Privacy Policy

Last Revised: May 31, 2023

This Privacy Policy governs how PurposeMed Inc., operating as Connect-Clinic (“Connect-Clinic”, “us,” “we, or “our”) collects, stores, uses, discloses and otherwise manages your Personal Information and your Personal Health Information (collectively, “Information”). For the purposes of this Privacy Policy, “Personal Information” means information about an identifiable individual, including your name, phone number, email address, gender, birth date, payment card information and internet protocol (IP) address used to connect your computer to the internet, but excluding Personal Health Information; “Personal Health Information” means information about an identifiable individual’s health or healthcare, including information that is collected or created by the Connect-Clinic Platform (defined below) healthcare team in the course of providing healthcare services to you, information concerning your physical or mental health history, health status, symptoms, diagnosis, laboratory testing results and diagnostic images, healthcare-related personal identification numbers, information concerning any healthcare service and advice provided to you, including referrals, recommended follow up or next steps, and other health-related information. Personal Information and Personal Health Information do not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.

This Privacy Policy applies to our privacy practices on (1) the Connect-Clinic website located at connect-clinic.com/privacy-policy (the “Website”); (2) the Connect-Clinic online platform, and (3) all other services provided by Connect-Clinic, as described on or through the Connect-Clinic online platform or Website (collectively, the “Connect-Clinic Platform”).

‍PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE CONNECT-CLINIC PLATFORM YOU CONSENT TO THE COLLECTION, STORAGE, USE AND DISCLOSURE OF YOUR INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

COLLECTION AND USE OF INFORMATION

Connect-Clinic provides individuals with access to authorized physicians and authorized non-physician health care providers such as nurse practitioners (collectively, “Health Care Practitioners”) and personal health assistants (“PHAs”) by secure text, video and audio chat for virtual care consultations (“Health Services”), and related healthcare and administrative support services (“Support Services”) through the Connect-Clinic Platform (together referred to as “Services”).

Provision of Services: Connect-Clinic collects and uses Information for the purpose of providing and facilitating the provision of the Services. For example, we use Information to verify your identify, determine your eligibility for Health Services, and provide you with services that you request us to perform on your behalf, such as transmitting your prescription to your chosen pharmacy.

Registration on the Connect-Clinic Platform: You do not have to register in order to browse our Website. However, in order to use the Connect-Clinic Platform to receive Services, you will need to register for an account with us and provide your name and email address. You will also need to disclose information about your current health condition and health history to Health Care Practitioners and PHAs in order to enable them to provide you with appropriate Services. We use your Information to identify who you are, communicate with you, and otherwise administer your use of the Connect-Clinic Platform to receive Services. The Connect-Clinic Platform in intended solely for individuals who have attained an age of 16 years or older.

Quality of Care: If you receive Services, members of the Connect-Clinic team may review your Personal Information and Personal Health Information in order to evaluate and/or improve the quality of Services or the Connect-Clinic Platform, including responding to any inquiries from you.

Payments: If you choose to purchase any services from us, we collect your payment information such as your payment method, payment card number, CVV code, and postal code. This Information is used to process your payments. We use a third-party service provider to facilitate secure payment processing.

Electronic Communications: If you have consented, Connect-Clinic may use your Information to send you electronic communications, such as emails and SMS messages, containing promotional marketing materials about Connect-Clinic’s products or services, including our newsletter.

Technical Support: When you speak to our support staff, all audio conversations will be recorded to ensure quality of service to you and for training purposes.

Job Applications: If you apply for a job at Connect-Clinic, you may provide us with certain Information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this Information for the purpose of processing and responding to your application for current and future career opportunities.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a telephone number) along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this Information to assist you in the future and to improve our customer service, service offerings, and the Connect-Clinic Platform.

‍DISCLOSURE OF YOUR INFORMATION

We will not rent, exchange or sell your Personal Information or your Personal Health Information.

We may transfer or disclose Information as follows:

Circle of Care: If you receive Services through the Connect-Clinic Platform, we may to disclose your Information to and among Health Care Practitioners and PHAs for the purpose of providing or assisting in the provision of Services to you. We may disclose your Information to third parties such as other health professionals, specialists, pharmacists, pharmacies and laboratories for the purpose of providing or assisting in the provision of Services to you.

Service Provider Arrangements: In connection with the Connect-Clinic Platform and/or Services provided by Connect-Clinic, your Information may be transferred to our suppliers, agents or other organizations or individuals who provide services or functions on our behalf. For example, we may use service providers to process payments, host our Website and store information on our behalf. Our service providers are given only the Information they need to perform their designated functions and we use contractual controls to protect this Information. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.

Sale of Business: Connect-Clinic may transfer Information as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Connect-Clinic or as part of a corporate reorganization or other change in corporate control.

Affiliates: Connect-Clinic may disclose Information to its affiliates for the purposes set out in this Privacy Policy.

Legal: Connect-Clinic and our affiliates and service providers may disclose Information to third parties where required or permitted by applicable law (which may include access by courts, law enforcement and national security authorities in Canada).

‍INFORMATION ABOUT OUR PLATFORM

As you use the Connect-Clinic Platform, certain Information may be passively collected by Cookies, navigational data like Uniform Resource Locators (URLs) and third party tracking services, including:

Access Device and Browser Information: When you access the Connect-Clinic Platform 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.

Cookies: The Connect-Clinic Platform uses a technology called “cookies”. A cookie is a tiny element of data that the Connect-Clinic Platform sends to your browser, which may then be stored on your hard drive so that we can recognize your browser when you return. We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Connect-Clinic Platform, you may not be able to take advantage of all of the features of the Connect-Clinic 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 push notifications to notify about activity on your account, such as messages from our Health Care Practitioners. Examples of information that may be collected and used include your device’s unique identifier, manufacturer, model, and operating system version. In addition, in the event our application(s) crash(es) on your mobile device we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).

Real-Time Video and Audio Conversations: You may be required to connect with Health Care Practitioners and PHAs through a real-time video and audio call to receive certain Health Services such as diagnoses and advice, and to verify your identity. All video and audio calls conducted through the Connect-Clinic Platform are confidential and end-to-end encrypted and accessible only to you and the Health Care Practitioners and PHAs responsible for your care. These calls are never recorded or stored and cannot be accessed at a later date.

Text-based Chat: No Personal Health Information will be requested during these conversations.

Third Party Links: The Connect-Clinic Platform may contain links to other websites or platforms that Connect-Clinic does not own or operate. Also, links to the Connect-Clinic Platform may be featured on third party websites or platforms on which we advertise. Except as provided in this Privacy Policy, we will not provide your Information to these third parties without consent. We provide links to third party websites or platforms as a convenience to our users. These links are not intended as an endorsement of, or referral to, the linked websites or platforms. The linked websites or platforms have separate and independent privacy statements, notices and terms of use. We do not have any control over such websites or platforms, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use or disclose, secure and otherwise treat personal information.

‍SECURITY OF INFORMATION

We understand that data security is a critical issue for our clients and we are committed to safeguarding the Information in our custody and under our control.

Connect-Clinic has implemented a comprehensive information security program that includes written policies and procedures, and security controls. We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, loss, modification and disclosure of Information in our custody and control.

Connect-Clinic’s security policies, procedures, and controls are tested and audited by a third party on an ongoing basis, using industry-standard practices.

Our privacy practices are intended to comply with applicable privacy laws, including without limitation, the Alberta Personal Health Information Act (“HIA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We will maintain the privacy and security of your Information as required by applicable privacy laws, including without limitation, HIA and PIPEDA and the regulations under those Acts. By using the Connect-Clinic Platform, you consent that your Information may be stored, processed, or transferred to other provinces or countries which may not guarantee the same level of protection of personal data as the one in which you reside. Your Personal Information will be subject to the local laws of the jurisdiction where it is transferred and in certain circumstances, other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal information.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Information, we cannot guarantee the security of your Information transmitted through the Connect-Clinic Platform. Any transmission of Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Connect-Clinic Platform.

‍ACCESS AND CORRECTION OF INFORMATION

Connect-Clinic takes reasonable steps to ensure your Information is accurate, complete, and up to date. If you become aware that any Information in our possession about you is not correct, please contact our customer support. Contact information may be found under the heading “Contact Us”.

You are entitled to a copy of the Information that we have in our possession or under our control; if you would like a copy of such Information, please contact us. We will take reasonable steps to verify your identity before granting access or making corrections. In addition, your right to access or correct your personal information is subject to certain legal restrictions.

‍ANONYMIZED INFORMATION

We may use non-identifiable information created by us from your Information in order to better understand and improve the Connect-Clinic Platform and our service offerings. We may share such non-identifiable information with our partners to assist in research, planning, or product and service development.

RETAINING YOUR INFORMATION; WITHDRAWAL OF CONSENT

We retain Information only for as long as necessary to fulfil the purposes described in this Privacy Policy or as required to meet legal or regulatory requirements. We will retain any and all Information that we are required to retain under any applicable laws and regulations for the full duration of time required under those laws and regulations. We may also retain non-identifiable information and continue to use this information in accordance with this Privacy Policy.

You may request that we delete the Information that we maintain about you, but please note that we may be required to maintain certain Information in order to meet our legal obligations (in which case we will comply with your deletion request only after we have fulfilled such obligations). When we delete Information, it will be deleted from the active database, but may remain in our archives and we may also retain Usage Information. After we delete Information, we may retain non-identifiable Information and will continue to use non-identifiable information as permitted under this Privacy Policy.

You can withdraw your consent to our collection, use and disclosure of your Information by contacting us at genderaffirmingcare@purposemed.com, subject to certain legal or contractual restrictions. However, if you refuse to provide certain information or withdraw your consent, this may limit our ability to provide you with certain services, products and functionalities.

REPORT VIOLATIONS

You should report any privacy or security violations, including any suspected or actual unauthorized access, use or loss, of Information, to us by sending an email to genderaffirmingcare@purposemed.com.

CHANGES TO THIS POLICY

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Information, we will notify you by email to the email address specified in your account or through a revised privacy policy on the Website.

We include the date the Privacy Policy was last revised at the bottom of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

CONTACT US

We welcome your questions, comments, complaints and requests regarding this Privacy Policy and our privacy practices. Please contact us at: genderaffirmingcare@purposemed.com.