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There are a number of defined terms used in this Policy:
“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.
“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 that we can reasonably use to directly or indirectly identify you, such as your name, date of birth, country of origin, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and includes PHI (defined below).
“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” means Personal Information about an individual’s physical or mental health, or about their diagnosis, treatment and care.
“Subprocessors” means the third-party service providers engaged by Essential Clinic listed in the table under the heading (V).
“User(s)” means an individual or group who has requested Essential Clinic services and registered on the Essential Clinic Platform in accordance with our Terms of Service and is eligible to receive Healthcare Services and/or Informational Services through the Essential Clinic Platform.
“Website” means the Essential Clinic Platform.
Essential Clinic uses a number of safeguards to protect the privacy of Users (“you”, “your(s)”) of the Essential Clinic Platform and the confidentiality of their Personal Information including PHI.
This Policy is designed to provide transparency regarding Essential Clinic’s privacy policies with respect to your Personal Information we collect from you when you use the Essential Clinic Platform, in accordance with the rules and protections governing such information under applicable law.
We are committed to complying with this Policy and with all applicable Provincial and Federal privacy legislation and health information privacy legislation.
When discussing Healthcare Services, Personal Information refers to PHI, and when discussing Informational Services, Personal Information typically refers to Personal Information that is not specifically about you or your health, such as Personal 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.
(For an explanation of the services that Essential Clinic provides to Authorized Clinicians and to Users respectively, please refer to 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.)
This Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Personal Information by Authorized Clinicians or any other third party. Authorized Clinicians are subject to privacy legislation and professional requirements that govern their management of Personal Information, including Personal 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 Personal Information.
Your continued use of the Essential Clinic Platform after we make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates. We will notify you in advance of any material changes to this Policy and obtain your consent to any new ways that we collect, use, and disclose your Personal Information.
We collect Personal Information, including:
We also collect information that is not Personal Information such as:
We use a number of methods to collect Personal Information:
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.
The following are the purposes and methods by which we collect and use your Personal Information:
We collect and use your Personal Information to present the Essential Clinic Platform and its contents to you, and 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 Personal Information in the Essential Clinic Platform such as your medical records.
We use Personal 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.
When you make a payment transaction through the Essential Clinic Platform, the billing and payment Personal Information you submit will be automatically transferred to our third-party payment processors, Spreedly and Stripe. They collect this Personal Information to process the payment and otherwise in accordance with their own privacy policies. We do not collect or store this payment Personal Information.
For registered Users, we collect and use Personal Information:
Essential Clinic collects and uses Personal 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 Personal Information to what is needed for these purposes.
We use your Personal 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 use Personal 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 requested by you, your chosen pharmacy).
As mentioned, Authorized Clinicians are responsible for their own collection, use, disclosure, retention, destruction and protection of Personal Information. As a result, the following description is an overview only of the use generally made of Personal 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 Personal Information as described in this Policy in connection with a particular interaction with a User.
To request Healthcare Services, you describe applicable symptoms relevant to your request. We facilitate your disclosure to the Authorized Clinician of that Personal Information, along with age and gender to determine whether your request is eligible. The Essential Clinic Platform presents to the Authorized Clinician the Personal Information you provided in your consultation request, including your name and medical history from your intake forms. Once the Authorized Clinician confirms that your request is eligible, we identify the Authorized Clinician to you.
Authorized Clinicians may collect Personal Information about you when you provide it as part of your intake forms, during a Healthcare Services consultation (e.g., verbally or in texts), by viewing the Personal Information that you have entered or uploaded to the Essential Clinic Platform and/or by creating or compiling Personal Information in the Essential Clinic Platform. Personal Information that is submitted through the Essential Clinic Platform and that will be available to Authorized Clinicians includes: the details that you provide in your consultation request; Personal Information you’ve entered or uploaded to profiles and medical records; Personal 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.
Authorized Clinicians use Personal 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 Personal 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 Personal Information that they collect.
Authorized Clinicians collect and use Personal Information that you provide in the course of obtaining Informational Services, by viewing the Personal Information that you have entered or uploaded to the Essential Clinic Platform and by creating or compiling Personal Information in the Essential Clinic Platform. The Personal Information that they collect and use includes: the details that you provide in your request for Informational Services and Personal 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.
We collect and use Personal Information in the course of communicating with you, including in the following circumstances:
We collect and use your Personal Information for the following business development and marketing purposes:
Without limiting the foregoing, we may also collect and use Personal Information:
Other than to Authorized Clinicians, emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy, we will not disclose, share, sell or rent your Personal Information with or to any third party (except to the extent we disclose), except for the purposes set out below, with your consent, or to the extent necessary, in our good faith judgment, to: (i) comply with applicable laws or regulations; (ii) respond to a subpoena, order, or similar obligation to produce Personal Information; (iii) establish or exercise Essential Clinic’s legal rights or defend against legal claims; or (iv) 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.
By your use of the Essential Clinic Platform, you consent to us disclosing your Personal Information for the following purposes and to the following entities/persons:
|Subprocessor||Types of Personal Information processed||Processor Activities||Location|
|Amazon Web Services||All listed above (except analytics, device type, and payment Personal Information)||Cloud-hosting||USA & Canada|
|Authorized Clinicians (doctors and nurse practitioner we have contracts with)||All patient demographic, medical history, prescription preferences, communications with us||Medical counselling||Canada|
|Drift||Email, chat logs with customer support||Chat widget||USA|
|Checkout and payment events||Advertisement conversion tracking||USA|
|Google Adwords||Checkout and payment events||Advertisement conversion tracking||USA|
|Google Analytics||Session length, pages visited||Analytics||USA|
|Google GSuite||Any email correspondence user has with us. Notifications of orders placed.||USA|
|Mouseflow||IP address, session length, pages visited, interaction events with website||Analytics||USA|
|PocketPills, Panorama Pharmacy Inc, or pharmacy of user choice||Prescriptions issued for patient including patient demographics (date of birth, gender, address), basic medical history (allergies, medications patient is currently taking), and photo ID for identity verification purposes as required by pharmacy regulations||Dispensing of prescriptions||Canada|
|Checkout and payment events||Advertisement conversion tracking||USA|
|Slack||Name, order status, medical history for internal communication and collaboration on as needed basis.||Internal communication and coordination||USA|
|Spreedly||Credit card payment Personal Information||Payment Processing||USA|
|SRFax||Prescriptions faxed to pharmacies (see above)||Faxing of prescriptions to pharmacies||Canada|
|Stripe||Payment Personal Information (credit card details). Address. IP Address. Products and services paid for and subscribed to. Date medical history was last updated (but no medical history).||Payment processing||USA|
|Vouched||Government ID||ID Verification||USA|
|Xero||Patient emails, payment amounts, payment description.||Cloud Accounting||Canada|
|Zendesk||All listed above (except analytics, device type, and payment Personal Information)||Medical record storage and communication platform with patient||USA|
For the purpose of engaging the Subprocessors to perform tasks on our behalf, we may need to share Personal Information with them to obtain certain services. Unless we tell you differently, such Subprocessors 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 Subprocessors 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.
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.
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.
By your use of the Essential Clinic Platform, you give your authorization to Essential Clinic to collect, use and disclose the Personal Information as described in this Policy, and confirm that you have been made aware of the reasons why the Personal Information is needed and the risks and benefits to you of consenting or refusing to consent.
Without limiting the foregoing, you specifically consent to us sharing your Personal Information with the Subprocessors, including 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 may revoke your consent at any time by following the procedure outlined below.
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at email@example.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
Unless we otherwise give you notice, we will retain your Personal 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 Personal Information subject to the following. To ensure that Authorized Clinicians may exercise any authority they have to withhold Personal 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 Personal Information held on the Essential Clinic Platform; rather it holds Personal Information on behalf of Users or Authorized Clinicians. Within a reasonable time period following termination of your User Account, once you have been given the opportunity to print or make copies of your Personal Information, we will delete the Personal Information associated with your User Account, except Personal 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 Personal Information when the Authorized Clinician has obtained a copy or terminates his/her account with Essential Clinic.
Essential Clinic takes the security of your Personal Information seriously. We store your Personal 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 Personal Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Essential Clinic Personnel are obligated to protect Personal Information by adhering to our policies, practices and applicable laws.
We only permit our Personnel to access Personal Information to the extent necessary to perform their designated functions. We require them to protect the Personal Information and maintain its confidentiality by complying with our policies, procedures and applicable law.
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 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 the 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.
We use encryption and other security measures to protect the confidentiality of all our email communications. However, notwithstanding our best efforts, as with any Internet transmission of data, emails can still be subject to hacking or unauthorized access by external actors. Accordingly, we ask Users to exercise caution in how much Personal Information and especially PHI they share with us by email.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Further, should you choose to print out or otherwise replicate Personal Information you have submitted to the Website, we will not be responsible for any consequent dissemination or loss of such replicated Personal Information. our data security measures cannot be extended to physical copies or other representations or replicas of Personal Information created or derived by you, from the Website.
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 Personal 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 Personal Information available to you, such as where that Personal 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 Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at firstname.lastname@example.org to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable Law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
If you are concerned about our response or would like to correct the information provided, you may contact us at email@example.com.
If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance Officer. Please include your name and contact Personal Information if you’d like us to respond to you.
ATTN: Chief Compliance Officer
400-119 14th St NW, Calgary, AB T2N1Z6
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 Personal Information