COLLECTION AND USE OF PERSONAL INFORMATION INCLUDING PHI
Eve provides a method for users to collect samples at home for the purposes of laboratory-based testing and facilitates the provision of lab results and access to appropriately licensed physicians or healthcare providers (“Providers”) and health administrative personnel (“HAPs”). These services (“Health Services”) as well as related healthcare and administrative support services (“Support Services”), are provided via telemedicine utilizing the Portal. For the purposes of providing Health Services and Support Services and purposes consistent with those purposes, Eve, Providers and HAPs collect and use personal information including PHI that is provided by clients during their use of the Portal and related telehealth consultations, or uploaded by clients to the Portal to complete and update online profiles and personal health histories maintained in secure client user accounts (“User Account”). Your PHI may include information or records regarding your medical or health history, health status and laboratory testing results, and other health related information. Your PHI may be contained in medical records, treatment and examination notes, and other health related records maintained on the Portal, or separately by Providers or HAPs. Neither Eve nor any Provider or HAP collects or uses personal information for any other purpose than providing and facilitating the providing of Health Services and Support Services, and uses consistent with those purposes, including but not limited to the following:
- Register:You do not have to register in order to browse our Website. However, in order to access and use the Portal, you will need to register to create a User Account and provide a username, email address and a password that you select. In order to receive Health Services or Support Services, you will also need to disclose additional information, including your contact information and your PHI to Eve, Providers and HAPs to enable them to provide those services. We use your personal information to identify who you are, communicate with you, and otherwise administer your use of the Portal to receive Health Services or Support Services.
- Purchase:If you choose to purchase and receive Health Services or Support Services, we or a third party service provider may collect your payment information such as your name, address, phone number, email address, billing address, and payment method information. This information is used to process your payment but will not be intentionally kept by us.
- Quality of Care:If you receive Health Services or Support Services, your PHI may be used to improve the quality of Health Services or Support Services provided by Providers and HAPs through the performance of quality reviews, training staff and students, for business management, quality improvement and similar activities. Your PHI may also similarly be used to create de-identified information such as aggregate statistics relating to the use of Health Services or Support Services.
- Contact Us:When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a telephone 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, service offerings, and our Portal.
DISCLOSURE OF PERSONAL INFORMATION
We may transfer or disclose personal information as follows:
- Circle of Care: If you receive Health Services or Support Services your personal information including your PHI may be disclosed to and among Providers and HAPs for the purpose of providing or assisting in the provision of Health Services or Support Services to you. Your personal information including your PHI to third parties such as other health professionals, specialists, consultants or pharmacists, pharmacies and laboratories for the purpose of providing or assisting in the provision of Health Services or Support Services to you.
- Public Health Reporting: In the case that your PHI is required to be shared with the relevant public health authorities by law, such as the reporting of positive communicable disease diagnoses, your information will be disclosed automatically in the manner and by methods normally used for such purposes by our laboratory partner.
- Service Provider Arrangements: In connection with our Portal, Health Services or Support Services, we may disclose (or otherwise make available) personal information to third parties who provide Health Services or Support Services on our behalf. For example, we may use service providers to process payments, host our website and store information on our behalf. Personal information may be maintained and processed by third party service providers in Canada and may be accessed by the courts, law enforcement and national security authorities as required under the laws of those jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.
- Sale of Business: Eve may transfer personal information as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Eve or as part of a corporate reorganization or other change in corporate control.
- Legal: Eve and our affiliates and service providers may disclose personal information to third parties as required or permitted by applicable law. Where a disclosure of our clients’ information is required by applicable law, we will promptly notify our client prior to complying with such requirements (to the extent we are not prohibited from doing so).
We may also disclose personal information 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.
INFORMATION ABOUT OUR PORTAL
As you use the Portal, certain information may be passively collected by Cookies, navigational data like Uniform Resource Locators (URLs) and third party tracking services, including:
- Activity Information: We may keep track of some of the actions you take on the Portal in order to enable delivery of services on the Portal, or to maintain records required by law or for the delivery of care.
- Access Device and Browser Information: When you access the Portal from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times (collectively, “Anonymous Information”).
- Mobile Services: We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use.
SECURITY OF PERSONAL INFORMATION AND PERSONAL HEALTH INFORMATION (PHI)
We understand that data security is a critical issue for our clients and we are committed to safeguarding the personal information in our custody and under our control.
Eve has implemented an information security program that includes information encryption, security controls, and audits of information access. We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.
Our privacy practices are intended to comply with applicable privacy laws, including without limitation, the Personal Health Information Protection Act (Ontario) (“PHIPA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We will maintain the privacy of your personal information including you PHI as required by applicable privacy laws, including without limitation, PHIPA and PIPEDA and the regulations under those Acts.
ACCESS TO PERSONAL INFORMATION
If we receive a request from an individual to access or update personal information we have collected on behalf of a particular client, we will direct that individual to the relevant client. We will assist our clients wherever possible in responding to individual access requests.
If you submit personal information via our Portal or otherwise provide us with your personal information, you may request access, updating or correction of your personal information by submitting a request to email@example.com. We may request certain personal information for the purposes of verifying your identity.
We may use de-identified information created by us from your personal information without restriction.