ClinicalHub - Privacy Policy

Privacy Policy – ClinicalHub Medical Services Inc.

Last updated: July 15, 2019. The terminology used in this Privacy Policy has the same meaning as in our Terms of Use.

1. General

This Privacy Policy (the “Policy”) governs how we collect, use, retain, disclose, manage and protect your personal information and personal health information (collectively referred to together in this Policy as “Information”). All employees, Healthcare Professionals, On-Site Physicians, and contractors working for ClinicalHub are required to adhere to the protections described in this Policy.

For the purposes of this Policy, personal information (“Personal Information”) means information about an identifiable individual. Personal health information, (“Personal Health Information”) means information about an identifiable individual that relates to the individual’s physical or mental health, including but not limited to, the name of patient, date of birth, medical history, past medical treatments, symptoms, diagnostic images, medical test results, medication lists, and health number. Personal Health Information may be found in medical records, treatment and examination notes and communications between patients and their Healthcare Professionals.

ClinicalHub will collect Information from you when you access and use our App, Platform, Website, or our other software products.

By accessing or using the Healthcare Services you are agreeing to the terms of the Policy. The Policy should be read in conjunction with the Terms of Use. You should not use the Healthcare Services unless you fully understand and agree to the Terms of Use and the Policy

If you have any questions about the Policy or our privacy practices, please contact info@clinicalhub.com.

Collection and Disclosure of Your Information

We will not give, sell, rent, loan, or exchange your Information to any third party unless legally required to do so. We may share non-personal, summary, or aggregate user data, with all personal identifying information removed, with partners and other third parties.

We may use non-personal information created by us from your Information in order to better understand and improve the Platform and our services. This process of data collection is done in the aggregate and allows ClinicalHub to improve its user experience services.

2. Account Information

When you register for an Account, in order to identify you properly and contact you when needed, we will collect identification and contact information, such as your name, date of birth, gender, email address, phone number, mailing address and a government issued photo identification card.

When you use the Platform, we will collect and store Personal Health Information, such as symptoms, medical history, clinician observations, appointment history, diagnosis, investigation results and treatment information.

We may use your Personal Information in order to verify your Account in the context of providing you with customer service support or to answer any inquiries that you may have regarding your Account.

3. Payment Information

When you make or receive a payment through our Services, we will collect and use your credit card or banking information or other financial data in order to process the payment. If you purchase a yearly subscription Healthcare Service this information may be used to renew your subscription.

4. Consultations and Healthcare Services

We will use the Information that we collect from you to schedule and administer your Consultations, update your patient record and to provide you with Healthcare Services. If you receive Healthcare Services through the Platform, we may disclose Information to and among Healthcare Professionals, On-Site Physicians, and ClinicalHub employees for the purpose of providing or assisting in the provision of Healthcare Services to you. We may disclose your Information to third parties such as other health professionals, specialists, physiotherapists, nutritionists, pharmacists, or pharmacies and laboratories for the purpose of providing or assisting in the provision of Healthcare Services to you. Healthcare Professionals and On-Site Physicians use Information to provide you with Healthcare Services and must comply with the privacy legislation and medical record- keeping obligations to which they are subject.

Only Healthcare Professionals, On-Site Physicians, and ClinicalHub employees involved in providing you with Healthcare Services can access your Information. Information concerning the diagnosis or treatment of you may be printed or transcribed in full and made part of your medical record. We will not forward electronic communications regarding your Personal Health Information to third parties without your prior written consent, except as authorized or required by law.

We may share with selected third-parties demographic and contact information about you (including but not limited to name, date of birth and any email addresses or phone numbers) by email, SMS text message, instant messaging or any other means necessary, for reasons including but not limited to: verifying your identity, medical follow-up, scheduling appointments, confirming appointments, customer support and technical support.

5. Third-Party Service Providers

Processing and Storage:

We may transfer your Information to a third-party service provider for processing and storage. Whenever we use a third-party service provider, we ensure that the Information is properly protected at all times.

Service Provider Arrangements:

In connection with the Website, Platform, and/or Healthcare Services, your Information may transit through third parties who provide services on our behalf such as a payment processer or website server host. Our service providers are given as much information as required to perform their designated duties.

6. Information on the Platform

As you use the Platform, certain Personal Information may be passively collected by cookies (as defined below), navigational data, and third-party tracking services. The following is the information we may collect

Access Device and Browser Information:

When you access the App from a computer or other device, we may collect information from that device, such as your Internet protocol address (“IP address”), browser type, connection speed and access times (collectively, “Usage Information”). We use Usage Information in order to improve our products and services and to protect your data from unauthorized access. We may keep track your actions while using the Website or App in order to improve your experience using the Platform as well as our products and services.

Cookies:

The Platform uses “cookies”. A cookie is a small packet of data sent by an internet server to an internet browser, which is returned by the internet browser each time it accesses the same server, which is used to identify the user or track their access to the server and is stored on the user’s computer. Cookies are used by ClinicalHub to remember your preferences and to authenticate you. You can refuse cookies by turning them off in your internet browser. If you decide to turn off cookies the Platform may not function as intended. We may use third parties or web analytical services to facilitate and engage users in advertisements. These companies may also use cookies and other technologies to report certain information about your visits to the Platform in order to measure the effectiveness of our marketing strategies and to deliver customized advertisements to you. The third-party partner or web analytical service partner may be able to collect data about visitors to the Website and other sites because of these cookies, may compose reports regarding the Website’s activity for us and may provide further services which are related to the use of the Website and the internet. By using the Platform and not turning off or blocking cookies, you are consenting to their use for the purposes described in this Policy.

Location Services:

The App may request your permission to use GPS technology to collect real-time information about the location of your device. Location services information may be used to ensure that a Healthcare Professional or On-Site Physician is available in your local region. Location services information may also be used in a research capacity to customize and improve your experience while using the Platform.

Device and Usage Information:

We may also collect device-related information from your mobile device or computer. This information is used to help us authenticate you, deliver content appropriate for your device’s capabilities, and to deliver notifications about activity on your account, such as messages from our Healthcare Professionals or On-Site Physicians. Examples of information that may be collected and used include your device’s unique identifier, manufacturer, model, and operating system version. This information may be used to improve the performance of the App, Website, or Platform and/or fix bugs contained therein.

Real-Time Video and Audio Consultations:

During a Consultation, you may be required to connect with your designated Healthcare Professional through a real-time video and audio call to receive the Healthcare Services and to verify your identity. All video and audio calls conducted through our Platform are end-to-end encrypted and shall remain confidential, only accessible to you and the Healthcare Professionals or On-Site Physicians responsible for your care. These video and audio calls are not recorded or stored by ClinicalHub and cannot be accessed at a later date for any reason.

Third Party Links:

The Website may contain links to other websites or platforms that ClinicalHub does not own or operate. Links to our Website or Platform may be featured on third party websites or platforms on which we advertise. Except as provided in this Policy, we will not provide Information to these third parties without your consent. We provide links to third party websites or platforms as a convenience to our users. You should carefully review the privacy policies and practices of other websites or platforms, as we cannot control or be responsible for their privacy practices.

7. Communication

ClinicalHub reserves the right to contact you at any time using any of the contact information you have provided. We may send you service announcements, including but not limited to, updates regarding our Terms of Use, Privacy Policy, or Platform in an effort to keep you wholly informed.

8. Legal Issues

We may use your Personal Information to detect, investigate, address and prevent fraudulent or illegal activities. We reserve the right to disclose your Personal Informationas required by law, when we believe that disclosure is necessary to comply with a judicial proceeding, court order, governmental request, subpoena, or legal process served on us and to defend against legal claims.

Sale of Business:

If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Platform to a third-party purchaser, such as by merger, acquisition, insolvency or bankruptcy proceeding or otherwise, we may transfer or sell your Information to the purchaser or new owner. In such a case, unless permitted otherwise by applicable law, your Information would remain subject to the promises made in the applicable Policy unless you have agreed differently.

We may store your Information on webservers located in Canada. By using and accessing our Platform, you agree that your Information can be stored and processed in Canada.

9. Accessing the Personal Health Information held by ClinicalHub

You have the right to access your patient record. If you request a copy of your patient record, it will be provided to you, subject to a reasonable fee. You can request access to your patient record by contacting us at info@clinicalhub.com.

At any time, you can view your information by logging into your Account.

10.Changes to Information

We use reasonable means to ensure that Information in your patient record is accurate. If you identify any inaccuracies, you can request that a note be made on the file indicating the inaccurate Information and we will undertake to correct it.

For your protection, we may need to verify your identity before fulfilling your request to access, correct, amend, remove, obtain a copy, or limit the use of your Information. We will respond to your request at our earliest convenience and in compliance with in accordance with the applicable law.

11.Retaining Your Information

Unless we otherwise give you notice, we will retain your Information on the Platform until such times as you or we terminate your Account. On termination, you will have an opportunity to download, print, or copy your Information. You will be required to request any access you would like to notes made by a Healthcare Professional or On-Site Physician about your Consultation from the Healthcare Professional or On-Site Physician. On termination of your Account, we will delete the Information associated with your Account, except Information that a Healthcare Professional or On-Site Physician requires in connection with a Consultation or Healthcare Service the Healthcare Professional or On-Site Physician provided.

ClinicalHub may use service providers who operate in jurisdictions outside of Canada. Your Information may be subject to the laws in those jurisdictions.

12.Safeguarding Your Information

We have implemented technical, physical, administrative, and organizational precautions to protect the Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Despite our efforts, electronic communication and transmission of information is subject to inherent risks including but not limited to, an increase the risk of such information being disclosed to third parties, employers and online services who may have a legal right to inspect and keep electronic communications that pass through their system, malware which may potentially damage or disrupt the computer, networks, and security settings, or videoconferencing services such as Skype. TrueConf, Vidyo, Polycom, Cisco, LifeSize, VSee, or FaceTime which may be more open to interception than other forms of videoconferencing. Due to this, we cannot guarantee, ensure, or warrant the security of any information you transmit to us as it is not a 100% secure environment. You should always take steps to protect against unauthorized access to your Account, password, mobile device, and computer by, among other things, signing off your Account after using a computer, choosing a unique password, and keeping your Account information private. We are not responsible for anylost, stolen, or compromised passwords or for any activity on your Account via unauthorized access.

Email, text messages, and instant messages can be easier to falsify than handwritten or signed hard copies. It is not feasible for ClinicalHub to verify the true identity of the sender, or to ensure that only the recipient can read the message once it has been sent.

ClinicalHub does not guarantee that electronic communications will be reviewed and responded to within any specific period of time. If your electronic communication requires or invites a response from the Healthcare Professional or On-Site Physician and you have not received a response within a reasonable time period, it is your responsibility to follow up with ClinicalHub to determine whether the intended recipient received the electronic communication and when the recipient will respond.

Electronic communication is not an appropriate substitute for in-person or over-the- telephone communication or clinical examinations, where appropriate, or for attending the Emergency Department in your local area. You are responsible for following up on the Healthcare Professional’s electronic communication and for scheduling appointments where necessary.

We store your information in electronic format within Canada, using computer systems with restricted access in our facilities. ClinicalHub and its employees and associates are obligated to protect Information by adhering to our policies, practices and applicable laws.

ClinicalHub’s security policies, procedures, and controls are in accordance with industry- standard practices.

End-to-End Encryption:

ClinicalHub encrypts any and all video, audio, and written exchanges with you. Data transmissions and communications on the Platform are end-to- end encrypted.

13.Children Under 18

The Website, App, and Platform are intended for use by individuals 18 years of age and older. Parents or legal guardians over the age of 18 may open accounts with us for their own use, and use by their Registered Dependents. If you are under the age of 18, pleasedo not attempt to register with us or provide any Information about yourself to us. In the event that we collected Information from a child under the age of 18, we will delete such Information from our database.

14.Changes to This Policy

This Policy is current as the date at the top of this page. We may change this Policy from time to time, so please be sure to review it periodically. We will post any changes to this Policy on this page. If we make any changes to this Policy that materially affect our practices with regard to the Information we have previously collected from you, we will undertake to provide you with reasonable notice in advance of such change. We will collect, use and disclose your Information in accordance with the Policy that was in effect when such information was collected, except that if you furnish information to us after a change in our Policy, all information shall be governed by the Policy in effect at the time information was provided to ClinicalHub.

29. Contact Us

Please contact us at the address set out below if you have questions, suggestions, or concerns regarding ClinicalHub, the Website, App, Platform, or the Information that we have collected from you. Please include your name and contact information and we will respond as soon as possible.

ClinicalHub Medical Services Inc.

2711 Avonhurst Drive

Regina, Saskatchewan

Canada S4R 3J3

Tel: (306) 543-4566

Fax: (306) 543-4441