WAYLAND IS PROTECTING CLIENT PRIVACY
Wayland supports industry and government initiatives to protect consumer privacy such as:
- the federal Personal Information Protection and Electronic Documents Act
- model code for the Protection of Personal Information with the Canadian Standards Association
WHAT IS PERSONAL INFORMATION?
Personal information means any information about an identifiable individual. This includes information such as a Client’s name, address, telephone number, birth date, purchase information, email address and patient information. Wayland Clients provide Wayland with personal information in a variety of ways, such as applying for a Wayland user account/registration, applying to become a registered client of Wayland, viewing and using Wayland content and services, entering on-line contests, signing up for various Wayland programs or services, visiting or using the Wayland website at waylandgroup.com, or using any of Wayland’s mobile device applications. In every case, Wayland adheres to strict guidelines when dealing with personal information.
COLLECTING PERSONAL INFORMATION
Wayland obtains Client consent for the collection of personal information. In some instances, where the purpose for collection is obvious, Client consent is implied.
Wayland may ask for Client permission to collect additional information that may be useful in serving the Client in the future.
For the purpose of maintaining quality service, telephone calls to Wayland’s user or customer service lines may be recorded. If a Client call is subject to a quality assurance program, the Client will be so advised prior to speaking with a representative.
USING AND DISCLOSING PERSONAL INFORMATION
Wayland may use Client personal information in order to process a Client’s application/registration, profile or to fulfill requests for content, products or services, or to tailor content, products or services or for advertising or marketing purposes. Wayland may also use Client information to better understand the Client’s information, product and service needs and to offer relevant information, products, services, marketing and advertising to meet those needs. A Client’s viewing times, patterns, purchases and other transactions, shopping patterns, account activity and payment history are tracked and analyzed for marketing purposes and for making promotional offers to Clients.
Wayland may receive information about a Client’s location. For example, a Client may choose to publish the Client’s location in the Client’s application, registration or profile. Wayland may also determine a Client’s location by using other data from a Client’s device, such as precise location information from GPS, information about wireless networks or cell towers near a Client’s mobile device, or a Client’s IP address. Wayland may use and store information about a Client’s location to provide features of the Wayland website or content or services provided thereat or in association with the website or mobile device applications, and to improve and customize website pages, mobile device applications, content, services and marketing materials to make them more relevant for a Client.
Wayland may keep track of how Clients interact with Wayland and with links across Wayland’s website and mobile device applications, and their content and services, including Wayland email and text notifications, third-party services, and Client applications, by redirecting clicks or through other means. Wayland does this to help improve its website and mobile device applications and its content, services and marketing, to provide more relevant advertising and information, and to be able to share aggregate statistics such as how many times a particular link was clicked on.
When a Client logs into the Client’s Wayland account with a browser or mobile device, Wayland will associate that browser or mobile device with the Client’s account for purposes such as authentication and personalization. Depending on the Client’s settings, Wayland may also personalize the Client’s experience on, and based on information from, other browsers or mobile devices besides the ones the Client uses to log into Wayland. For example, if a Client visits other websites with certain content, Wayland may show the Client related ads on or via the Wayland website or mobile device applications, or pushed to the Client on the Client’s browser or mobile device.
Wayland may share or disclose Client information at the Client’s direction, such as when a Client authorizes a third-party web client or application to access the Client’s Wayland account or any portion of it, or when the Client directs Wayland to share the Client’s feedback with a business. If the Client shares information using social media features of the Wayland website or any mobile device application or any content or services, with another user or person who can access the Wayland website or a mobile device application or such content or services, Clients must keep in mind that the information may be shared with the third-party.
Wayland may share or disclose a Client’s public information, such as a Client’s public user profile information and a Client’s public social media communications and interactions.
Wayland may share or disclose non-personal, aggregated, or device-level information. This information does not include a Client’s name, email address, phone number or personal patient information. Wayland may, however, share non-personal, depersonalized, aggregated, or device-level information through partnerships and associations with entities that may use data in their possession (including data a Client may have given them) to link a Client’s name, email address, or other personal information to the information that Wayland provides to them.
Wayland may share information about Clients as permitted or required by law, for example with credit bureaus, regulators and law enforcement agencies.
MAINTAINING AND SAFEGUARDING PERSONAL INFORMATION
Wayland strives to ensure that its security measures protect against loss, theft and unauthorized access, disclosure, use or modification of personal information.
Wayland limits access to personal information to those Wayland associates who may need it for use in accordance with Wayland’s established privacy principles.
Wayland associates sign an acknowledgement and undertaking which requires them to keep personal information confidential and comply with Wayland’s security standards.
Wayland keeps Client information for as long as necessary and in order to service Clients better.
Clients can withdraw consent to the use of personal information at any time, subject to legal restrictions and upon reasonable notice to Wayland. Wayland will let Clients know of the implications of withdrawing consent. Regardless, information may be retained by Wayland for audit or archival purposes.
ENTITLEMENT TO ACCESS PERSONAL INFORMATION
If requested by a Client, access will be given to that Client’s personal information, Wayland targets a response time of not more than 30 days to requests for Client access to the Client’s personal information.
There is no cost for reasonable requests, unless a Client requires copies of records. Wayland advises Clients of the cost, if any, prior to copying those records.
Wayland may not be able to provide a Client with access to the Client’s personal information where the information cannot be separated from the records of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege.
A Client may access that Client’s personal information that Wayland has on record to ensure it is accurate, by submitting a written request to Wayland.