PRACERA Privacy Policy

This Privacy Policy applies to personal information handled through PRACERA's website, accounts, profiles, marketplace, opportunity listings, applications, messaging, subscription and billing functionality, communications and related services.

This Privacy Policy does not govern the independent privacy practices of clinics, practitioners or third-party websites and services that PRACERA does not control.

PRACERA is responsible for personal information under its control.

PRACERA will designate an individual responsible for privacy compliance and for responding to privacy inquiries, access requests and correction requests.

Privacy inquiries may be submitted using the contact information at the end of this Policy.

The information collected depends on how an individual uses PRACERA.

Account Information

PRACERA may collect:

• name;
• email address;
• telephone number;
• account type;
• login and authentication information;
• account status;
• communication preferences;
• acceptance of Terms and Privacy Policy versions; and
• other information necessary to administer an account.

Practitioner Professional Information

PRACERA may collect:

• professional name;
• profile photograph;
• profession or discipline;
• city;
• province or territory;
• professional registration information;
• registration and good-standing attestation;
• years of experience;
• areas of focus;
• professional biography;
• availability;
• preferred opportunity type or work arrangement;
• relocation preferences;
• résumé;
• cover letter;
• application responses; and
• other professional information voluntarily supplied.

Clinic Information

PRACERA may collect:

• clinic name;
• clinic logo;
• clinic photographs;
• clinic location;
• website;
• clinic description;
• services;
• clinic contact information;
• opportunity postings;
• recruitment requirements; and
• information supplied by Clinic Owners.

Some clinic information may constitute business information rather than personal information. This Privacy Policy applies where the information qualifies as personal information under applicable law.

Application Information

When a practitioner applies to an opportunity, PRACERA may collect:

• applicant name;
• profession;
• experience;
• résumé;
• optional cover letter;
• message to the clinic;
• professional registration and good-standing attestation;
• opportunity applied to;
• application date;
• application status; and
• communications and activity relating to the application.

Communications

When users communicate through PRACERA, we may process:

• message content;
• sender and recipient information;
• timestamps;
• conversation history;
• message status; and
• information necessary to provide and secure communication functionality.

Subscription and Billing Information

For Clinic Owner subscriptions, PRACERA may collect or process:

• selected plan;
• subscription status;
• subscription start date;
• renewal date;
• cancellation status;
• billing period;
• transaction information;
• billing name and address;
• applicable business information;
• receipts;
• invoices;
• applicable tax information;
• limited payment-method information supplied by a payment processor; and
• payment status.

Complete payment-card details may be submitted directly to PRACERA's payment processor rather than stored by PRACERA.

Technical and Usage Information

PRACERA or its service providers may collect:

• IP address;
• device type;
• browser type;
• operating system;
• login activity;
• pages or features accessed;
• timestamps;
• security logs;
• diagnostic information;
• error information; and
• cookie or similar technology information.

PRACERA may collect personal information:

• directly from you;
• when you register;
• when you update your account;
• when you create or modify a profile;
• when you publish an opportunity;
• when you apply to an opportunity;
• when you upload a document;
• when you communicate through PRACERA;
• when you purchase or manage a subscription;
• when you contact PRACERA;
• automatically through your use of the Platform;
• from service providers acting on PRACERA's behalf; and
• where otherwise permitted or required by law.

PRACERA may collect and use personal information to:

• create and administer accounts;
• authenticate users;
• provide the marketplace;
• display professional or clinic profiles according to applicable visibility settings;
• enable opportunity discovery;
• enable practitioner discovery;
• process applications;
• associate applications with the correct clinic and opportunity;
• enable communication between users;
• operate Find Practitioners;
• maintain saved opportunities;
• maintain application history;
• administer subscriptions;
• process payments;
• calculate applicable charges and taxes;
• generate receipts and invoices;
• send service and account notifications;
• respond to support requests;
• prevent fraud;
• prevent misuse;
• enforce duplicate-posting and anti-flooding rules;
• enforce PRACERA's Terms;
• secure the Platform;
• diagnose technical problems;
• maintain records;
• improve functionality;
• understand Platform performance;
• comply with applicable legal requirements; and
• protect PRACERA, its users and others.

PRACERA will not use personal information for an unrelated new purpose unless that use is permitted by law or appropriate consent is obtained.

Where consent is required, PRACERA seeks meaningful consent appropriate to the circumstances.

The form of consent may depend on the nature and sensitivity of the information and the reasonable expectations of the individual.

Users may withdraw consent to certain uses or disclosures, subject to legal or contractual restrictions and reasonable notice.

Withdrawal of consent may affect PRACERA's ability to provide functionality that requires the information.

PRACERA may require users to acknowledge or agree to applicable legal policies when creating an account.

PRACERA may maintain records showing:

• the user who accepted;
• the date and time of acceptance;
• the version of the Terms accepted;
• the version of the Privacy Policy acknowledged; and
• other information reasonably necessary to document consent or agreement.

Where material changes require renewed acknowledgement or consent, PRACERA may request that users review and accept an updated version.

Practitioners may be able to choose whether their professional profile is discoverable by eligible Clinic Owner accounts.

When a practitioner enables profile visibility, professional information intended for the profile may be displayed to eligible clinics through PRACERA.

A practitioner profile configured for clinic-only discovery is not intended to become a publicly searchable internet profile.

Turning profile visibility off does not necessarily delete:

• the practitioner's account;
• previous applications;
• information previously supplied to a clinic;
• previous messages;
• saved opportunities;
• application history;
• security records; or
• information PRACERA reasonably or legally needs to retain.

When a practitioner submits an application, PRACERA makes the applicable application information available to the clinic receiving that application.

This may include:

• name;
• profession;
• experience;
• résumé;
• cover letter, if supplied;
• application message;
• professional registration/good-standing attestation; and
• related application information.

Submitting an application therefore directs PRACERA to provide the relevant application information to the clinic to which the practitioner has chosen to apply.

Clinics receiving personal information through PRACERA are responsible for handling that information appropriately and lawfully.

Depending on subscription level, account eligibility and practitioner privacy settings, Clinic Owners may be able to access professional practitioner information through PRACERA.

PRACERA may limit or anonymize information for certain subscription levels.

Private account information is not automatically included merely because a Clinic Owner can view a professional profile.

A user's private account email address or telephone number is not intended to be automatically displayed to other marketplace users.

PRACERA may use private contact information to:

• administer an account;
• authenticate a user;
• provide security communications;
• send necessary service notifications;
• notify users of relevant PRACERA activity;
• provide billing communications where applicable; and
• respond to support inquiries.

Where PRACERA provides internal messaging, clinics and practitioners may communicate without PRACERA automatically disclosing their private account email addresses.

PRACERA may record a practitioner's confirmation that the practitioner is currently registered and in good standing with the applicable regulatory college or professional body in the province or territory where the practitioner practises.

This is a practitioner-provided attestation.

PRACERA may display to an eligible clinic that the practitioner or applicant has made this confirmation.

The attestation is not independent verification by PRACERA.

PRACERA may use third-party service providers to operate and support the Platform.

These providers may include providers of:

• cloud hosting;
• databases;
• authentication;
• cybersecurity;
• file storage;
• payment processing;
• email delivery;
• analytics;
• error monitoring;
• infrastructure; and
• other technical services.

Service providers may process information as reasonably necessary to perform services for PRACERA and in accordance with applicable contractual and legal requirements.

PRACERA may use a third-party payment processor for Clinic Owner subscriptions and other authorized payments.

Payment-card information may be submitted directly to the payment processor.

PRACERA may receive limited payment information such as:

• payment status;
• card brand;
• partial card identifier;
• transaction identifier;
• subscription status;
• billing information; and
• payment or refund information.

PRACERA does not intend to store complete payment-card numbers where payment processing is handled by an external payment processor.

Some service providers used by PRACERA may process or store information outside British Columbia or outside Canada.

When information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies or governmental authorities where permitted by applicable law.

PRACERA will take reasonable steps appropriate to the circumstances when selecting and using service providers that process personal information.

PRACERA and its service providers may use cookies or similar technologies for purposes including:

• authentication;
• maintaining account sessions;
• security;
• remembering preferences;
• Platform functionality;
• analytics;
• performance; and
• diagnostics.

Where legally required, PRACERA will provide appropriate choices or consent mechanisms for non-essential technologies.

PRACERA may use aggregated, statistical or appropriately de-identified information to:

• understand Platform use;
• improve features;
• identify technical problems;
• assess marketplace performance;
• improve security; and
• make business decisions.

Where information has been effectively de-identified so that it is no longer personal information under applicable law, it may be handled as non-personal information.

PRACERA may send service communications relating to:

• account activity;
• security;
• applications;
• PRACERA messages;
• clinic messages;
• opportunity activity;
• subscription and billing matters for Clinic Owners;
• renewals;
• receipts;
• policy changes; and
• other Platform activity.

Users may be able to control certain notification preferences.

Essential account, security, transactional or legally required communications may continue while necessary even where optional notifications are disabled.

If PRACERA sends commercial electronic messages, those communications will be handled in accordance with applicable Canadian requirements.

PRACERA may disclose personal information:

• at the user's direction;
• to a clinic when a practitioner submits an application;
• to eligible clinics when a practitioner has enabled appropriate profile visibility;
• to service providers supporting PRACERA;
• to payment processors;
• where required by applicable law;
• in response to lawful legal process;
• where permitted by privacy legislation;
• where reasonably necessary to investigate fraud, security incidents or unlawful activity;
• to protect PRACERA's legal rights;
• in connection with a legitimate business transaction where permitted by law; or
• with consent.

PRACERA does not operate as a data broker selling private practitioner or Clinic Owner account information.

PRACERA uses reasonable administrative, technical and organizational safeguards appropriate to the nature of the personal information under its control.

Safeguards may include:

• authentication;
• access controls;
• account permissions;
• service-provider controls;
• technical security measures;
• monitoring;
• backups where appropriate; and
• internal procedures.

No internet-based system can guarantee absolute security.

Users are responsible for protecting their passwords and account credentials.

PRACERA will investigate suspected privacy or security incidents involving personal information under its control.

PRACERA will take reasonable steps appropriate to the circumstances.

Where notification, reporting or another response is legally required, PRACERA will take the action required by applicable law.

PRACERA will take reasonable steps appropriate to the circumstances to ensure personal information used to make a decision directly affecting an individual is sufficiently accurate and complete.

Users are responsible for keeping their account, clinic and professional information current.

Subject to applicable law, individuals may request access to personal information about themselves under PRACERA's control.

PRACERA may require reasonable information to verify identity before responding.

Certain information may be withheld where permitted or required by law.

Individuals may request correction of personal information they believe is inaccurate or incomplete.

Where appropriate and required by applicable law, PRACERA will correct the information or otherwise address the request in accordance with applicable privacy requirements.

PRACERA retains personal information only for as long as reasonably necessary for identified purposes or legitimate legal, security and business requirements.

Different categories of information may have different retention periods.

Information may be retained where reasonably necessary for:

• account administration;
• application history;
• transaction and tax records;
• security;
• fraud prevention;
• dispute resolution;
• enforcement of agreements;
• legal claims;
• records of consent or policy acceptance;
• regulatory requirements; and
• other legitimate recordkeeping purposes.

Where personal information has been used to make a decision directly affecting an individual, PRACERA will retain the information for any minimum period required by applicable law.

When information is no longer reasonably required, PRACERA will take reasonable steps to delete, destroy or appropriately de-identify it, subject to legal and technical requirements.

Users may request account closure using available Account functionality or by contacting PRACERA.

Closing an account does not necessarily result in immediate deletion of every record associated with that account.

PRACERA may retain information where reasonably necessary or legally required for:

• transaction and tax records;
• fraud prevention;
• security;
• dispute resolution;
• legal claims;
• enforcement;
• application history;
• consent records; and
• compliance obligations.

Information previously shared with another user may remain in that user's legitimate records.

PRACERA is a professional careers marketplace and is not intended for children.

Individuals who are not legally eligible to create an account must not register for PRACERA.

PRACERA does not knowingly design the Platform for collection of children's personal information.

If PRACERA is involved in a financing, reorganization, merger, acquisition, sale, transfer or similar business transaction, information may be disclosed or transferred where permitted by applicable law and subject to appropriate safeguards.

PRACERA may preserve, use or disclose information where reasonably necessary and permitted or required to:

• comply with applicable law;
• respond to lawful legal process;
• protect legal rights;
• investigate fraud;
• enforce agreements;
• protect users;
• protect Platform security; or
• respond to circumstances where disclosure is otherwise lawfully permitted.

PRACERA may update this Privacy Policy as the Platform, business, technology, service providers or legal requirements evolve.

The Last Updated date will identify the latest revision.

Where a change materially affects how personal information is handled, PRACERA will provide additional notice or obtain additional consent where required.

Questions, concerns, access requests or correction requests relating to PRACERA's handling of personal information may be directed to:

Privacy Officer – PRACERA British Columbia, Canada Email: contact@pracera.ca

Individuals may also have the right to raise a concern with the applicable privacy regulator.