Privacy Policy

The Essential Clinic Privacy Policy was updated on Jan 19, 2022.

The words and phrases used in this Policy have the same meaning as in EssentialClinic.ca's Terms of Service. You can also find a list of definitions at the bottom of this Policy or if you still have questions, contact our Chief Compliance Officer as indicated below.

Essential Health Systems Inc. doing business as EssentialClinic.ca (" Essential Clinic", " we", " us") uses a number of safeguards to protect the privacy of Users of the Essential Clinic Platform and the confidentiality of their Personal Information including Personal Health Information (collectively referred to together in this Privacy Policy as " Information"). When discussing Healthcare Services, Information typically refers to Personal Health Information (" PHI"), and when discussing Informational Services, Information typically refers to information that is not specifically about you or your health, such as information in questions you would be comfortable asking of an expert during the call-in portion of a radio broadcast on health-related matters. PHI is not required for Informational services, and we advise you to not to submit PHI in the course of accessing Informational Services.

The agreement between Essential Clinic and clinicians providing services through the Essential Clinic Platform, (Essential Clinic Clinician Services Agreement) and the Terms of Service for the Essential Clinic Platform explain the services that Essential Clinic provides to Authorized Clinicians and to Users respectively. This Privacy Policy (" Policy") summarizes how Essential Clinic collects, uses, discloses, retains, disposes of, destroys and protects Information as well as Data (information that does not identify an individual) in the course of providing our services. We are committed to complying with this Policy and with applicable Provincial and Federal privacy legislation.

Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Clinicians or any other third party. Authorized Clinicians 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 Essential Clinic Platform. Please feel free to ask any Authorized Clinician to whom you are referred if you have questions about how he or she will treat your Information.

Collecting and using Information

Essential Clinic collects and uses Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes.

As mentioned, Authorized Clinicians are responsible for their collection, use, disclosure, retention, destruction and protection of Information. As a result, the following description is an overview only of the use generally made of Information for the purpose of providing services through the Essential Clinic Platform. A particular Authorized Clinician may or may not choose to collect or use Information as described below in connection with a particular interaction with a User.

Healthcare Services

Authorized Clinicians may collect Information about you or any Registered Dependent (as defined below) when you provide it as part of your intake forms, during a Healthcare Services consultation (e.g., verbally or in texts), by viewing the Information that you have entered or uploaded to the Essential Clinic Platform and/or by creating or compiling Information in the Essential Clinic Platform. Information that is submitted through the Essential Clinic Platform and will be available to Authorized Clinicians includes: the details that you provide in your consultation request; information you've entered or uploaded to profiles and medical records; information created during earlier interactions through the Essential Clinic Platform with other Authorized Clinicians; the name, email address, phone number, gender and date of birth, health card number, and province/territory that you provided when you registered, as well as medical history and symptoms (allergies, medications taken, past surgery history, and answers to specific medical questions) in order to get the appropriate treatment, desired prescription). This information is used to match you with an Authorized Clinician.

Authorized Clinicians use Information to provide you with Healthcare Services and/or Informational Services and, as with any clinician, must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Clinicians may create Information such as prescriptions, and other notes about your interaction with them through the Essential Clinic Platform. They may export or print copies of your Information that they collect.

Informational Services

Authorized Clinicians collect and use Information that you provide in the course of obtaining Informational Services, by viewing the information that you have entered or uploaded to the Essential Clinic Platform and by creating or compiling Information in the Essential Clinic Platform. The Information that they collect and use includes: the details that you provide in your request for Informational Services and information that you provided to register to use the Essential Clinic Platform (name, gender, date of birth and place of residence) to confirm your eligibility to receive Informational Services. Authorized Clinicians are bound to comply with privacy legislation applicable to providers of Informational Services.

Provision of the Essential Clinic Platform

We collect and use your Information to register you and personalize your experience while using the Essential Clinic Platform. We confirm your eligibility to use the Essential Clinic Platform for Healthcare Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.

You may choose to enter or upload and store your Information in the Essential Clinic Platform such as your medical records.

We use Information that you enter, or upload, or which is created as part of an interaction with an Authorized Clinician to make it available to you when you access your User Account.

We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.

We may use Information to help us create, develop, operate, deliver, support and improve the Essential Clinic Platform, its content and advertising provided to you through it (Essential Clinic's and third parties') unless you have decided not to receive such advertising.

To request Healthcare Services, you describe applicable symptoms relevant to your request. We facilitate your disclosure to the Authorized Clinician of that information, along with age and gender to determine whether your request is eligible. Once the Authorized Clinician confirms that your request is eligible, we identify the Authorized Clinician to you. The Essential Clinic Platform presents to the Authorized Clinician the Information you provided in your consultation request, including your name and medical history from your intake forms.

We use Information that you enter to provide you with services that you request us to perform on your behalf, e.g., securely sending your prescription to one of our third-party pharmacy partners (or if request by you, your chosen pharmacy.)

We use your Information to text or email you to notify you about services that you request. For example, we notify you about the status of your consultations and other requests, such as prescription orders.

We may collect location data through the use of GPS technology and your IP address where applicable to services you have requested, e.g., ensuring you are connected to an Authorized Clinician or pharmacy that is licensed or authorized to provide such services in the jurisdiction where you are located. When you make a payment transaction through the Essential Clinic Platform, the billing and payment information you submit will be automatically transferred to our third-party payment processors, Spreedly and Stripe. They collect this information to process the payment and otherwise in accordance with their own privacy policies. We do not collect or store this payment information.

Collection and Use of Government ID

We are required to collect a copy of your government-issued photo identification, and the personal information about you on such identification, for the following purposes:

To verify your identification itself: a copy is shared with our service provider, Vouched, who then extract the user's name, date of birth, address, ID type, country, province, issue date and expiry date, as well as the last few numbers of the ID number. Vouched, in turn, has its own privacy policy that applies when it collects this information from us.

We will retain this information ourselves after sharing it with Vouched, for the purpose of filling future orders from you. However, if you wish to revoke consent to us keeping this information, please see our Privacy Policy for details on how to request us to delete and remove that information.

To comply with law: (1) Pharmacies in British Columbia and other provinces are required by law¹ to collect identifying information about patients before filling prescriptions. We must therefore provide this information to our pharmacy partners that supply our clients. (2) As well, we must provide this information to our professional providers who may provide services to you, as they are required by law to collect such information by their own professional regulatory legislation. We retain this information ourselves after sharing it with the pharmacists or professional providers. Pharmacists and other health care professionals all have their own very strict health information privacy rules and protection methods.

By your use of the Essential Clinic Platform, you consent to the collection of your personal identifying information by us for the purposes described above, and consent to our sharing it with Vouched or other similar third party identity verification provider, with the pharmacists from whom we obtain remedies for our clients, and with any professional providers that may provide you telemedicine services. You will also be prompted to confirm this consent at the time of registration.

Communicating with you

Medical emergencies associated with requests for Healthcare Services. Should you submit Information about a medical issue, which is deemed an emergency by an Authorized Clinician prior to their acceptance of your request for Healthcare Services, Essential Clinic reserves the right to contact you at any time using any of the contact information you have provided. This contact is strictly for the purpose of informing you that an Authorized Clinician has viewed your anonymized request and has declined the request based on their belief that your symptoms may represent a medical emergency.

Updates and marketing. From time to time, we may send you service announcements, including policy updates and updates to our Terms of Service and software and keep you posted on our latest products and any upcoming events that may be of interest to you or apply to you. You may opt-out of receiving non-essential communications through the an unsubscribe link or similar in the communication you receive or by contacting us. For clarity, service announcements including updates to our policies and Terms of Service and software are not considered non-essential communications.

Customer support. If you email, fax, write to us or complete a 'contact us' form on the Essential Clinic Platform, we will collect the name and contact information that you provide to us and will use it to respond to you.

We only permit our Personnel to access Information to the extent necessary to perform their designated functions. We require them to protect the Information and maintain its confidentiality by complying with our policies, procedures and applicable law.

Disclosing Information

We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Clinicians, emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Essential Clinic's legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person.

We may disclose Information for the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.

We may from time to time employ third parties to perform tasks on our behalf and we may need to share Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage include third party companies and individuals employed by us to facilitate our services, including the provision of database management, payment processing and customer relationship management tools. For a list of our current third-party sub-processors, please see of Sub-processors Page.

Retaining and disposing of Information

Unless we otherwise give you notice, we will retain your Information on the Essential Clinic Platform on your behalf until such times as you or we terminate your User Account (unless a longer period is required by applicable laws or regulations). On termination, you will have an opportunity to print or make copies of your Information subject to the following. To ensure that Authorized Clinicians may exercise any authority they have to withhold Information they compile in connection with Healthcare Services from patients under the law, you will be required to request any access from Authorized Clinician about your consultation from the Authorized Clinician.

As mentioned above, Essential Clinic is not the custodian of Information held on the Essential Clinic Platform; rather it holds Information on behalf of Users or Authorized Clinicians. Within a reasonable time period followingOn termination of your User Account, once you have been given the opportunity to print or make copies of your Information, we will delete the Information associated with your User Account, except Information that an Authorized Clinician advises us he or she requires in connection with a consultation or Informational Services the Authorized Clinician provided. In such circumstances, Essential Clinic will destroy the Information when the Authorized Clinician has obtained a copy or terminates his/her account with Essential Clinic.

Safeguarding Information

Essential Clinic takes the security of your information seriously. We store your information in electronic format using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Essential Clinic Personnel are obligated to protect Information by adhering to our policies, practices and applicable laws.

Essential Clinic processes and stores its data, including Personal Information, on servers located in Canada and the United States. Essential Clinic also transfers data to the following third-party service providers described on our Sub-Processors webpage. By submitting Personal Information or otherwise using the services, you agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

Cookies and similar technologies

The Essential Clinic Platform, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. We use these technologies to better understand User behaviour, analyze trends, administer, personalize and improve the experience of using the Essential Clinic Platform. You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, the Essential Clinic Platform might not function correctly. In particular, Essential Clinic uses the following types of cookies:

• Our advertisement partners use cookies to track results of ad campaigns (marketing) and re-marketing our service within other websites the user may visit. User can opt out by visiting the advertisement platform's website (e.g. AdWords' opt-out instructions) and opting out from there.

• Our login systems use cookies to remember if the device the user is using is already authenticated or not. User can opt out by logging out immediately after logging in and performing the task they need to do. They can also disable cookies in their browser via extensions such as EFF Privacy Badger or unselect any visible "Remember Me" type checkboxes.

• Our chat widget (Drift) uses cookies to retrieve user's chat history and track the same user over multiple visits (see https://gethelp.drift.com/hc/en-us/articles/360019665133-What-is-the-Drift-Cookie-Security-and-Privacy-Policy-). Users can opt-out by disabling cookies on their browser or using a Chrome extension such as EFF Privacy Badger to selectively disable specific cookies.

• Our proprietary intake forms and app within our website uses cookies to store the user's answers to our intake forms so that the answers are remembered and can be restored for the user in case the user leaves the website (for up to 7 days). The cookie is deleted once the user completes the form and submits the information to our server. User can opt-out by disabling cookies on their browser or using a chrome extension such as EFF Privacy Badger to selectively disable specific cookies

Essential Clinic also uses third parties to assist in tracking certain anonymized information of users and visitors to our website the Essential Clinic Platform. In particular, we keep track of device information and browser type, screen resolution, as well as session length, pages visited, interaction events such as clicks and mouse movements, and javascript errors. We use this information on an anonymized basis to gain a better understanding of our customer demographics and preferences in order to improve our products and services. For more information on those third parties, please see our Sub-processors Page.

Users can opt out of Mouseflow by following Mouseflow's Opt-Out instructions.

Users can opt out of Google Analytics by following Google Analytic's Opt-Out instructions.

Links and third party websites and applications

The Essential Clinic Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.

Policy changes

We publish the current version of our Policy at https://www.essentialclinic.ca/privacy-policy. We reserve the right to amend our Policy at any time. Check back often to ensure you are aware of our current practices for collecting, using, disclosing, retaining, destroying and protecting Information.

Privacy Rights

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Contact Us

If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance Officer. Please include your name and contact information if you'd like us to respond to you.

Essential Clinic ATTN: Chief Compliance Officer 400-119 14th St NW, Calgary, AB T2N1Z6

Definitions

"Authorized Clinician" means a clinician who is registered to practice medicine in a Province or Territory of Canada, meets Essential Clinic's other criteria, and is permitted to provide Healthcare Services and/or Informational Services through the Essential Clinic Platform.

"Data" means information collected or compiled through the Essential Clinic Platform which has been de-identified.

"De-identify" in relation to PHI, means to remove information that identifies the individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify the individual.

"Device" means a mobile or desktop device owned or controlled by a User and used to access Essential Clinic Clinician Services.

"Health Care" means any observation, examination, assessment, care, service or procedure that is provided by a clinician to an individual to diagnose, treat, or maintain the individual's physical or mental condition, to prevent disease or injury to the individual, or to promote the individual's health.

"Healthcare Services" means the provision of Health Care by an Authorized Clinician through the Essential Clinic Platform.

"Informational Services" means the provision of general information about a disease or condition, rather than patient specific medical information, for educational purposes only and for clarity, not including a diagnosis, treatment or advice based on observation, examination or assessment of a particular patient.

"Essential Clinic Platform" means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Clinicians to provide Healthcare Services and Informational Services to Authorized Users.

"Personal Information" means information about an identifiable individual which is not PHI and which is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Essential Clinic Platform.

"Personnel" in relation to Essential Clinic, means its employees and agents including independent contractors and sub-contractors, for whom Essential Clinic is responsible at law.

"PHI" or "personal health information" means information about an individual's health or healthcare that is subject to Privacy Law and that is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Essential Clinic Platform.

"Privacy Law" means the applicable legislation governing the collection, use, disclosure, and/or protection of PHI in the Province or Territory in which a User resides.

"User" means an individual who has requested Essential Clinic service in accordance with our Terms of Service and is eligible to receive Healthcare Services and/or Informational Services through the Essential Clinic Platform.

Sub-Processors

To support Essential Clinic in delivering the services and Essential Clinic Platform, Essential Clinic engages third-party service providers as sub-processors.

This page identifies our sub-processors, describes where they are located, lists what services they provide to us and identifies the type of personal information processed.

Our business needs may change from time to time and Essential Clinic will periodically update this page to provide notice of additions and removals to our list of sub-processors.

¹College of Pharmacists of British Columbia, Health Professions Act Bylaws, Schedule “F”; and CPBC Professional Practice Policy 75, “Patient Identification”