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VSP® Canada Vision Care Insurance

Privacy Policy: Members


VSP Canada Vision Care Insurance ("VSP") is committed to the security and protection of your personal information. This Privacy Policy sets out how VSP collects, uses and discloses personal information relating to you. If you have any questions or concerns relating to the policy or to the manner in which VSP collects, uses or discloses personal information, please contact VSP’s Privacy Officer using the contact information below.

Overview

The practices described in this Privacy Policy apply to VSP's services available to members for the administration of your vision insurance benefits. By accepting this Privacy Policy and the VSP Canada Vision Care Insurance Terms of Service ("Terms of Service") when registering on the Site, you expressly consent to our collection, use and disclosure of information collected on the Site in accordance with this Privacy Policy.

The secure collection, use and disclosure of Personal Information is fundamental to our business operations and we comply with all applicable privacy laws including, but not limited to, Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and all applicable provincial laws concerning the collection, use and disclosure of personal information including personal health information.

1. Scope of the Privacy Policy

This Privacy Policy governs VSP's collection, use and disclosure of personal information (including any personal health information) ("Personal Information") relating to you.

2. Personal Health We Collect

Our primary purpose in collecting Personal Information about you is to process your member benefits, communicate with you as part of our services and to facilitate transactions (such as submission and processing of claims, identity verification and verification of your member eligibility). We may also use Personal Information to help us to design and provide services and features that most likely meet your needs, and to customize our services to make your experience easier and more efficient. We only collect Personal Information about you from providers that is necessary to achieve these purposes.

We use data collection devices such as "cookies" on certain pages of our web site https://vsp-canada.ca ("Site") to help analyze our Web page flow, measure promotional effectiveness, and customize features. "Cookies" are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a cookie. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. All cookies that we use are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site and you may be required to re-enter your password more frequently during a session.

You can set your Internet browser or operating system settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, to omit images (which will disable pixel tags) or adjust your tracking preferences. Please consult the "tools" or "help" tab on your browser for more information on how to change cookie and other tracking preferences and options.

If you send us personal correspondence, such as e-mails or letters, this information will be retained in a file that is specific to you. We keep this information in order to ensure we properly track and maintain a record of our communications with you.

3. Use of Personal Information

We use Personal Information about you to facilitate the services you request. We may also use Personal Information in the file we maintain about you, and other information we obtain from your current and past activities on the Site to:

  • administer and manage our operations (including our claims processing procedures for you and the management and administration of product orders) and enforce our Terms of Service;
  • respond to your requests for information and other inquiries relating to our products and services
  • deliver information to you such as administrative notices, and communications relevant to your use of the Site
  • resolve disputes and troubleshoot problems;
  • inform you of updates,
  • detect and protect us against error, fraud, and other criminal activity and to enforce or protect our rights;
  • improve our Site content and product offerings including, but not limited to, conducting surveys concerning our services, service delivery and product expansion,
  • customize the Site's content, layout and services;
  • investigate breaches, or potential breaches, of applicable laws;
  • comply with legal and regulatory requirements;
  • in connection with a commercial transaction including a transaction involving the sale or transfer of our business; and
  • as otherwise required or permitted by law.

Parts of the Site require a User ID or password that you would have created. If you have forgotten your User ID or password, we may also use your Personal Information to recover them online. To confirm your identity before providing either of these items, we match the information you provide against previously collected information.

Personal Information may be provided to VSP's parent or affiliate companies and/or to companies, including companies that are outside of Canada (including in the United States or other countries), retained by VSP for processing or storage of such information. Recipients of Personal Information will be instructed not to use or disclose Personal Information other than for the purposes allowed by this Privacy Policy or applicable law. As described below, in "Security and Transfer of Personal Information", records containing Personal Information may be sent out of province or out of Canada for any of the purposes described in this Privacy Policy. VSP ensures, by a written contract or other confirmation, that any such recipients/providers of processing services agree to protect that Personal Information and not to use or disclose that information in any way which is not authorized as provided in this Privacy Policy or the terms of VSP's privacy policies as amended from time to time.

We will treat all Personal Information that we obtain from you (either directly from you, your employer or from a medical provider) as confidential. Only our employees or agents who are engaged in the processing of claims or the other uses of Personal Information set out above shall have access to Personal Information. We will take all reasonable steps to prevent disclosure of Personal Information except in accordance with applicable law.

4. Disclosure of Personal Information

We do not disclose, sell or rent any Personal Information to third parties for their marketing purposes without explicit consent. However, the following describes some of the ways that Personal Information may be disclosed in the normal scope of providing our services.

VSP cooperates with law enforcement inquiries, as well as other third parties, to enforce laws and help protect you and the VSP community. At times we may be required by law or legal process to disclose Personal Information about you to competent legal bodies. We may also disclose Personal Information to a person to whom the information must be communicated by reason of the urgency of a situation that threatens the life, health or safety of the person concerned.

Due to the existing regulatory and technological environment, we cannot guarantee that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example, we may be required to disclose Personal Information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse Personal Information about your patients, you or your practice that they collect from the Site. Therefore, although we use industry standard practices to protect privacy and take the security measures necessary to ensure the protection of the Personal Information collected, used, communicated, kept or destroyed and that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored, we cannot guarantee that Personal Information or private communications will always remain private or secure.

5. Control of Your Password

You are required to log onto the Site with a User ID and password. Do not use your name, the name of a close relative or any significant dates, commonly used words or readily accessible information about you when choosing a password. We recommend that you use a combination of letters and numbers and change your password regularly.

You are responsible for all actions taken with your User ID and password and for creating a strong and secure password. Do not disclose your User ID or password to any third parties. If you choose to share your User ID and password or your Personal Information with third parties, you are responsible for all actions taken with your account and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password.

6. Changing Personal Information

Personal Information that we collect, use or disclose shall be as accurate, complete, and up-to-date as is necessary for the purposes for which that information was collected. We will update Personal Information only as and when necessary to fulfill the identified purposes or upon notification from the individual or your employer. You must promptly contact your employer to update Personal Information if it changes or is inaccurate.

7. Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of Personal Information we collect from you. To the extent that you disclose information to other parties, whether they are external providers on the Site or other sites accessed via VSP, different rules or policies apply to their use or disclosure of the information you disclose to them. VSP does not control the privacy policies or practices of third parties, you are, therefore, responsible for understanding the privacy policies and practices of these third parties. VSP is not responsible for the privacy policies or practices of these Web sites. We encourage you to ask questions and to ensure the secure treatment of any personal information that you may share on such Sites before you disclose any Personal Information on any other web sites or to others.

8. Security and Transfer of Personal Information

Our Site also has a provider portal. Only authorized VSP Preferred Providers and their authorized staff, may register to access the "Providers" portal on the Site. All such users must have a User ID and password issued by the Provider Services Department.

Records containing Personal Information may be sent out of province or out of Canada and may be stored on VSP's servers located in the United States. Other provinces or countries may not have privacy laws that provide the same protections as the laws applicable in this province. However, VSP will respect the terms of applicable privacy law and this Privacy Policy in all provinces and countries to the extent permitted under applicable law. Personal Information processed, stored or transferred outside of Canada may be available to the foreign government of the country in which the information or the entity controlling it is situated under a lawful order made in that country and used for purposes other than those described in this Privacy Policy.

VSP uses procedural and technical safeguards to protect Personal Information against loss or theft as well as unauthorized access and disclosure to protect its privacy, including encryption, "firewalls", and Secure Socket Layer security. However, the Internet is not a fully secure medium where privacy and confidentiality can be guaranteed. Similarly, the complete security and confidentiality of transmissions to and from the Site over the Internet cannot be guaranteed. Similarly, your confidential use of the Site cannot be guaranteed and you acknowledge that your use of this Site, including information you transmit to or receive from the Site, may be subject to disclosure to, access or manipulation by third parties. VSP and its affiliates shall not be liable for any damage that your or any other person may suffer in connection with any such breach of privacy, confidentiality or security.

We will destroy all Personal Information when it is no longer needed, subject to applicable laws, including applicable privacy laws and time limits prescribed by law or by a retention schedule.

Should VSP learn of, or discover, any disclosure, use or access of Personal Information contrary to this Privacy Policy, we will take all reasonable steps, in accordance with applicable privacy laws, to investigate, mitigate or address such disclosure immediately and on an ongoing basis, as required. VSP will also report any such unauthorized access, use or disclosure to you as applicable.

9. Notice

We may amend this Privacy Policy at any time by posting the amended terms on the Site. If any material changes are made to this Privacy Policy, we will notify you by posting an announcement on our Site. By using the Site after such amendment, you agree to the terms of any amendments to the Privacy Policy.

10. Access

You will have access to your Personal Information that we hold, upon written request presented to our Privacy Officer in accordance with applicable privacy laws. If we cannot give you access to your Personal Information that you requested, you will be notified in writing, given reasons and informed of the recourses available. You will also be able to challenge both the accuracy of your Personal Information and our compliance with the above principles. The procedures will be accessible through our Privacy Officer at the address and number below.

By using the Site and the services provided herein, you are deemed to have accepted this Privacy Policy and that you agree that we may collect, use and disclose Personal Information about your patients, you and your practice or business for these purposes. This consent will be valid as long as you are a VSP member. If you do not agree to this Privacy Policy, please do not continue to review or access this Site.

11. Contact Information

Web: https://vsp-canada.ca/contactUs
Mail: VSP Vision Canada Privacy Officer
c/o VSP Vision Care
3333 Quality Dr, Rancho Cordova, CA 95670, United States
Phone: 1.800.852.7600 ext 4111

Our Privacy Officer is accountable for our compliance with all applicable federal and provincial privacy laws and this policy.

Dated: July, 2014

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