation").

When you participate in our Program (defined below), your privacy is very important to us. This Privacy Policy explains what categories of personal information we collect, the purpose of collection, and how we share it.

What Do we do?

Our program is an integrated set of online tools through an App or website that allow individuals to assess their level of resilience, create an action plan to increase resilience and monitor their progress, increasing their resilience over time. The Sapphire program is dedicated to young woman that participates on Ruby program.

 

What Personal Information Do We Collect?

Personal information is information about an identifiable individual, as defined in applicable Privacy Laws (“Personal Information”). Personal Information that Sapphire may collect from you from time to time includes: your name, email address, your password to register a user account (“User Account”) with us and any Personal Information you choose to submit under your User Account in your online written responses to open-ended questions when using the Program, although most of that content is aggregated and not identifiable. We then assign an anonymous user ID number to your User Account to mask your identity.  Indirectly we may collect responses to security questions for resetting your password from time to time, as well as any customer service preferences. 

If you choose to enable HealthKit, Sapphire's Move feature can track your physical activity and highlight the role of exercise in supporting mental well-being and overall health. The app provides insights to guide and support your fitness journey.

Use of HealthKit is entirely optional, and you may choose whether to enable or disable this functionality within your app settings.

All Personal Information is encrypted during transmission and then aggregated and anonymized.

Please note Personal Information does not include:

Device Information. We collect device-specific information from you in order to provide the Program (such as a user’s hardware model, operating system and web browser versions, unique device identifiers and mobile network information, including phone number). We may associate your device-specific information with your Personal Information on a periodic basis specifically to confirm you as a user and to check the security on your device.

Information from cookies. Like many other websites, the website or App gathers and stores certain information automatically. When you visit the website or App we may send one or more “cookies” to your computer or other device to provide us with information relating to the sources of our site traffic. Cookies are small pieces of information store on your computer’s hard drive. Most browsers automatically accept cookies, but allow you to modify security settings so that you can approve or reject cookies on a case-by-case basis. The App or website requires that cookies be enabled. If you reject cookies, some parts of the Program may not work properly for you.

Log-in and other information. When you access the website or App, or other content served by or on behalf of us on other websites or mobile applications, our servers may automatically record information that your browser sends whenever you visit a website. These server logs typically include your web request, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or user ID to us. During some visits to our website or App we may use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We will also contact you to prompt you to frequently change your password for your User Account. If you delete your User Account your Personal Information is deleted along with it.

Information from other sources. We may receive general information about you from other sources, including anonymous demographic information from third parties. [e.g. Apple iPhone data]

Online Communications. In order to provide you with services or information, you may voluntarily submit Personal Information to us through our website or App for purposes such as conducting business online, asking a question, obtaining information, reviewing or downloading a publication, participating in an event, and participating in contests and surveys. If you are known to Sapphire with a User Account of our online service, we may combine and store Personal Information about your use of our website or App and the online information you have provided with certain other online and offline information we may have collected. All collection, use and disclosure of Personal Information obtained through our website or App shall be subject to this Privacy Policy and Privacy Laws.

Links. Our website or App may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than Sapphire, and Sapphire has no responsibility for such third party websites regarding its privacy policies on its content generally.

 

For What Purpose(s) Do We Collect and Use Your Personal Information?

In general, Sapphire collects, uses and discloses Personal Information in an aggregate (anonymous) format or is otherwise consolidated based on age group(s) (also on an aggregate basis), in order to help us provide our Program to you and build improvements to our website or App. For example, if we learn from the information we collect that certain common events are producing stress in the lives of users, we may use that information to develop skill exercises designed to enable users to respond productively to such events. We may work with Sponsors to tailor and promote Programs and additional relevant services.

Sharing your Personal Information and Using Your Personal Information. We do not use or disclose your Personal Information for purposes other than those for which it was collected, except with the consent of you or as required or permitted by Privacy Laws or other Applicable Legislation.  Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law.

 

Sapphire may collect from and/or disclose your Personal information to:

a) a person who, in the reasonable judgment of Sapphire, is providing or seeking the information as your agent;

b) any of the companies and business entities that form part of Sapphire;

c) an organization or individual retained by Sapphire to perform functions on its behalf, such as contractors, consultants, auditors, software developers (including web-site developers and hosts), data processing, document management and office services;

d) our auditors and professional advisors;

e) another person or corporation as part of conducting business together or pursuant to the sale of all or substantially all of Sapphire’s assets related to one or more specific lines of business, subject to the other person or corporation agreeing to manage Personal Information in accordance with Privacy Laws;

f) another company or person for the development, enhancement, marketing or provision of any of Sapphire’s products or Programs;

g)an agent or third party retained by Sapphire in connection with Sapphire’s administration or the provision of Sapphire 's products or Programs;

h) applicable public authorities where such disclosure is required pursuant to Applicable Laws; and

i)  a public authority or agent of a public authority, if in the reasonable judgment of Sapphire, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of this information.

Except as permitted in this principle, Sapphire does not provide or sell its customer lists to any outside company for use in marketing or solicitation.

 

Your Consent

CONSENT   Please read this entire Privacy Policy carefully and contact us if you have any questions or concerns. BY SUBMITTING PERSONAL INFORMATION TO SAPPHIRE OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT SAPPHIRE AND ITS SERVICE PROVIDERS AND AGENTS MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY TO PERFORM THE PROGRAM AND AS PERMITTED OR REQUIRED BY PRIVACY LAWS.  Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting Sapphire’s Privacy Officer. If you refuse or withdraw your consent, you may not be able to continue in the Program or receive information which may be of value to you.  If you provide us or our service providers and agents with Personal Information of another individual, you must have all necessary authority and/or have obtained all necessary consents from such person for us to collect, use and disclose their Personal Information for the purposes set forth in this Privacy Policy.

 

Consent. Your knowledge and consent are required for the collection, use, or disclosure of Personal Information, except as permitted by Privacy Laws. Pursuant to this Privacy Policy, you acknowledge your consent to Sapphire’s collection, use and disclosure of your Personal Information, or the Personal Information of another individual which you provide to Sapphire, as stated above. Generally, should a different purpose to the collection, use or disclosure of your Personal Information be proposed by Sapphire, Sapphire shall seek your consent at the time it collects the information. However, Sapphire may seek consent to use and disclose Personal Information after it has been collected, but before it is used or disclosed, for a new purpose. You may withdraw consent at any time to some or all of the purposes indicated below, subject to legal or contractual restrictions and reasonable notice.  Please note, however, that in some circumstances, we may not be able to provide you with our Program if you withdraw your consent to our use of your Personal Information.

NOTE: In certain circumstances under Privacy Laws, Personal Information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information.

Sponsors. If you are using the Website or App or the Services as part of a Program, Sapphire may provide or make available the following information, which may include your Personal Information, to your Sponsor: Information, other than user-input free text answers entered as part of the Program, regarding your User Account activity or participation with the Program, which may include log-in times, application progress, your specific Sapphire resilience Skill Scores or other score or personality type information, survey results, or derivative information or analysis. Our automated algorithms may derive insights and recommendations from this information, offering suggestions regarding helpful resources related to the Program.

With respect to Personal Information that we collect from you and share with your Sponsor, as described in this Privacy Policy, your Sponsor is responsible for limiting its use of such information as reasonably necessary in connection with the Program, in each case solely to the extent needed to develop, implement, manage, or improve the Program and in accordance with all applicable notices and consents and this Privacy Policy. Your Sponsor is also responsible for any notification or consent that may be required beyond this Privacy Policy. Your Sponsor is responsible for maintaining reasonable and appropriate confidentiality and security of Personal Information shared with it under the Program. Sponsors are responsible for ensuring that any commercial emails, text messages, or telephone calls to their Program participants comply with applicable law, including any consent requirements. If we are instructed by Sponsors to transmit communications on their behalf, Sponsors remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete. Subject to applicable law, we assume no responsibility for validating that appropriate consent has been obtained or that information contained in communications we send on behalf of Sponsors are accurate and complete. If you have any questions or concerns, we recommend that you contact your Sponsor for more information about how your Personal Information is shared and used in connection with the applicable Program.

Non-personal Information. We may provide Non-Personal Information about our users to strategic partners for research, statistics, marketing or analysis. For example, your information (e.g., scores and personality types) may be aggregated with the information of other user and shared with third parties to enable them to develop products and research. We may also provide Non-Personal Information to third party service providers in relation to the services they provide. We may provide Non-Personal Information to Sponsors in relation to a Program. For example, your information may be aggregated with information of other employees and analyzed to evaluate the effectiveness of the Website or App and the Program, and the results of that analysis may be shared with third party service providers to help Sapphire improve the Website or App and the Program, or with Sponsors to allow them to evaluate the success of the Programs.

 

How Are We Responsible?

Sapphire is responsible for Personal Information under its control and has designated an individual who is accountable for Sapphire’s compliance with the Privacy Laws (“Privacy Officer”). As such:

a)            accountability for Sapphire’s compliance with these privacy principles lies with the Privacy Officer, although other individuals within Sapphire may be responsible for the day-to-day collection and processing of Personal Information.  In addition, other individuals within Sapphire may be delegated to act on behalf of the Privacy Officer;

b)            the identity of the Privacy Officer designated by Sapphire to oversee Sapphire’s compliance with the principles shall be made known upon request; and

c)            Sapphire is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing.  Sapphire shall use contractual or other obligations to provide a comparable level of protection while the information is being processed by a third party.

Limiting Collection. We limit the collection of Personal Information to what is necessary for the purposes identified by Sapphire. Personal Information shall be collected by fair and lawful means and may be collected from other sources who represent that they have the right to disclose the information. In most cases, collection shall be pursuant to appropriate contractual arrangements.

Accuracy.       Sapphire will update your Personal Information as and when you request.  Sapphire will not routinely update Personal Information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other Personal Information changes, please feel free to contact us so that we can update our records. You can access, update or delete your personal data through the functionality of our service. You can choose whether or not to receive promotional communications, but please note that we may still contact you with important information about your account.

Protecting your Personal Information. Your Personal Information will be protected and certified by security safeguards appropriate to the sensitivity of the information. This is to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. The methods of protection include:

a)            organizational measures, such as security clearances and limiting access on a “need-to-know” basis;

b)            technological measures, such as the use of passwords, firewalls and encryption;

c)            physical measures, such as locked filing cabinets and restricted access to offices;

Notwithstanding our commitment to take reasonable and appropriate measures to protect your Personal Information, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart or hack our security systems. As a result, we cannot ensure or warrant the security and privacy of any information you transmit to us, and you do so at your own risk. We will notify you, via email, posting or other commercially reasonable method, of any loss of data or breach of our security measures that has resulted in the loss or unauthorized access, disclosure, use or acquisition of your Personal Information (including hard copy records) or otherwise presents a potential threat to such information, as required by law.

Please remember that you also play a valuable part in data security. You should never share your password with anyone. If you feel your password has been compromised, you should change it immediately. After you have finished using the website or App, you should log out of your User Account and exit your browser so that no unauthorized persons can use the website or App under your name or User Account .

 

Openness.     Included in this Privacy Policy is:

(a)          the name or title, and the address, of the Privacy Officer to whom complaints or inquiries can be forwarded;

(b)          the means of gaining access to your Personal Information held by Sapphire;

(c)           a description of the type of your Personal Information held by Sapphire, including a general account of its use;

(d)          what Personal Information is made available to affiliated companies.

Individual Access. Upon your request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your Personal Information and shall be given access to that information. You can access and update your User Account information by accessing “My Profile” in the website or App. Personal Information entered actively by a user during the use of the Service, such as answers to assessment questions, tool entries, etc., is not deleted or modified and may remain on servers for as long as needed to provide you the Website or App’s products and services and the Program or as otherwise permitted by law. However, should you wish to have your Personal Information deleted please contact info@Sapphire.com to request us to do so.

Promptly after receiving your request, all Personal Information stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable. Sponsors are responsible for any requests made to them by Program participants regarding access to and rectification of participants’ respective Personal Information that is transferred to us.

NOTE: In certain situations, under Privacy Laws, Sapphire may not be able to provide access to all of your Personal Information it holds. The reasons for denying access will be provided to you. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-users or litigation privilege.

 

What If I Have Concerns About Sapphire’s Compliance?

You may wish to address a concern regarding Sapphire’s compliance with the above principles to Sapphire’s Privacy Officer. Sapphire shall investigate all complaints. If a complaint is found to be justified, Sapphire shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and practices.

 

Changes to the Privacy Policy

Sapphire reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post the revised Privacy Policy on our website or App. We will provide to you such revised Privacy Policy upon request to the Privacy Officer.  However, Sapphire will obtain the necessary consents required under applicable Privacy Laws if it seeks to collect, use or disclose an individual’s Personal Information for purposes other than those to which your consent has previously been obtained unless otherwise required or permitted by Privacy Laws.

If changes are significant, we will, in our sole discretion, post a more prominent notice on the homepage of our Website or App or notify you by email at the address we have on file for your User ID. You agree that your continued access or use our Program after posting of the changes to the Privacy Policy or your receipt of notice of a change to the Privacy Policy will constitute your affirmative acceptance of any such change and your agreement to such updated terms.

 

How Do I Obtain Further Information?

Sapphire has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws. For information on Sapphire’s privacy practices, please contact our Privacy Officer at help@sapphire-app.ca.