Privacy Policy

PRIVACY AND COOKIES  POLICY

Updated: November 12, 2020

Introduction

NURSING THE FUTURE (“We” / “we” / “our” / “us”) respect your privacy and are committed to protecting your personal data. This Privacy and Cookies Policy will inform you as to how we look after your personal data when you visit our Site: https://nursingthefuture.ca/ (the “Site”) (regardless of where you visit it from) and will tell you about your privacy rights and how the law protects you. Capitalized terms used below but not defined in this policy have the meaning set forth in the Website Terms of Use.

1. IMPORTANT INFORMATION AND WHO WE ARE
   • Purpose Of This Privacy And Cookies Policy

This Privacy and Cookies Policy aims to give you information on how we collect and processes your personal data through your use of the Site.

This Privacy and Cookies Policy (together with the Website Terms of Use) sets out the basis on which any personal data we collect from you when you interact with us or that is provided by you through your use of our Site or our Chat, will be processed by us.  

The Site is not intended for children or under age individuals (as they are defined in the laws of applicable jurisdictions) and we do not knowingly collect data relating to children. By accepting this Privacy and Cookies Policy you acknowledge that you are of the age of majority in your domicile jurisdiction.

It is important that you read this Privacy and Cookies Policy together with any other privacy and cookies policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

• Our data privacy officer

We have appointed a data privacy officer who is responsible for overseeing questions in relation to this Privacy and Cookies Policy. If you have any questions about this Privacy and Cookies Policy, including any requests to exerciseYour Legal Rights, please contact the data privacy officer by email at privacy@nursinghtefuture.ca.

• Third-party Links

The Site may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Sites and we are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy and cookies policies of every site you visit.

2. THE DATA WE COLLECT ABOUT YOU
   • The Types of Information We Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data is collected only from Subscribers and includes first name, last name, username or similar identifier, title, and company details, occupation, level of education.
• Contact Data is collected only from Subscribers and includes email address.
• Technical Data includes internet protocol (IP) address, your login data (in case of Subscribers), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site.
• Usage Data includes information about how you use our Site, features and services.
• Marketing and Communications Data is collected only from Subscribers and includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not and cannot not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookies Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

• If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms and conditions of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to Subscriber only content).

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • (i) apply for our services;
  • (ii) subscribe to our services or emails;
  • (iii) request marketing emails to be sent to you; or
  • (iv) give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies notice below for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • (i) Technical Data from analytics providers, advertising networks, search information providers, including Google Analytics, LinkedIn, Facebook, Slack and other social networks.
  • (ii) Contact from providers of technical, payment and delivery services.
  • (iii) Identity and Contact Data from publicly available sources.

4. HOW WE USE YOUR PERSONAL DATA
   • Circumstances under which we will use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you, or provide you with service or information.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

• Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

• Marketing and Opting out

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Additionally, you can review and revise your marketing and communication preferences by contacting us at newgraduates@nursingthefuture.ca or following the opt-out links on any marketing message sent to you.  

• Third-party marketing and Opting out

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a browsing the Site or other transactions.

• Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact privacy@nursinghtefuture.ca.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties and for the purposes set out below:

• Internal Third Parties, means other organizations that provide us with IT system administration services, or other technical services required for the Site for the purpose of provision and receipt of such services.
• External Third Parties, which include (a) service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, but also when providing you with marketing communications, analytics and search engine providers that assist us in the improvement and optimisation of the Site; (b) professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services for the purpose of provision and receipt of such services; (c) government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include requirement to share your location information).
• Third parties to whom we may choose to sell, transfer or merge parts of our business, organization or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our organization, then the new owners may use your personal data in the same way as set out in this Privacy and Cookies Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our Subscribers (including Contact, Identity) for six years after they cease being Subscribers.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data, including your Aggregated Data, (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. COOKIES NOTICE

Since our Site uses cookies and/or other further identifiers (such as pixel or tag) for several purposes, this Privacy and Cookies Policy sets out what cookies are and how they are used on the Site.

Certain cookies and identifiers are conveyed and controlled by us directly. We collect and process your personal data by means of these cookies and identifiers. To the contrary, other cookies and identifiers are conveyed and controlled by third parties, over which we have no control. We hereby invite you to read such cookies policies of the third parties carefully.

• What cookies are and what they are for

The cookies are small text files that Sites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same Sites at the following visit of the same by the same user (the so called proprium first party cookies). During the surfing of a Site, a user may receive on its terminal also cookies of other Sites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited Site, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a Site other than the one that is currently visited.

The cookies may have a duration limited to a single session of navigation on the browser (called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorised and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).

The cookies are used for several purposes. Certain cookies are necessary in order to allow you to surf the Site and benefit of its functionalities (the so called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the Site and how the Site is used (called monitoring cookies or analytics). To the end, other cookies are used in order to track your Subscribers account and allow you to view advertisements that may be of interest to you (called profiling cookies).

• Our use of cookies

You can find more information about the individual cookies we use on the Site and the purposes for which we use them in the table below:

• How to manage the cookies and oppose to their use

You can manage, disable and remove the cookies. To do so, please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies.

Please be careful in making your choice. By blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Site, you may no longer able to surf the Site or to benefit, in whole or in part, from its functionalities. Furthermore, removing the technical cookies could remove the preferences set up by using the Site.

In order to disable the third parties cookies or identifiers, please see the privacy policies of those third parties.

9. YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your personal data. In particular, you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling lawful grounds to process your personal data which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish your personal data's accuracy.
• Where our use of your personal data is unlawful but you do not want us to erase it.
• Where you need us to hold your personal data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your personal data but we need to verify whether we have overriding lawful grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of Your Legal Rights, please contact our data privacy officer at privacy@nursingthefuture.ca.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to the Privacy and Cookies Policy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We keep our Privacy and Cookies Policy under regular review.