EMRO DOCTORS INC. (the “Company”)
Privacy Policy

Date Last Modified: February 28, 2022

NAVIGATION

  1. Introduction
  2. Data Collection
  3. Data Management
  4. Data Usage
  5. List of Third-Party Processors
  1. INTRODUCTION TO PRIVACY POLICY

The Company is committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) about Company’s End-Users. To demonstrate Company’s commitment to protecting Your privacy, Company has developed this privacy policy (“Privacy Policy”), which describes how Company will collect, use, disclose and protect Your Personal Information through the virtual consulting telehealth platform for cancer care professionals and cancer patients and their families (the “Product”).

COMPLIANCE WITH LEGISLATION

In Canada, the Company is a service provider and may act as a service provider, information manager or electronic service provider under applicable privacy legislation, including Ontario’s Personal Health Information Protection Act (PHIPA) regulations (the “Applicable Laws”).

The Company may use and disclose personal information if it is required to do so by law, when it is permitted to do so consistent with HIPAA, or if the Company has a good faith belief that such action is necessary to conform to applicable laws or comply with any legal, regulatory or similar requirement or investigation, to protect or defend the rights or property of the Company or another user or to enforce the Company’s Terms of Use.

The Company is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the GDPR. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure ongoing compliance.

  • LICENSE AGREEMENT AND END USER LICENSE AGREEMENT

This Privacy Policy as well as the PLATFORM LICENSE AGREEMENT AND END USER LICENSE AGREEMENT (“License Agreement”) govern Your access and use of the Product, as owned and operated by the Company, a provincially incorporated company in the Province of Ontario (referred to in this Privacy Policy as the “Company”). Terms capitalized but not defined in this Privacy Policy have the meanings set out in the License Agreement. “You”, “Your” and “Yours” refers to you, the End-User, or if You are a company that is registering for user accounts on behalf of Your employees or contractors, the Client, as the case may be, and as defined in the License Agreement.

  • CONSENT AND AGREEMENT TO BE BOUND

(i) CONSENT PROVIDED BY CONTINUING USE. By accessing and/or using the Product You agree to all the terms and conditions of this Privacy Policy and the License Agreement which are incorporated here by reference. If You do not agree to all the terms and conditions of this Privacy Policy and the License Agreement, please do not use the Product.

(ii) YOU MAY ALSO HAVE PROVIDED CONSENT THROUGH DISTRIBUTION PLATFORMS. There are certain types of device data that the Product cannot access without Your consent. The various application marketplace platforms that Company serves the Product through will notify You the first time the Product requires permission to access certain types of data and will let You decide to consent to that request. You further agree to abide by all the terms in the Google Play Store or Apple App Store end user licensing agreement, or any other applicable application store (“Distribution Platforms”) agreement, so long as such agreement does not conflict with the terms herein or the License Agreement.

(iii) CHANGES WILL REQUIRE YOUR CONSENT. In the case of a material change to the Product as described in the amendment provision set out in the License Agreement, and in accordance with the amendment requirements set out therein, Company will provide written notice to inform You and will obtain consent from You for any new purposes not previously identified.

(iv) PROVIDING CHANGES TO YOUR CONSENT. Changes can be submitted by updating Your data in accordance with the user data update and verification provisions set out in the section of this Privacy Policy entitled 3. Data Management.

  • CONSENT TO COLLECTION AND ANALYSIS OF THE INFORMATION YOU PROVIDE TO US

(i) SPECIFIC CONSENT TO COLLECTION OF INFORMATION. By using the Product, You consent to the collection, use and disclosure of Your Personal Information by Company in the manner described in this Privacy Policy. You may always opt not to disclose certain Personal Information, but which may restrict access to certain features of the Product. For example, Your name and email address are necessary to complete the registration process. At any time after registration, You may opt out of most email communication from Company by clicking on the opt-out link at the bottom of Company’s emails, or by contacting Company at the contact details listed above. However, Company may still contact You for administrative purposes. Withdrawing consent will not apply to actions the Company has already taken based on Your prior consent.

(ii) CONSENT TO PROCESS THIRD PARTY DATA YOU SEND TO US IS YOUR RESPONSIBILITY. Any data sent to the Company for processing by You is considered to be third party data (“Third Party Data”). For all Third Party Data, consent required upon collection of third party data shall be obtained by You (“Third Party Data Consent”).

(iii) CONSENT TO RECEIVING COMMUNICATIONS FROM US: When You sign up for an account, You are opting in to receive emails from the Product for administrative or technical issues and You may occasionally receive the Company newsletters.

  1. COMMUNICATIONS IN THE EVENT OF BREACH: In the unlikely event that Company believes that the security of Your Personal Information in Company’s possession or control may have been compromised and creates a real risk of significant harm to You, or if Company believes that a notification is appropriate, Company may seek to notify You of that development, pursuant to both Company’s desire to keep You informed and Company’s legal requirement to do so. If a notification is appropriate, the Company may notify You by the email address registered to Your account. Additional details on a Data Breach can be found in the section of this Privacy Policy entitled 3. Data Management.
  • AMENDMENTS TO THIS PRIVACY POLICY AND VALIDATION TO CONFIRM COMPLIANCE WITH LAW. The Company may amend or change this Privacy Policy at its sole discretion at any time, and in accordance with the amendment provisions set out in the License Agreement. The use of the information Company collects at any given point is subject to the Privacy Policy in effect at the time of collection. If the Company makes any material changes the Company will notify You by email or by means of notice on the Product prior to the change becoming effective. Company will post the most current Privacy Policy on the Product, and Your use of the Product is subject to the most current Privacy Policy as posted on the Product at any time.

(i) Company’s PERIODIC REVIEW. Company will perform a periodic and timely review to ensure that Company’s Privacy Policy is compliant with Applicable Laws.

(ii) YOUR PERIODIC REVIEW. Company encourages You to periodically check Company’s Privacy Policy for the latest information on Company’s current policy.

  • DISCLAIMER

IF YOU CHOOSE TO ACCESS THE PRODUCT, YOU DO SO AT YOUR OWN RISK, AND ARE RESPONSIBLE FOR COMPLYING WITH ALL LOCAL LAWS, RULES AND REGULATIONS. WE MAY LIMIT THE AVAILABILITY OF THE PRODUCT, IN WHOLE OR IN PART, TO ANY PERSON, GEOGRAPHIC AREA AND/OR JURISDICTION WE CHOOSE, AT ANY TIME AND IN COMPANY’S SOLE DISCRETION. COMPANY’S PRIVACY POLICY DOES NOT COVER THE INFORMATION PRACTICES OF OTHER COMPANIES AND ORGANIZATIONS WHO ADVERTISE COMPANY’S SERVICES, AND WHO MAY USE COOKIES (DEFINED BELOW) AND OTHER TECHNOLOGIES TO SERVE AND OFFER RELEVANT ADVERTISEMENTS. SEE COMPLETE Section 9 (LIMITATION OF LIABILITY) AND Section 3, Schedule “E”(DISCLAIMERS), AND Schedule ‘C” (PROHIBITED USES) CONTAINED IN THE LICENSE AGREEMENT.

INFORMATION YOU SHARE WITH THIRD PARTIES. You should be aware that by providing third parties with Your name (User ID) and password, You may inadvertently enable unauthorized persons to review, modify or delete Your health records. If You provide a third party with Your user credentials, the Company cannot monitor the use of the Product.

  • MINORS

The Product is not intended for children under 18 years of age, and the Company does not knowingly collect or sell Personal Information from children under 18. If You are under 18, do not use or provide any information on the Product or through any of its features. However, if requested by Your healthcare provider, minor patients, parents or guardians may elect to establish a portal account, and, in doing so, expressly consent to the Company utilizing such information as set forth in this Privacy Policy and the License Agreement and executing the Parental Consent Form contained at Schedule “A” herein. If the Company learns they have collected or received Personal Information from a child under 18 without verification of parental consent, the Company will delete it. If You are the parent or guardian of a child under 18 years of age whom You believe might have provided us with their Personal Information, You may contact us using the below information to request that it be deleted.

  • INTERNATIONAL USERS

The Product is controlled and operated by the Company from Ontario, Canada and is not intended to subject the Company to the laws or jurisdiction of any state, country or territory other than that of Ontario, Canada. Any information You provide to the Company through use of the Product may be stored and processed, transferred between and accessed from either: (1) Ontario, Canada, or (2) other countries/jurisdiction that have similar privacy standards as those in Ontario, Canada, but which may not guarantee the same level of protection of personal data as the jurisdiction in which you reside. However, the Company will handle Your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.

  • MISCELLANEOUS

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for convenient reference only and are not to affect the interpretation of this Privacy Policy.

  • CONTACT INFORMATION

If You have questions or concerns regarding Company’s policy or practices, please contact Company’s privacy officer by email at info@emrodoctors.com or at the following address:

EMRO Doctors INC.,

569 Mohawk Road

Ancaster, Ontario, Canada, L9G 2X1

  • EFFECTIVE DATE.

This Privacy Policy is effective as of the Effective Data as defined in the License Agreement.

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