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Your privacy is very important to us. This Privacy Policy is both an agreement hereby entered into by you and Seamless Mobile Health, Inc. (“Seamless”, “we”, “us”, “our” or other similar terms), and also a policy that describes how our services handle and secure the information we collect through the Seamless Mobile Health platform (the “Platform”, as defined in the End User License and Services Agreement). By accepting our privacy policy during registration for the Platform, or by visiting and/or using the Platform, you expressly consent to our collection, use and disclosure of your information as set out in this Privacy Policy. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE PLATFORM.
The Platform includes healthcare software and services that allow you to complete health questionnaires, track your self-management tasks and access patient education.
The information that you generate on the Platform may be provided to your health care providers, depending on how they choose to use the Platform.
This policy aligns with recommendations from the Health Insurance Portability and Accountability Act, the Personal Health Information Protection Act of Ontario, and the Personal Information Protection and Electronic Documents Act of Canada.
HOW WE COLLECT INFORMATION
Any information that you provide to the Platform is safeguarded in accordance with applicable laws. The following describes the information collected by the Platform:
Personal Information
We collect Personal Information, which may include but is not limited to your name, telephone number, and email address, in order to create an account and provide you with the Platform. Depending on how your healthcare provider configures the Platform, this may change the type of Personal Information we collect. Depending on how you use the Platform, you may also choose to provide similar Personal Information about caregivers in order for them to also access the Platform.
Health Information
We collect the Health Information you provide to the Platform, including but not limited to, your provider, your surgery date and the information you record using our Platform, including but not limited to your responses to health questionnaires and your completion of tasks.
Usability Information
We collect Usability Information from your activity on the Platform for the purpose of operating and improving the Platform, including but not limited to, the buttons you click, the content you view, the features you use, how long you spend on each page of the Platform, the date and time of when you use the Platform and other information about how you interact with the Platform.
By virtue of using the Platform, you are consenting for your Personal Information, Health Information and Usability Information to be collected and used by Seamless in the manner outlined below.
We seek to limit our exposure to the Personal Information we collect. However, we may use the Personal Information, Health Information and Usability Information we collect for any purpose related to your access and use of the Platform, and our maintenance and development of the Platform, including but not limited to:
By virtue of using the Platform, you grant us the permission to disclose your Personal Information, Health Information and Usability Information to any individual or entity that may assist us in providing you with access to and the use of the Platform, including, without limitation, to:
To render the services described in the End User License and Services Agreement, your Personal Information may be transferred, accessed and/or processed by us, our affiliates and other third party service providers in Canada or the United States to the extent permitted by the applicable privacy laws. Your Personal Information may be subject to the laws of the jurisdiction to which the Personal Information was transferred, accessed and/or processed; and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in that jurisdiction in accordance with the laws of that jurisdiction.
We may use, and disclose (to a third party) aggregated and de-identified Health Information and Usability Information from the Platform, such that it is not associated with any individual account that personally identifies you (“Aggregated Information”). We reserve the right to collect, use, disclose, distribute and otherwise exploit any and all Aggregated Information to the extent that such data is not linked to any particular individual.
If you discover unwanted or incorrect Personal Information and Health Information associated with your Seamless account, you should contact your healthcare provider who will then communicate with Seamless to potentially remove or correct such information. We will make reasonable efforts to promptly remove or correct such information so long as it is information within our control and generated as a result of the Platform. Please understand that removal of unwanted Personal Information and Health Information, or the entry of inaccurate Personal Information and Health Information may mean we may not be able to provide accurate or timely Platform. If you wish to receive access to your data, please contact support@seamless.md. Your personal information will be uploaded to a secure file repository for you to access. You will receive this information within 10 business days of your request. SeamlessMD may refuse this request if we are unable to verify your identity or would expose the private information of other persons through your request. You will only receive information stored by SeamlessMD in reference to your activities on the platform or information we have collected on your behalf.
We have implemented security measures to protect against unauthorized use, misuse, or modifications to information stored on our servers, your computer, or your mobile device. We use software, encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorized access to your information.
Seamless has in place effective administrative, technological and physical safeguards to stop theft, loss and unauthorized access, copying, modification, use, disclosure or disposal of information. These safeguards are consistent with industry practice. SeamlessMD has achieved SOC2 Type 2 certification, an independent audit which verifies our internal controls and processes. This includes geographically isolated private networks, encryption of data in transit and at rest, log monitoring, and other leading security measures.
Seamless will ensure that its personnel are aware of and agree to be bound by the privacy laws applicable to Seamless’ business.
We do not have control over the privacy policies and practices of third-party websites. There may be links to other websites and pages provided by third-parties on our Website and/or the Platform. Any information you choose to provide to a third-party is provided directly to that third-party and is subject to that third-party’s privacy policy. We are not responsible for, nor do we endorse, the privacy policy or privacy practices of other web sites and third-parties.
We may occasionally update this Privacy Policy with or without notice to you. We encourage you to review this Privacy Policy from time to time to stay informed about how we are protecting the information that we collect. If you continue to access or use our Platform, or any other related products and services after we have updated the Privacy Policy, you accept and agree to such changes in the Privacy Policy.
The Platform is not intended for children under the age of 13, without the consent and supervision of the parent or legal guardian. We are in compliance with the requirements of COPPA (the Children’s Online Privacy Protection Act) and do not knowingly collect information from anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us information without their consent, please contact us. Access to and use of the Platform for minors must be through the parent or legal guardian’s account or with the parent or legal guardian’s express permission. If we become aware that a user of the Platform is under the age of 13 and has provided us with information without parental consent, we will delete such information and suspend access to the Platform.
If you: (a) have any questions, comments, or concerns about this Privacy Policy; (b) wish to review or make changes to your Personal Information or Health Information; or (c) wish to withdraw your consent in respect of the collection, use, or disclosure of your Personal Information or Health Information, please contact our privacy and compliance officer at: privacy@seamless.md. Ontario residents can also contact the Information and Privacy Commissioner of Ontario to escalate concerns.
If you withdraw your consent, you will no longer be able to access or use the Platform. We may continue to use the information you previously provided to us to the extent required for us to enforce any contractual obligations that you may have to us or to the extent required by us to fulfill any of our contractual obligations.
Up to date as of July 4th, 2023.
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