Last Updated: June 29, 2022
Modern Health Canada Inc. (“Modern Health”, “we” or “us”) provides a website platform located at https://modernhealth.ca/ (the “Website”) that allows its healthcare and wellness provider customers to deliver health and wellness services to their clients, including client intake, appointment and calendar scheduling, secure messaging, video sessions, billing and payments, client record storage, and website hosting. Modern Health provides the Website as a service to its healthcare and wellness provider customers (the “Services”).
Please note that in providing Services, Modern Health generally acts as a “service provider” (or equivalent term) to its customers under applicable private or health sector privacy legislation.
TABLE OF CONTENTS
- Collection and Use of Personal Information
- Sharing of Personal Information
- Information About Our Website
- Interest-Based Advertising
- Safeguards and Retention
- Your Choices
- Access to Information
- Contact Us
COLLECTION AND USE OF PERSONAL INFORMATION
In the course of acting as a service provider and providing the Services to our customers, we may obtain information about identifiable individuals (“personal information”) on behalf of our customers regarding their clients, employees, or authorized users (such as healthcare providers employed by our customers) as outlined below.
We require our customers to ensure that they have the authority to provide personal information to us in accordance with applicable privacy laws. Except as set out herein, we collect and use our customers’ personal information only for the purpose of providing Services to our customers.
In certain limited contexts, we may collect personal information on our own behalf, such as in connection with visits to our websites, job applications, events and surveys.
Information we process on behalf of our customers:
- Create an Account:
- Clients of Our Customers: If you are a client of one of our customers, you may register for an account by selecting a username and password, and providing us with your name, email address, telephone number, and payment information in order to create and administer your user account. We use this information to enable our customers to provide you with health and wellness services through the Website.
- Customers: If you are a customer, or are an employee or authorized user of one of our customers, we will collect your name, business contact information (such as company name, address and email address) and payment information in order to create and administer your user account, and a password that you select. We use this information to enable our customers to provide their clients with the Services.
- Provision of Services: In the course of providing these Services, we may obtain information about our customers’ clients. While the nature of the personal information we process on behalf of our customers will be unique to their clients’ needs, it may generally include their client’s name, email address, mailing address, phone number, health card number, video and audio (to enable video consultations), payment information, insurance information, treatment information and notes, and other personal information or personal health information necessary to deliver the Services that our customers offer and deliver to their clients. We require our customers to ensure that they have obtained all authority to provide personal information to us in accordance with applicable privacy laws. We do not collect or use our customers’ client personal information for any purpose other than to provide Services on behalf of our customers.
- Secure Messaging: We may collect the content of any secure messages sent between our customers and their clients in order to provide the Services. We do not review or access such secure messages unless required to perform the Services on behalf of our clients, or as otherwise permitted or required by applicable law.
- Calendar Sync: Our customers and their authorized users may grant permissions to connect their external calendar with the calendar made available on the Services. In doing so, we may collect certain information about the authorized user’s external calendar, including the duration of events and free/busy status, so that we can assist in booking appointments in that external calendar.
- Payments: We use a third-party payment processor to process payments on behalf of our customers. If clients make a payment through the Website, card data or account information is provided to our payment processor. If you pay using a debit or credit card, Modern Health only stores the last four digits of your credit card number, the card type, the expiration number, your postal or zip code and the country.
- Support Services: We may collect certain information (such as name, email address, phone number and query) reasonable to assist us in providing customer support services by phone, email or within the platform.
- Use of the Services: We may monitor use of the Services by our customers’ clients or other authorized users in order to detect, investigate or prevent any actual or potential violation of our terms and conditions. We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the Services and to improve the Services.
- Storage: As a service provider, we may access or store personal information in the U.S., or other foreign jurisdictions in the course of providing Services to our clients, including healthcare professionals.
Information we collect and use through our Website and other interactions:
We may collect personal information when you:
- Purchase our Services
- Request a demo of our Services
- Sign-up to receive marketing communications
- Apply for a job with Modern Health
- Attend one of our talks or visit a Modern Health booth at an event
- Participate in our surveys or customer research
- Contact us with a comment, question or complaint
- Purchases: We use a third-party payment processor to process payments. Your payment card data or account information is provided to our payment processor. If you pay using a debit or credit card, Modern Health only stores the last four digits of your credit card number, the card type, the expiration number, your postal or zip code and the country.
- Request a Demo: When you request a demo, we may ask for your name, company name (if applicable), phone number, and work email address. We use this information to contact you and otherwise facilitate your demo or provide you with a quote.
- Marketing Communications: If you choose to sign-up for our marketing communications, we will collect certain information such as your name and work email address. If you no longer wish to receive these communications, you may unsubscribe any time by clicking the “unsubscribe” link at the bottom of the email or by contacting us at the contact information under “Contact Us” below. Please note that you may continue to receive certain transactional or account-related communications from us.
- Careers: If you apply for a job with Modern Health, you may provide us with certain personal information about yourself, such as information 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.
- Events: If you attend one of our talks or visit our booth at an event, we may collect business contact information such as your first and last name, work email address and phone number. We collect this information so that we can contact you about future events, promotions, offers and upgrades to our services.
- Surveys and Customer Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form. We use this information to help us understand our customers, to enhance our product and service offerings, and promotions and events.
- Contact Us: When you contact us with a comment, question or complaint through email, telephone, or live chat on our Website, you may be asked for information that identifies you, such as your name, company name (if applicable), work email address and a phone 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 and service offerings.
- Call Recording: We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.
SHARING OF PERSONAL INFORMATION
Modern Health does not sell, rent or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law.
- Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website, processing payments, providing advertising and marketing services, and other services as required. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions. For more information about the policies and procedures that we have regarding foreign service providers, please contact our Privacy Officer at firstname.lastname@example.org.
- Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
- Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Modern Health or as part of a corporate reorganization or other change in corporate control.
INFORMATION ABOUT OUR WEBSITE
Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
Cookies: Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. 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 our Website, you may not be able to take advantage of all of the Website features.
Analytics: This Website also uses web analytics services such as MixPanel to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms, and other engagement data) in order to evaluate and improve the user experience and the Website.
Tracer Tags & Web Beacons: The Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Websites. These tracer tags are used to help us optimize and tailor the Website for you and other future visitors to the Website.
We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferencpries, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.
As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the newsletter. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.
ACCESS TO INFORMATION
If we receive a request from an individual to access or update personal information we process on behalf of a particular customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.
If you submit personal information via our Website or otherwise provide us with your personal information, you may request access, update or correction of your personal information by submitting a written request to our Privacy Officer (see “Contact Us” below). We may request certain personal information for the purposes of verifying your identity.