SEAMLESS PRIVACY POLICY

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 “Service”). By accepting our privacy policy during registration for the Service, or by visiting and/or using the Service, 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 service.

INTRODUCTION

The Service is a healthcare platform that allows you to track your symptoms and health statuses, complete health questionnaires, complete patient self-management tasks and access timely patient education.

 

The information that you generate on the Service may be provided to your health care providers, depending on how they choose to use the Service.

HOW WE COLLECT INFORMATION

Any information that you provide to the Service is safeguarded in accordance with applicable laws. The following describes the information collected by the Service:

Personal Information

When you register for the Service, we may collect Personal Information (e.g. telephone number, email, etc.) in order to create an account and provide you with the Service.

Health Information

We collect the Health Information you provide to the Service, including but not limited to your surgeon, your surgery date, your symptoms, health status, responses to health questionnaires and completion of patient self-management tasks.

Usability Information

We collect Usability Information from your activity on the Service for the purpose of operating and improving the Service, including but not limited to, the buttons you tap, the content you view, the features you use, how long you spend on each page of the Service, the date and time of when you use the Service and other information about how you interact with the Service.

By virtue of using the Service, you are consenting for your Personal Information, Health Information and Usability Information to be collected and used by Seamless in the manner outlined below.

HOW WE USE INFORMATION

We may use the Personal Information, Health Information and Usability Information that we collect for any purpose related to your access and use of the Service and our maintenance and development of the Service, including but not limited to:

·         operate, maintain, manage and administer the Service, including processing registrations, and providing customer support;

·         respond to questions and communications, which we retain in the ordinary course of business;

·         safeguard and protect our Service, the information they safeguard, the rights of third parties and in response to legal process

·         facilitate communication between you and us, your health care team, physician, or hospital, and any other individuals or entities in connection with your use of the Service;

·         improve the Service and monitor our services, including without limitation, analysing the performance and effectiveness of the Service, and identifying your needs and preferences.

HOW WE DISCLOSE INFORMATION

By virtue of using the Service, 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 Service, including, without limitation, to:

·         your caregivers who you consent to be involved in your care;

·         your treating physician, hospital, other members of your health care team, or pilot or research study team, which may include providing the data to your health care provider’s electronic medical record systems;

·         third party service providers, business partners, or other trusted individuals and entities that may assist us in providing you with access to, and use of, the Service, who will be under an obligation of confidence in respect to your Personal Information, Health Information and Usability Information;

·         third parties in connection with a sale or transfer of some or all of the shares or assets of Seamless or in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, who will be under an obligation of confidence in respect to your Personal Information, Health Information and Usability Information; and

·         any individual or entity if required by applicable law or to cooperate with by law enforcement if permitted by applicable privacy laws.

HOW WE USE AGGREGATED INFORMATION

We may use, and disclose (to a third party) aggregated Health Information and Usability Information from the Service, such that it does not personally identify you (“Aggregated Information”). We reserve the right to collect, use, disclose, distribute and exploit any and all Aggregated Information to the extent that such data is not linked to any particular individual.

Accessing and Updating Your Information

If you discover unwanted or incorrect Health Information associated with your Seamless account, you should contact 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 Services.  Please understand that removal of unwanted Health Information, or the entry of inaccurate Health Information may mean we may not be able to provide accurate or timely Services.

SECURITY

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, secure socket layer (SSL) encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorized access to your Personal Information and Health 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.

Your Personal Information and Health Information will be processed and stored at a secure location in Canada.

SEAMLESS’ PERSONNEL

Seamless will ensure that its personnel are aware of and agree to be bound by the privacy laws applicable to Seamless’ business.

THIRD PARTY PRIVACY POLICIES

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 personal information (e.g. name) you 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.

UPDATING THIS PRIVACY POLICY

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 Service, 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.

CHILDREN

The Platform is not intended for children under the age of 16, 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 16. 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 Service 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 Service 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 Service.

CONTACTING SEAMLESS

If you: (a) have any questions, comments, or concerns about this Privacy Policy; (b) wish to review your Personal Information and Health Information; or (c) wish to withdraw your consent in respect of the collection, use, or disclosure of your Personal Information and Health Information, please contact our privacy and compliance officer at: privacy@seamless.md.

If you withdraw your consent, you will no longer be able to access or use the Service.  We may continue to use the Personal Information and Health Information 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. 

I HAVE READ, UNDERSTAND AND CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF MY INFORMATION PURSUANT TO THE TERMS OF THIS PRIVACY POLICY AND BY CLICKING ON THE “I ACCEPT” BUTTON BELOW, I AGREE TO AND SHALL BE BOUND BY THIS PRIVACY POLICY.

Up to date as of October 15, 2014

 

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