EMERGE Virtual Care Privacy Policy
This policy explains how we collect, use and disclose your personal health data when you use our healthcare services and products in Canada, or visit or use the EMERGE Virtual Care App or any of our websites that link to this policy (collectively, our “App”).
We want to help you understand how we manage your data, so that you can make informed decisions and be in control of your information.
The agreement between EMERGE Virtual Care and healthcare providers providing services through the EMERGE Virtual Care Platform, (EMERGE Virtual Care Healthcare Provider Services Agreement) and the Terms of Use for the EMERGE Virtual Care Platform explain the services that EMERGE Virtual Care provides to Authorized Healthcare Providers and to Users respectively.
Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Healthcare Providers. Authorized Healthcare Providers are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use and retain in the course of providing services through the EMERGE Virtual Care Platform. Please feel free to ask any Authorized Healthcare Provider to whom you may connect through EMERGE Virtual Care if you have questions about how he or she will treat your Information.
A particular Authorized Health Care Provider may or may not chose to collect or use Information as described below in connection with a particular interaction with a User.
If you have any questions about how we process your information, please don't hesitate to get in touch by contacting our Privacy Officer at privacy@getemerge.ca
1. About Us
Your relationship is with 12677776 CANADA LTD. When this policy talks about 'EMERGE Virtual Care', 'us', 'we' or ‘our’, it means 12677776 CANADA LTD.
Our website and App provide information services and digital healthcare software services through our digital healthcare tools (such as Virtual Care feature).
As health information custodians, healthcare providers may also be subject to legislative and professional requirements that govern their management of your information.
2. Information We Collect
We use the following categories of personal data:
Personal details
When you register with us, you complete your health profile and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. You may also provide us health card number/provincial health insurance number for the purposes of the healthcare provider bill the public health system. You are responsible for the accuracy of the information that you provide to us.
Health and medical information
The main type of information we hold about you is health and medical information: information about your health, symptoms, treatments, consultations and sessions, medications and procedures. This includes details of your consultations with our doctors.
We get some of this information directly from you, when you register with us and when you use our healthcare services.
We do not retain recordings of our consultations, but we do retain records of interactions with you. To monitor our service quality, we may retain records of when you contact our support teams via email or phone.
3. Provision of the EMERGE Virtual Care Platform
- We collect and use your Information to register you, create your Personal Profile, authenticate you when you log in into the EMERGE Virtual Care Platform.
- We collect your provincial health card number in order to the healthcare provider of your choice can bill provincial health plans for those services that are eligible for coverage by provincial health plans.
- You may choose to enter and store your Information in the EMERGE Virtual Care Platform such as your medical conditions, and allergies.
- We use Information that you enter, or which is created as part of an interaction with an Authorized Healthcare Provider to make it available to you when you access your Personal Profile.
- We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.
Users eligible for Virtual Care feature:
To request Virtual Care, you need to describe the symptoms relevant to your request. You may also specify whether you’re seeking to renew a prescription or obtain a sick note. We facilitate your disclosure to the selected Authorized Healthcare Provider of that information, along with age and name to determine whether your request is eligible. Once the selected Healthcare Provider confirms that your request is eligible, we disclose the remaining of your information saved on your profile with the selected Healthcare Provider. Unless you have elected not fill your information in the EMERGE Virtual Care Platform about you, the selected Authorized Health Care Provider will be able to view it too.
We may collect location data through the use of GPS technology and your IP address where applicable to services you have requested, e.g., show nearby providers. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.
4. Technical Information and Analytics
When you use our App or visit our website, we may automatically collect the following information where this is permitted by your device or browser settings:
- Technical information, including the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system platform type and version, device model, browser or app version, time zone setting, language and location preferences, wireless carrier and your location (based on IP address); and information about your visit (such as when you first used the App and when you last used it, and the total number of sessions you have had on that App), including products and services you viewed or used, App response times and updates, interaction information (such as button presses or the times and frequency of your interactions with the communications we deliver to you in the App or otherwise) and any phone number used to call our customer service number.
- Cookies and similar technologies may be used to collect this information, such as your interactions with our services. You can change your device settings to block cookies, or to notify you before a cookie is set. If you block cookies, you may not be able to use all the features of our App. You can prevent the setting of cookies by adjusting the settings on your browser or your mobile phone. This technical information is not linked to your medical record. Your health information is not analyzed to target you with advertising services.
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At EMERGE, we collect certain data from our users' mobile phones, such as GPS location, camera, images and files, Bluetooth, and audio, in order to provide a more personalized and effective healthcare experience. This data is only collected with the user's explicit consent and is used solely for the purpose of providing virtual care services through our platform. We take the privacy and security of our users' data very seriously and are committed to ensuring that it is used in a responsible and transparent manner.
5. Use of Personal Information
The purposes for which we use your personal data and the grounds on which we do so are set out below. We generally use personal data with your consent, except where the use of personal data without consent is permitted by law.
Providing you a service
We obtain and use your personal details in order to verify your identity and eligibility for our services, establish and deliver our contract with you including to provide the services you request.
We collect, use and transfer your medical information in order to the selected healthcare provider perform effective diagnosis, treatment and care. This includes the information collected through our consultations with you (such as notes), our digital services. The selected healthcare provide may also share information with other healthcare professionals as necessary for the provision of care to you, such as your Family Doctor, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, and laboratories chosen by you for the purpose of health exams.
Keeping you up to date
As part of providing you, with high quality health care services, we may contact you by SMS, email and/or other means to provide appointment reminders, offer you helpful information.
We may also use your email address, postal address, phone number and/or name to contact you or present you with occasional updates and marketing messages where you have not opted out.
You can opt out receiving these communications at any time by following the instructions contained within the marketing communication.
Other uses
Based on our legitimate interest in managing and planning our business, we may analyze data about your use of our products and services to, for example, troubleshoot bugs within the App or our website, forecast demand of service
and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you that would have a significant legal effect on you – it is only about improving our App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
Where necessary, we may need to share personal details for the purposes of fraud prevention and detection.
We also store your medical information, such as notes from consultations and your interactions with our digital services. For example, we may need to review your information and, where necessary, make disclosures in compliance with lawful requests by regulatory bodies or as otherwise required by law or regulation.
Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.
We may obtain and use data about your precise location where you give your consent (through providing us access to your location through your App or browser settings or your address), for example, to help direct you to the nearest healthcare provider.
Sharing your personal data with others
We have partnered with local healthcare providers to provide you healthcare services through our platform. Your personal data will be shared with the healthcare provider of your choice when necessary to allow local healthcare providers to provide these services to you and to us.
We will, where necessary for your treatment or care, share your information with your other health and social care providers. We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.
We may share your personal information with companies we have hired to provide services on our behalf, such as data hosting and processing, technical support, marketing and communications. These service providers are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
Where you access our services through public health insurance, and where you have given your consent, we will provide the selected healthcare institution of your choice with the personal information required to allow them to process your claim. This may include your name, email address, policy number, location, demographic information, that you had an appointment through us, the date of the appointment, details of your diagnosis, prescription, pharmacy location, whether or not you had a referral made and other similar information about your appointment through EMERGE Virtual Care. Personal information provided will be limited to only what is required.
Retention
Unless we otherwise give you notice, we will retain your Information on the EMERGE Virtual Cate Platform on your behalf until such times as you or we terminate your Personal Profile. To ensure that Authorized Healthcare Providers may exercise any authority they have to withhold Information they compile in connection with Virtual Care consultations from patients under the law, you will be required to request any access you would like to notes made by an Authorized Healthcare Provider about your consultation from the Authorized Healthcare Provider. EMERGE Virtual Care is not the custodian of Information held on the EMERGE Virtual Care Platform; rather it holds Information on behalf of Users or Authorized Healthcare Providers. On termination of your Personal Profile, we will delete the Information associated with your Personal Profile, except Information that an Authorized Healthcare Provider advises us he or she requires in connection with a consultation. In such circumstances, EMERGE Virtual Care will destroy the Information when the Authorized Healthcare provider has obtained a copy or terminates his/her account with EMERGE Virtual Care.
Data storage, security and transfers
We do not store your medical information on your mobile device.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
While some of your personal information may be processed outside of Canada, we store all of your medical information on secure servers in Canada.
Some of your personal information may be processed or accessed outside of Canada by EMERGE Virtual Care or our service providers. Regardless of location, personal information will be protected in accordance with the applicable data protection law and subject to strict safeguards. For example, when we do transfer personal information outside of Canada, we strive to minimize the amount of personal information to what is absolutely necessary to achieve the specified purpose. Notwithstanding these safeguards, while outside of Canada, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access personal information in certain circumstances. We will only provide, and our service providers are only permitted to provide, personal information in these circumstances if we or they are compelled to do so under applicable laws.
6. Personal Information Protection
EMERGE Virtual Care takes the security of your information seriously. We store your information in electronic format within Canada. More generally, we have in place appropriate technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, EMERGE Virtual Care employees are obligated to protect Information by adhering to our policies, practices and applicable laws.
You also play an important role in protecting your privacy and the confidentiality of your Information.
For example:
- Create a strong and unique password for your Personal Profile and update it periodically.
- Do not share your Personal Profile or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.
- Log out of your Personal Profile once you are finished using it, especially if you share your Device with anyone else.
- Have a strong and unique password on your Device.
- Choose a quiet, private location from which to receive services from Authorized Healthcare Providers.
7. Your rights
As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by emailing us with your request.
You may also have the right to:
Request access to the personal data we hold about you. For other information, you can make a request by email;
Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
Ask us to restrict our processing of your personal data or object to our processing.
8. Contact us
For any questions or concerns, or if you’d like information about how to create a complaint with us or an applicable privacy commissioner’s office, you can contact us by sending an email to
privacy@getemerge.ca
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