HAT Privacy Policy
Effective Date: July 24, 2024
University Health Network (“UHN”, “us”, “we”, “our”) is committed to the confidentially and security of the personal information we hold. Personal information is about an identifiable individual, either alone or when combined with other information.
UHN developed and operates the Hypermobility Assessment Tool (HAT) application to provide our service (the “Service”, or “Services”) to users of HAT (“you” or “your”). The services provided via HAT are as follows: The system will provide you with the ability to complete joint hypermobility assessments through its phone and web application. The HAT application and software are together referred to as the “Platform”. All written materials displayed or made available through our Platform such as videos, audio clips, assessments are referred to as “Content” or “Contents”.
As part of our ongoing commitment to protect your personal information, this privacy policy informs you of our privacy practices to be transparent and clear about how your personal information is managed by UHN.
Please read this policy carefully as it describes how we collect, use, disclose and safeguard your personal information. This privacy policy should be read with our Terms of Use [https://www.edsgoodhope.ca/hat-terms]. By using our Service, including providing your personal information, you understand and agree to the collection, use and disclosure of your personal information by us, in the manner described in this policy. Unless otherwise defined in this policy, the terms used in this policy have the same meaning as in our Terms of Use.
Collection of Personal Information
Throughout your interactions with our Services, we collect the following types of personal information. The table below describes the category of personal information collected, the specific types of personal information collected, and the source of collection.
Use of Personal Information
UHN uses the personal information collected in the table above for the following purposes:
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For research purposes
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To screen you for the presence of generalized joint hypermobility using the Beighton score
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Maintaining our Platform
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Informing you about changes or updates to the Platform
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Providing customer service and/or technical support, upon your request
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Gathering analysis and information about how you use the Platform so we can improve the Platform
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De-identifying your information
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Monitoring the usage of our Platform, including to detect, prevent and address technical and security issues
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Contacting you about future research opportunities (if you consent to such use)
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Enforcing our obligations under the Terms of Use
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Complying with legal or regulatory requirements or other lawful purposes under applicable laws e.g. Personal Information Protection and Electronic Documents Act (PIPEDA) and Personal Health Information Protection Act (PHIPA)
De-identified or Aggregated Data
UHN will de-identify and aggregate data generated from the Platform for research, analytical purposes, and to improve user experience on the Platform. De-identified data is data that has had the direct identifiers removed making it difficult to link individuals to their data. Aggregated data is data that has been grouped or summarized in a way that prevents identification of individual records.
Disclosure of Personal Information
We will never sell your personal information and we do not disclose your personal information to any third parties, for any purpose, unless required by law.
Required by Law
UHN may be required by law to disclose your personal information:
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to prevent, investigate, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of UHN, our users, or others;
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when we determine, at our sole discretion, that the disclosure of such information is necessary to enforce our rights against you or in connection with a breach by you of this policy or the Terms of Use;
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under a regulation, subpoena, or other legal process.
Third-Party Sites:
The Platform contains links to external websites. UHN is not responsible for the privacy practices or the content of any third-party website
Not for Clinical Care
Your information will not be collected or used for the purpose of sharing with your doctors. As per the Terms of Use, [https://www.edsgoodhope.ca/hat-terms] your care providers will never see the information collected on the Platform, unless you choose to share it with them. You will be able to see the results of your joint hypermobility assessment through the HAT phone application and will receive a copy of your results through email.
Security Safeguards
We take privacy very seriously. We apply technical, physical and administrative safeguards to protect your personal information against the rick of unauthorized access, collection, use, or disclosure. For example, your information will be stored by UHN, in encrypted database, with robust access controls, according to UHN security standards.
It is your responsibility to help keep your personal information secure by safeguarding your password, in accordance with the Terms of Use [https://www.edsgoodhope.ca/hat-terms]
We will never send messages to you that request confidential information such as passwords, credit card numbers, or social insurance numbers. Do not act on any such emails as you may compromise your personal information by replying or by following fraudulent links.
As with any electronic communication, using platforms such as HAT to transmit information over the internet carries some risk and is never guaranteed to be 100% secure. Exchanging personal information over the internet is done at your own risk.
Use of Artificial Intelligence
The Platform uses artificial intelligence (AI) to automatically process your data. We use publicly distributed and custom human pose-estimation models when analyzing your videos. The models we use extract the locations of key body parts (such as the shoulders, elbows, wrist, hips, knees, ankles, as well as various points on hand and forearm) from the videos you upload. These models are hosted on the HAT Platform and do not share any data with any external party. We further process the joint locations output by the AI models to estimate the likelihood of joint hypermobility.
Cookies and Related Technologies
A cookie is a small text file that our Platform may place on your device as a tool to remember your preferences and display more relevant information next time you visit.
Retaining Personal Information
We will retain your personal information as required by applicable laws and regulations for the full length of time required under those laws and regulations. We may retain de-identified information for as long as we deem necessary and in accordance with the terms of this policy.
Correcting or Accessing Your Personal Information
We rely on you to ensure that the personal information you enter in the Service is as accurate, complete and up-to-date. If you identify personal information within the Platform that contains errors and needs to be corrected, please inform us of the necessary changes at EDSPROGRAM@uhn.ca.
You have a right to request access your personal information held by UHN within the Platform. You also have a right to know if your personal information has been shared with third parties. To make an access request, please contact us at EDSPROGRAM@uhn.ca.
Removing Consent
You can withdraw your consent for UHN to use your information held within the Platform at any time through the app or by contacting us directly at EDSPROGRAM@uhn.ca. You may also request that your information and account be deleted from the Platform but please note, UHN cannot delete information that has been previously shared with third parties.
You may discontinue using the Platform at any time by uninstalling the application from your device.
Children’s Data
We do not knowingly collect children’s data. Our services are intended for persons 18 years of age and older and are not directed towards or meant to be used by children. If you think a child may have created an account with us without your consent, you may request the deletion of any information provided to and retained by us by writing to us at EDSPROGRAM@uhn.ca.
Changes to Our Privacy Policy
We may be updated from time to time for any reason. Updated versions of the privacy policy will be posted on the HAT website. It is your responsibility to review any updates. Your continued use of the Platform, represents your continued consent for UHN to collect and use your personal information, for the purposes set out in the current privacy policy.
Concerns About Our Privacy Practices
If you have any questions or complaints regarding this privacy policy, please contact the UHN Privacy Office:
Telephone: 416-340-4800 ext. 6937
Email: privacy@uhn.ca
If the UHN representative is unable to resolve the concern, or is there is a further complaint, you have the option to contact the Privacy Commissioner of Ontario at Suite 1400, 2 Bloor Street East, Toronto, ON, M4W 1A8, Telephone: 416 326-3333, 1-800-387-0073 (within Ontario).