The privacy of your personal information, including your personal health information is very important to us. This section describes how your personal information may be collected, used, disclosed, stored and your rights related to your personal information.
“Personal Information” includes your (i) personal health information (“PHI”), as defined in the Personal Health Information Protection Act (Ontario) (“PHIPA”), as applicable; (ii) personally identifiable information, which is information that can be used to identify you (“PII”); and (iii) non-personally identifiable information, which is information that cannot be used to identify you (“Non-PII”).
How to withdraw Consent
Assumption of Valid Consent
- COLLECTION OF PERSONAL INFORMATION
When we collect your Personal Information
We will collect your Personal Information in the following ways:
- When you create an Account via the Jane App;
- When you book an appointment via the Jane App;
- When you complete an intake form via the Jane App prior to your appointment;
- When you use the Platform.
Personal Health Information
If you create an account and book an appointment, Conceive, on behalf of NDs, will collect the following mandatory PHI about you:
- Name of family doctor;
- Fertility health history as set out in our intake forms via the Jane App;
- Name of ND, which is the name of the ND with whom you book your appointment with.
Personally Identifiable Information
If you create an account and book an appointment, Conceive will collect the following PII about you:
- Your first name and last name;
- Phone number;
- Your birth date;
- Your gender/sex;
- Emergency contact information;
- Payment transaction details.
Non-Personally Identifiable Information
Conceive will collect the following Non-PII about you:
- How you heard about Conceive. If you create an account and book an appointment, we will ask you to let us know how you heard about Conceive and out NDs.
- Website activity: We collect information about your use of the Platform, whether you create an Account or book an appointment, etc.
- Device information: We also collect information that your device provides us in connection with your use of the Platform, such as your desktop device type, system language, mobile carrier, browser type, IP address, etc.
- Web Beacons/Pixel Tags. These are invisible tags placed on certain pages of our Website. When you access our Website, pixel tags generate a notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit. We may use web beacons to recognize users and access traffic patterns.
- USE OF PERSONAL INFORMATION
How we use your Personal Health Information
Conceive uses your PHI:
- To receive appointment bookings and patient PII and PHI on behalf of NDs. Knowing this information beforehand will assist the ND during your appointment;
- To coordinate care on behalf of NDs.
- To act as the contact person on behalf of the NDs when it comes to access to or correcting your PHI;
- To provide you with a list of past and upcoming appointments;
- For any purpose as permitted by PHIPA in Conceive’s capacity as agent or representative of NDs;
- For any other purpose for which we have obtained your consent to the use of your PHI or PII, as applicable.
Other than as specified in this Section Conceive will not use your PHI for any other purpose without your written authorization, or unless otherwise permitted or required by law.
How we use your Personally Identifiable Information
We will use your PII to:
- To troubleshoot problems;
- Detect and protect us against error, fraud and other criminal activity;
- Provide you with system or administrative messages;
- Inform you of site updates and notices related to privacy or security;
- To send you information about your relationship or transactions with us;
- To contact you about the status of your appointment;
- To contact you to inquire, confirm or verify details relating to your appointment;
- On behalf of NDs, to contact family or a potential substitute decision maker if you are injured or unable to give consent, and
- Deliver you information that may be relevant to your interests (if you have opted in to receive such information).
Other than as specified in this Section Conceive will not use your PII for any other purpose without your written authorization, or unless otherwise permitted or required by law.
How we use your Non-Personally Identifiable Information
We use Non-PII for purposes such as measuring the number of users of various features of the Platform and making the Platform more useful to you. We may use your Non-PII for research purposes, for marketing and promotional purposes, and to develop new learning tools and solutions. We may analyze trends, administer the Platform, track your movement, and gather demographic information in an aggregate anonymized non-personally identifiable way. We may also perform internal research on our users demographics, interests, and behavior to better understand, protect and serve you and your community.
- DISCLOSING YOUR PERSONAL INFORMATION
Personal Health Information and Personal Identifying Information
Conceive discloses your PHI and PII:
- To NDs, since we are collecting information on behalf of the ND with whom you booked an appointment. The ND’s treatment of your PHI and PII is subject to the ND’s own policies and procedures;
- To any other health care professional within your circle of care, in accordance with PHIPA;
- To any other party as permitted by PHIPA, unless otherwise notified in writing by you;
- To any other party as permitted by PHIPA in Conceive’s capacity as agent or representative of NDs or other health care professionals, unless otherwise notified in writing by you;
- To any other party for which we have obtained your consent to the disclosure of your PHI or PII to such party, as applicable.
Other than as specified in this Conceive will not disclose your PHI for any other purpose without your written authorization, or unless otherwise permitted or required by law.
Third-Party Service Providers
Some portions of the Conceive Platform are reliant on Third-Party Service Providers, including but not limited to the Jane App. These Third-Party Service Providers may be supplied with or have access to your Personal Information solely for the purpose of providing the Platform and Platform Components to you on our behalf. Such Third-Party Service Providers are best-in-class and have appropriate confidentiality and security standards. The Jane App is PHIPA-compliant.
We cooperate with law enforcement inquiries and demands for information that are made under force of law. Therefore, we may disclose your Personal Information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), in accordance with the applicable law (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, in accordance with the applicable law (c) as otherwise required under any applicable law.
Sale of Business
We may also disclose Personal Information to the acquirer or its agents in the course of the sale of our business. If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.
- STORAGE AND RETENTION OF YOUR PERSONAL INFORMATION
Retention of Personal Information
Personal Information Stored Outside Canada
You acknowledge and understand that Conceive, through the use of Third-Party Service Providers, your Personal Information may be stored and processed outside of Canada.
- PROTECTING YOUR PERSONAL INFORMATION
Conceive strives to protect your Personal Information, including your PHI and PII. We use commercially reasonable administrative, technical, and physical measures to safeguard your PII and PHI in our possession against loss, theft and unauthorized use, disclosure or modification. We or our Third-Party Service Providers follow generally accepted industry standards to protect the information submitted to us or our Third-Party Service Providers, both during transmission and once we receive it.
Unfortunately, no data transmission over the internet and no storage of data, even in an encrypted form, can be guaranteed to be 100% secure. Therefore, while we and our Third-Party Service Providers strive to make all reasonable efforts to use commercially acceptable means to protect your PHI and PII, we and our Third-Party Service Providers cannot warrant the security of any information you transmit to us or our Third-Party Service Providers, and you acknowledge that there is always some risk when transmitting information to us through the Platform.
You acknowledge that Conceive not responsible for any breach of security or for any actions of the NDs.
Conceive will not permit its employees, contractors, representatives, directors, officers, etc. to have access to your PHI or PII unless they agree to be bound by a confidentiality agreement that includes the above restriction and have a need-to-know your with respect to your PHI or PII.
- REGARDING YOUR PERSONAL HEALTH INFORMATION
This section highlights some of your rights regarding your PHI.
Your contact person regarding your PHI is Dr. Jennifer Fitzgerald ND, and can be reached at firstname.lastname@example.org
Accessing your PHI
You have the right to obtain access to your PHI in either electronic or paper format. For instructions on how to get a copy of your PHI or patient chart, please email email@example.com. We reserve the right to charge you a reasonable cost-based fee, such as for photocopying or postage.
If you are requesting access to your PHI, we, of course, have to take reasonable steps to verify your identity before releasing your PHI to you.
Correcting your PHI
You have the right to make corrections to your PHI. For instructions on how to make corrections to your PHI or patient chart, please email firstname.lastname@example.org.
If you are requesting a correction to your PHI, we, of course, have to take reasonable steps to verify your identity before correcting your PHI for you.
Communicating in a Specific Way
When corresponding with Conceive about your PHI, you may ask us to communicate with you in a specific way. Please let us know your email or phone number at which you would like us to contact you.
Complaints to Conceive
You may make a complaint about our practices relating to your PHI by emailing email@example.com.
Complaint to the Commissioner
You may make complaint to the Commission regarding our practices relating to your PHI by contacting:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
- QUESTIONS OR CONCERNS
It is our goal to make our privacy practices easy to understand. If you have questions or concerns, please email our privacy officer at firstname.lastname@example.org.