1) Overview This Privacy Policy explains how your Personal Information (defined below) will be collected, used and disclosed by ClaimSecure Inc. (“ClaimSecure”) and other Program Partners (defined below) when you access and use the tools and related features of the “Upgrade to a Better You” employee wellness initiative (the “Program”) made available to you by Air Canada (the “Sponsor”).
Please read this Privacy Statement carefully, and be aware that by accessing and using the website or services of either ClaimSecure or any Program Partner for purposes of the Program, you confirm and agree that you have read this Privacy Statement, and the privacy policies/statements of any Program Partner(s) whose tools you access and use, and that you accept and consent to the privacy practices described herein.
This Privacy Policy does not apply to the activities of ClaimSecure with respect to the administration of the Air Canada employee health benefit plan(s) (the “Employee Benefit Plans”), including i) health benefit claims and any related payments, ii) adjudication of health benefit claims, or iii) eligibility determination and maintenance of Employee Benefit Plan-related Personal Information. However, as set out in this Privacy Policy, ClaimSecure may use Personal Information obtained or derived from administering the Employee Benefit Plans for purposes of administering the Program. ClaimSecure will not use Personal Information obtained or derived from administering the Program for purposes of administering the Employee Benefit Plans.
For information on ClaimSecure’s privacy policies and practices as they relate to the Employee Benefit Plans, please consult the ClaimSecure Privacy Policy on ClaimSecure’s eProfile page which is accessible through the AC Aeronet.
For the purposes of this Privacy Policy, a person who accesses, uses, or otherwise participates in the program is referred to as a “Member”.
2) Personal Information Personal Information (“Personal Information”) is information about an identifiable individual. It includes information such as an individual’s full name, address, telephone number, date of birth, e-mail address, and any other information that identifies who you are or would allow someone to contact you. Personal Information also includes personal health information, which is any Personal Information relating to a person’s physical or mental health, including their health history.
3) Program Partners The Sponsor and/or ClaimSecure have contracted with a number of parties to supply services to the Program or to Members. In this Privacy Statement, a “Program Partner” means any party, including ClaimSecure, who is selected by ClaimSecure or the Sponsor to provide services (such as health risk assessment services, financial services, or other services) in connection with the Program.
By participating in the Program, you agree that you understand and accept the following:
(a) ClaimSecure will handle all Personal Information which it receives from you or from any other source (for example, other Program Partners) in accordance with this Privacy Policy.
(b) Your access to the tool or tools provided by ClaimSecure or another Program Partner may be facilitated by a sign-on mechanism managed by ClaimSecure. During this sign-on process, ClaimSecure will transfer or disclose your unique ClaimSecure user ID and certain Personal Information about you to that Program Partner to confirm your eligibility to use that Program Partner’s tools, and to improve your user experience.
(c) Each Program Partner may pass Personal Information to ClaimSecure and (at the request and direction of the Sponsor or ClaimSecure, or as otherwise provided for in the Program), to other Program Partners or other Sponsor vendors for the purposes of (i) confirming your Program participation and otherwise assisting them in providing their services to you, (ii) processing any applicable incentives you may earn for Program participation, (iii) customizing services and features of the wellness tools provided by ClaimSecure and the Program Partners or those Sponsor vendors to be most useful for you, and (iv) Program data compilation and storage, evaluation and reporting. No Program Partner will transfer or disclose your Personal Information to anyone else under any other circumstances, without your specific acknowledgement and agreement.
(d) Using the Program, the ClaimSecure website, or any of the tools provided by any of the Program Partners is voluntary. None of the health scores or recommendations provided to you by any of them is intended as medical advice or to replace guidance from your personal healthcare provider. Please consult your healthcare provider if you have any questions or concerns regarding any of the information within this website, or any of the tools provided by any of the Program Partners.
(e) Each Program Partner will collect, use, transfer, disclose and retain any Personal Information which it receives from you or from any other source in accordance with this Privacy Policy and that Program Partner’s Privacy Policy/Statement. The Program Partners are:
i. InfoTech Inc. (“InfoTech”), whose “Wellness Checkpoint” comprehensive health questionnaire tool is available to you as part of the Program. The Wellness Checkpoint tool is hosted in Winnipeg, Canada and subject to strict privacy legislation. InfoTech's Terms and Conditions and Privacy Policy can be accessed at:
ii. The Achievers’ Employee Recognition and Rewards program provides companies with a robust foundation for their employee engagement initiatives that enables both social and rewards-based recognition. Achievers’ Privacy Policy can be accessed at:
4) Collection and Retention of Personal Information For purposes of the Program, Personal Information relating to a Member may be supplied to ClaimSecure by the Sponsor, the Member or by another Program Partner.
For the purposes of administering the Program, ClaimSecure will only collect and use the Personal Information that is required to enable us to complete the services that we have been contracted to provide. ClaimSecure will not collect Personal Information from any sources other than those listed herein. If additional Personal Information is required by ClaimSecure from any source not set out herein, ClaimSecure shall not request such information without notifying the Member.
We will do our best to base our decisions on accurate and up to date Personal Information. However, we rely on the Sponsor, the Member and other parties including other Program Partners to disclose all material Personal Information to us, and to inform us of any changes thereto. We assume that any Personal Information provided to us by any such sources is complete and accurate.
ClaimSecure will only retain Program-related Personal Information for as long as it is needed for the identified purposes related to the Program, or as required by law.
5) Use of Personal Information For the purposes of administering the Program:
(a) ClaimSecure will only use the Personal Information that is required to enable us to complete the services that we have been contracted to provide; and
(b) ClaimSecure may access or use Personal Information that it has obtained or derived from the administration of the Employee Benefit Plans.
ClaimSecure will not use any Personal Information that it obtains or derives from administering the Program for purposes of administering the Employee Benefit Plans.
For purposes of administering the Program, and for statistical and analytical purposes, ClaimSecure may combine, compare, or otherwise utilize any Personal Information and other information in its possession.
6) Disclosure of Personal Information Some or all of the Personal Information in ClaimSecure’s possession, including Personal Information that is derived or compiled by ClaimSecure may be accessible by or provided to:
(a) the Member;
(b) Program Partners or other Sponsor Vendors for the purposes of (i) confirming a Member’s Program participation and otherwise assisting them in providing their services to Members, (ii) administering and processing any applicable incentives the Member may earn under the terms of the Program, (iii) customization and administration of the services and features of the Program products and services provided by those Program Partners or Sponsor vendors to be most useful to the Member, and (iv) overall Program data evaluation and reporting;
(c) Other parties as required by statutory authority and legal process.
ClaimSecure will not disclose Personal Information to any other party without the prior consent of the Member.
7) Disclosure of Information to Sponsor ClaimSecure will not grant access to, or provide the Sponsor with, any of the Personal Information it collects, derives or compiles for the purposes of the Program.
Any information provided by ClaimSecure to the Sponsor, or to which the Sponsor will be granted access will be aggregate and/or anonymized information only, and will not directly or indirectly reasonably enable the identification of any individual Member or specific group of Members by the Sponsor. The aggregate and/or anonymized information that may be provided to the Sponsor may include, and may be utilized by the Sponsor to assess: (i) overall participation rates for the Program; (ii) the total number or amount of incentives credited to Members under the terms of the Program; (iii) underlying overall Member healthcare and wellness trends or issues; iv) customizing or enhancing the services and features of the Program, or creating and administering other programs or initiatives to address these and other issues; and (v) overall administration of Wellness Checkpoint and the Program, including data evaluation and reporting.
8) Member Access to Personal Information, Correction of Personal Information, and Termination of Participation in the Program Upon request, ClaimSecure shall make available to the Member the Personal Information maintained in its files relative to that Member, subject to any applicable legal or ethical prohibition or privilege.
A Member may correct Personal Information that the Member previously entered into Wellness Checkpoint by accessing the Wellness Checkpoint application directly. A Member may request that other Personal Information be corrected or amended by contacting the Sponsor, or the relevant Program Partner directly.
A Member may elect to terminate his/her participation in the Program by contacting the Sponsor. It should be noted however that if a member elects to terminate his/her participation in the Program, some or all of the Personal Information in the possession of the Sponsor, ClaimSecure, and other Program Partners may be retained and utilized by the Sponsor, ClaimSecure and the other Program Partner(s) for statutory purposes, as well as for ensuring the ongoing administration and integrity of the Program and any related programs.
9) Consent to the Terms of this Privacy Policy If you do not agree with any terms of this Privacy Policy/Statement or a Program Partner’s Privacy Policy/Statement, please do not use the Program.
If you do not understand the nature, purpose and consequences of the collection, use, retention, and disclosure of Personal Information by ClaimSecure or another Program Partner, please contact ClaimSecure or the other Program Partner directly using the contact coordinates in their respective Privacy Statements to address your questions and concerns.
10) Communication with ClaimSecure A Program- related privacy-related inquiry relating to ClaimSecure may be made by contacting ClaimSecure’s Privacy Officer. The Privacy Officer will investigate all inquiries and complaints. If a complaint is justified, we will take appropriate steps to correct the situation, including changing our policies and procedures if necessary.
For more information, please contact ClaimSecure’s Privacy Officer and reference “Air Canada- Upgrade to a Better You” by email at privacy@ClaimSecure.com or by mail at:
ClaimSecure Inc. Privacy Officer 1 City Centre Drive, Suite 620 Mississauga, Ontario L5B 1M2