VirtualCare Privacy Policy

Last Updated: September 4, 2021

Mednow Virtual Care is a service that allows individuals to receive virtual medical consultation that is convenient and easy to use.

 This Privacy Policy describes how Mednow Virtual Care, a subsidiary of Mednow Inc. (“MVC”, “we”, “us”, or “our”) protects your privacy when we collect, use, store and share your personal information and personal health information while you use our services via our website (https://mednow.inputhealth.com/), when we provide you with virtual care services, and when you otherwise interact with us (“Services”). 

“Personal Information” is information about an identifiable individual or information that can be used to identify an individual. Personal Information includes Personal Health Information. For the purposes of this Privacy Policy, when we refer to “Personal Information”, we also refer to Personal Health Information. 

“Personal Health Information” includes information related to an individual’s physical or mental health, health history, healthcare received by an individual, healthcare provider, medical records, payments or eligibility for healthcare, health card number, or other healthcare identification numbers and other information regulated under provincial health privacy legislation. 

“Healthcare Practitioner” is any practitioner or assistant provisioning healthcare services, including a physician, nurse practitioners, pharmacists, nurses, health therapists, and psychologists.

ACCOUNTABILITY

MVC is directly accountable to you for the treatment and protection of your Personal Information, including your medical records. The Healthcare Practitioners that you interact with as part of the Services are independent contractors to MVC and are required to handle your Personal Information in accordance with this Privacy Policy, applicable privacy laws and the terms of our agreements with them.  

CONSENT

We collect, use, store and disclose your Personal Information with your explicit or implied consent, as applicable laws require, unless there is a legal exemption for us to do so. 

When you request healthcare from us, we assume we have your permission or implied consent to collect, use and share your Personal Health Information among the MVC healthcare providers, including doctors, nurse practitioners, nurses, pharmacists nurses, and staff who are involved in providing healthcare to you for the purposes of providing you with medical care.  We may also give your Personal Health Information to healthcare providers outside of MVC for the purposes of facilitating your healthcare, assuming we have your implied or explicit consent or it is reasonable to believe you want us to do so and subject to certain limitations. You should advise MVC if you do not want us to use, share or give out some or all of your Personal Health Information in connection with your healthcare needs. 

There are certain activities for which we may not need consent to use or disclose your Personal Health Information. These are activities that are permitted or required by law and vary depending on the provinces in which you are located. For example, if you are located in Ontario, we do not need consent to use or share Personal Health Information to:

• plan, deliver, evaluate or monitor our programs and services; 
• process payments;
• engage in quality improvement, error management, and risk management activities;
• educate our team members and others;
• modify the Personal Health Information to conceal the identity of the patient; or
• comply with mandatory reporting obligations.

When you create an account for virtual healthcare consultation, we ask you to confirm that you have read and understand that your Personal Information will be treated in accordance with our Privacy Policy and we request your express consent to provide you with healthcare services through audio and video virtual care. 

In addition, prior to commencing any virtual care consultation, including consultations via phone calls, the Healthcare Practitioner will seek your explicit consent to start the consultation. For virtual consultations, the audio and video settings on your device will be turned off by default. By enabling your audio and/or video, you are consenting to engaging in audio and/or video communications with the Healthcare Practitioner. Consultations will not be recorded regardless of whether they are on video, audio or phone call.

Withdrawal of Consent

You may withdraw your consent at any time subject to legal and contractual restrictions by contacting us as set out in Your Choices. The withdrawal of consent cannot be retroactive.  If you withdraw your consent or refuse to provide us with necessary information, we may not be able to provide you with certain Services and certain Service functionalities may be limited.

COLLECTION OF PERSONAL INFORMATION

We collect Personal Information to assist us in establishing our relationship, providing our Services to you, communicating with you, and maintaining and improving our Services.

Information You Provide To Us: We collect Personal Information directly from you or someone who is authorized to provide Personal Information to us on your behalf, such as a parent, legal guardian or caregiver.

Information you may provide to us when you register for an account or when you engage in a healthcare consultation includes your name, address, date of birth, medical history, medical conditions, medical practitioners, images (only at the request of a healthcare practitioner), health card number or other healthcare identification numbers, and health insurance information. 

In order to make the virtual healthcare consultation efficient, we ask you to complete an optional questionnaire prior to your consultation. Filling out the questionnaire in advance will inform the virtual healthcare practitioner of your current condition and health history. Should you choose not to fill out the questionnaire, the virtual healthcare practitioner may ask you those questions during your consultation. 

Information We Collect From Third-Parties: We may collect your Personal Health Information, such as your medical records, from your treating Healthcare Practitioner or medical facility, in order to be better informed of your health history.  

Information We Automatically Collect: Like most websites, we collect information about your visit, use, and interaction with our website. We may send your browser one or more cookies to improve the quality of our Services by storing user preferences and following user trends. 

A “cookie” is a file containing an identifier (a string of letters and numbers) that is placed on your computer or mobile device when you visit a website, which relays information to us about how you use our website. Cookies may collect your Internet Protocol (IP) address. 

We may use cookies for a variety of purposes including collecting usage information (such as your IP address, page requests, browser type, operating system and average time spent on our website) to provide us an understanding about how our Services are being used and how we can improve our Services. We may also be able to track activity and click-through behaviour to understand your preferences and provide a personalized experience. 

Most browsers are set up to accept cookies, however, you can reset your browser to reject cookies. If you choose to disable cookies, some of the functionalities on our website may be affected. Be aware that clearing your browser history will clear all of the cookies for all the sites you have visited, even those you have opted-in to. You may also lose saved login information and preferences for other websites.

USE OF PERSONAL INFORMATION

We may use your Personal Information for the following purposes:

• Provide you with our Services. We may need certain Personal Information to set up your account, deliver virtual healthcare consultations, complete and update your medical records, and coordinate and administer our Services.
• Validate your identity. We will use the information you provide to us, such as your health card number, photo identification, insurance information, date of birth, or phone number, to validate your identity prior to the commencement of a consultation. 
• Process payments. To process payments for the Services you received through your provincial health card number if the treatment is covered by a provincial health care insurance plan. Otherwise, we will either issue payment directly with your insurance company or directly with you. Payment processing is outsourced to reputable third party service providers who securely process your credit card-related information in accordance with Payment Card Industry Data Security Standard.
• Communicate with you. To communicate with you about the Services you requested, such as sending you an email, SMS text message, or both, which confirms or reminds you of your appointment, sends you a questionnaire, or sends a secure link to your appointment or responding to your inquiries and requests. Please review Your Choices to change your preference on how we communicate with you.
• Provide technical support. To resolve technical issues our patients may have. We will not provide our support team with access to Personal Information if those issues can be resolved without accessing or viewing Personal Information.
• Improve our Services. To develop and improve our Services by measuring and understanding the effectiveness of the content on our website, and your use of our Services. 
• Security and safety purposes. To keep our website, Services, and patients safe and secure.
• Pursuant to applicable law. To comply with our legal or regulatory obligations, including protecting the rights, property and safety of our users as well as to enforce our Terms of Use and other agreements.

We may de-identify and/or aggregate your Personal Information, including your Personal Health Information in your medical records, in such a way that it cannot be used alone or in combination with other information to identify you. We use this information for research purposes, or to learn about how we can improve the quality of our Services. We may share the de-identified and aggregated information as described under Sharing of Personal Information. 

We may also use your Personal Information for purposes that we inform you of at the time of collecting your information. If we intend to use or disclose your Personal Information for a new purpose, we will ask you for your consent first, unless we are otherwise permitted or required by law or court order.

SHARING PERSONAL INFORMATION

There are certain circumstances in which we may disclose, transfer or share your Personal Information with certain third parties. We limit who we share your Personal Information with and how much information we share. We may share your Personal Information to the following parties:

• Healthcare Practitioners, such as your family physician, providers, affiliated staff, pharmacies and laboratories for the purpose of provisioning or assisting in providing healthcare to you. 
• Health organizations (such as the Ministry of Health) or insurance companies as required under laws and regulations and as necessary to submit claims for payment. 
• Employers if you are accessing our Services via an employee group plan. Any information we may disclose to your employer is in de-identified and aggregated form for the purposes of disclosing how many employees are using our Services and certain trends. We will not disclose your identity or Personal Information. 
• Service providers who assist us in provisioning our Services, where such sharing is reasonably necessary to provide you with the requested Services, such as to operate our virtual platform and host our website, send communications, store information or process payments. Our service providers are only provided with the information they require to provide the services, and are not authorized to use it for any other purpose. 
• Our affiliates and subsidiaries for the purposes of assisting us in planning, developing or improving our products or Services, however, we will de-identify and aggregate your information prior to sharing information about you so that your identity and Personal Information is not shared. 
• Any other party if we are required or authorized to do so by applicable law. For example, we may be required to disclose your Personal Information in the event of an emergency that threatens your life, health or security, or those of others. We may also be required to share Personal Information with law enforcement, courts, or government agencies with a court order.

We do not sell your Personal Information to any third party.

ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION

Correction

We rely on you to provide us with accurate, complete and up-to-date information. If you need to update your Personal Information, you may do so by correcting the information in your Mednow Virtual Care account. If you cannot update your information on your account or require assistance, you may email us at virtual-care-privacy@mednow.ca with a written request to correct your Personal Information. If you believe the Personal Information in our records is inaccurate or incomplete, you may request in writing that we correct the record. You must be able to demonstrate the inaccuracy or incompleteness of the record and provide us with the information necessary to correct it.

Access

You may also access your Personal Information by logging into your Mednow Virtual Care account. If the information you are looking for is not in your account, such as your medical records, please contact us at virtual-care-privacy@mednow.ca with a written request for a copy of your Personal Information.  

Note that we may not be able to provide access to all Personal Health Information we hold about you. There are exceptions to the right of access requirement prescribed by law, such as where there is a risk of serious harm to a person or if the information is subject to legal privilege.

We will respond to your request for access or correction within reasonable timelines and costs, in accordance with applicable legislation.  

When we receive a written request for access, correction or withdrawal of consent, we will take reasonable steps to verify your identity before granting you access or correcting your Personal Information. There may be limited exceptions where your request may be denied, such as if we cannot verify your identity or in accordance with applicable law, in which case we will advise you of our reasoning for declining your request.

YOUR CHOICES

You may withdraw your consent at any time by informing us at virtual-care-privacy@mednow.ca. 

You can request to close your account or delete your information by sending us an email to virtual-care-privacy@mednow.ca. Upon your written request and verification of your identity, we will close your account or delete your Personal Information, however we may be required to retain certain Personal Information in accordance with our legal or regulatory obligations. Please see Retention and Storage of Your Personal Information for more information. 

You may change your communication preference by changing the settings in your account or notifying us at virtual-care-privacy@mednow.ca.

 

SECURITY

We understand the importance of protecting your Personal Information and are committed to taking all reasonable steps to ensure the security and protection of your Personal Information. We have taken proactive steps to implement administrative, physical and technical safeguards to protect your Personal Information against unauthorized access, use, loss, modification and disclosure of your Personal Information. 

We protect Personal Information using a range of measures, consistent with industry practices for the protection of similar information. These safeguards include the following methods of protection:

• Physical measures, such as locked filing cabinets and restricted access to offices and facilities.
• Organizational measures, such as employee security clearances, security and privacy training for staff, and restricted, “need-to-know” access.
• Technological measures, such as the use of passwords, encryption, and intrusion detection software.

All our virtual healthcare consultations are conducted in real-time video or audio calls. You will be provided with a secure link with a passcode to your preferred device. In addition to your passcode, you must also enter your date of birth to validate your identity. The virtual Healthcare Practitioner will take extra measures to validate your identity, such as confirming your health card number or phone number, and seek your explicit consent to start the consultation. You will always have the option to activate your microphone and/or camera which are off by default. The audio and video calls conducted through our Services are confidential and end-to-end encrypted. 

The security of your information is important to us. While we strive to protect your information, it is important to note that no computer system or online communication is perfectly secure. As such we cannot guarantee that communications between you and any of our Services, or information stored on our servers will be free from unauthorized access. Your use of the Services demonstrates your assumption of this risk. We encourage you to take appropriate steps to protect your information, including not sharing with us more information than is necessary and not allowing other individuals to use your account.

THIRD-PARTY LINKS

Our website may contain links to other websites and services that we do not own or operate. By clicking on those links, you will leave our website and be redirected to third-party websites. We are not responsible for the privacy practices of those third-parties and we encourage you to read their privacy policies to understand how they protect your Personal Information.

RETENTION AND STORAGE OF YOUR PERSONAL INFORMATION

We retain Personal Information only for as long as is necessary to fulfill the purpose for which we originally obtained your information. 

Your Personal Health Information, such as your medical records, will be retained in accordance with our legal and regulatory obligations in the applicable province. 

All Personal Information is stored within Canada. There may be limited circumstances in which our service providers may access your Personal Information outside of Canada, such as in the United States.

UPDATES TO THIS PRIVACY POLICY

From time to time we may update this Privacy Policy based on new or changed Services. Please note the “Last Updated” date at the top of this Privacy Policy. Updates to this Privacy Policy become effective when posted on our website. Your continued use of our Services after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of the Privacy Policy.

QUESTIONS OR CONCERNS

If you have any questions or concerns about your privacy or our Personal Information handling practices, please contact us. Please also contact us if you need to report any suspicious activity or unauthorized access to your Personal Information. 

Contact Information:
Privacy Officer
Mednow Virtual Care Inc. 
2310 St. Laurent Blvd, Unit 320
Ottawa, Ontario
K1G 5H9

or

virtual-care-privacy@mednow.ca 

You may also contact the Privacy Commissioner located in the province in which you reside with any concerns.