Posted November 23, 2016
Effective January 1, 2017
Some of our users – such as healthcare providers – are subject to laws and regulations governing the use and disclosure of health information they create or receive, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time, together with the regulations adopted thereunder (“HIPAA”). When we store, process or transmit “individually identifiable health information” (as defined by HIPAA) on behalf of a healthcare provider who has entered into a Healthcare Provider User Agreement, we do so as its “business associate” (as also defined by HIPAA). Under this agreement, we cannot use or disclose individually identifiable health information in a way that the provider itself may not. We are also required to, among other things, apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of the individually identifiable health information we store and process on behalf of such providers. For the purpose of this Policy, the term “healthcare provider” means any user who is a “health care provider” (as defined by HIPAA) or any user who is a member of such health care provider’s “workforce” (as also defined by HIPAA).
Information Collected by Our Services
Information You Submit or We Collect on Your Behalf:
We collect information from you when you:
- Enter information on our Services, such as when you register for our Services, use our Services, or complete a form;
- Upload a document, image, or other data file on our Services;
- Contact us; or
- Make a customer service request.
We also collect information on your behalf when you authorize us to retrieve and import information from another user or other third party within our Service or as set out in the User Agreement.
Information we collect about you may include your name, address, telephone number, email address, or the information you enter on or upload to our Services.
Automatically Collected Information:
We and our partners automatically gather information whenever you visit, log in, or otherwise interact with our Services, including when you receive emails delivered via our Services. We and our partners use the technologies described below (and similar technologies that may not be expressly described) to gather this information to enhance and operate our Services in a number of ways, such as to:
- Save user preferences and information;
- Preserve session settings and activity;
- Authenticate users;
- Enable support and security features;
- Tailor the delivery of informational messages, media, advertising and other content; and
- Analyze the performance and use of our Services and its various features and content.
Even if you do not register with us or submit any information on our Services, our Services will automatically receive information about, and the software running on, the computer, mobile phone, or tablet (each, a “Device”) you use to interact with our Services.
Device Information: When you interact with our Services, we collect information about your Device such as the URL of services your Device is requesting and the referring web pages, your IP address, Device type, operating system, browser type, application identifier, and, under certain circumstances, the location information your Device sends to us.
Cookies & Similar Technologies: We and our partners collect information about you and your Devices through cookies, web beacons, and similar technologies. A “cookie” is a small data file sent from a website and stored on your Device to identify your Device in the future and allow for an enhanced personalized user experience based on your previous activity on the website. A “session cookie” disappears after you close your web browser, or may expire after a fixed period of time. A “persistent cookie” remains after you close your web browser and may be accessed every time you use our Services. We and our partners may use both session and persistent cookies on our Services. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may not be able to use certain features of our Services.
Some of our partners deploy these technologies directly on our Services. These third parties may collect information over time about your use of our Services, as well as your online activities across other websites or online services. Some third parties may allow you to opt-out of targeted advertising based on this information. You can find more information about these opt-outs from the Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA).
Information from Other Sources:
We may receive (or proactively gather) information about you from other sources and add it to information we otherwise have about you for any purpose described in this Policy. This may include situations where a third party seeks to communicate with you through the Services or establish an “Integration” (as more fully described below under the heading, Third Party Integrations).
How We Use Information
We may use the information we collect for the following purposes:
- Operating our Services and developing new functionality and features;
- Responding to questions and communications, or obtaining your feedback about our Services;
- Administering and logging your participation in educational and informational programs, including webinars and other classes, and any product or support matters that may arise from such programs;
- Providing you with more relevant content, including clinical support tools, assessments or medical-related information or services, patient support programs, advertising, or other programs appearing on our Services or third-party services;
- Analyzing usage trends and patterns and measuring the effectiveness of content, programs, advertising or the features or functionality of the Services, including emails that may be sent by us to you;
- Preparing reports for any of the purposes described in this Policy, including for current or future sponsors, advertisers or other partners to show utilization or trends about the use of our Services. Such reports may include demographic or other general user information, but will not include personally identifiable information unless the recipient has agreed to confidentiality obligations;
- Safeguarding and protecting our Services, the information we collect, and the rights of us, our users or third parties, and in response to legal process;
- Any other purpose described in this Policy or your User Agreement; or
- When we otherwise have your permission.
How our Services Allow Users to Share Information:
Surveys, Feedback, Informational Programs:
From time to time you may receive survey requests through emails or displays within our Services that request feedback on a variety of topics. These programs may be sponsored or funded by third parties, and may include branded or unbranded content about medical conditions, treatments and products, or safety and regulatory information resources. If you choose to engage with or use one of these requests, you may be asked to provide information that may be used to supplement information that you submitted to our Services. This information may be shared with the sponsor of the program.
Our Services allow users to store personally identifiable and health information (“Records”), including Records that identify other individuals, including other users. Certain of our Services permit users to share all or portions of these Records at their discretion.
You should be aware that this Policy covers only the information you submit through our Services. If you contact or exchange information with another user in person or through a means other than our Services, such activity is not covered by this Policy. Because our Services enable users to share information you share with them, you should take care in selecting with whom you share your Records and other information. Although our Services process such transmissions, we are not responsible for the actions of persons with whom you share your Records and other information.
Emails and Other Communications:
Our Services allow users to communicate with others through Service-branded emails, and other electronic communication channels. We may communicate administrative or Service-related announcements through email or other communications within our Services. These communications may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure. Please note that you may not be able to opt out of receiving certain messages from us.
Emails and other communications from individuals who are not users of our Services, or that we send in connection with business agreements or subject matter other than the User Agreements, are not covered by this Policy. If, for example, you contact us regarding a job opening, that communication to us is not covered by this Policy even though that job opening may have been posted on our Services.
Third Party Integrations
Sharing of Information
We may share information you submit to us with third parties under the following circumstances:
- When you choose to share such information through our Services;
- When your account has been issued by an account administrator with administrative rights over your account, your account administrator will have access to your account information;
- With third party service providers that have agreed to confidentiality obligations, which may include, as applicable, business associate contract obligations;
- If you are a healthcare provider who has entered into a Healthcare Provider User Agreement, we may share information with the third parties who are subject to confidentiality obligations that you have elected to establish Integrations with, or who seek to establish Integrations with you, and to facilitate, maintain and monitor the utilization of such Integrations;
- If you are a healthcare provider who has entered into a Healthcare Provider User Agreement, we may also share information with third parties who are subject to confidentiality obligations who are funding or administering certain branded or unbranded content about medical conditions, treatments and products, or safety and regulatory information resources, such as clinical decision support tools, patient savings offers, discount programs, medication adherence programs, and other similar programs. The purposes of such sharing may include administration, recordkeeping or compliance obligations, and assessing the effectiveness or utilization of any such program.
- If you receive any honoraria or payment in connection with a survey or request for feedback, your information may be shared with the funding source or sponsor of such survey or program;
- To protect our Services, the information we collect, and the rights of us, our users, and any third parties, including to verify your identity;
- To detect, prevent, investigate, or address fraud, illegal activity, or violations of our terms and agreements;
- In response to legal process, such as a search warrant, court order, or subpoena, or when we have a good faith belief that the law requires us to do so;
- With our current and future subsidiaries or corporate affiliates or actual or potential investors;
- In connection with a potential or actual sale, merger, transfer, exchange, reorganization or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by our Services. If such a transaction occurs, the acquiring company’s use of your information will remain subject to this Policy, as may be subsequently amended;
- Any other purposes described in this Policy or your User Agreement; or
- When we otherwise have your permission.
To help prevent unauthorized access, maintain data accuracy, and protect against the inappropriate use of the information we collect, store, and transmit, we deploy a range of technical, physical and administrative safeguards. Under our Healthcare Provider User Agreement and applicable law, we are required to apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of individually identifiable health information residing on, and processed by, those elements of our Services that we operate as a business associate on behalf of healthcare providers. It is important to remember, however, that no system can guarantee absolute security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Services.
Third Party Services
This Policy applies only to our Services. It does not apply to services offered by third parties, including websites and other online services that our Services may display links to or to advertisements appearing within the Services. When you click on such links or advertisements, you will be visiting websites or interactive services operated by third parties, who have their own information collection policies and procedures. You should be aware that we do not have control over how any third party collects or uses information, so you should review their privacy policies to learn of their practices.
Changes to this Policy
Changes in our business may require that we amend this Policy from time to time. Because this Policy can change at any time, we encourage you to reread it periodically to see if there have been any changes, amendments, or updates. If you object to the changes or any terms within this Policy or the User Agreements, you should discontinue using our Services. Your continued use of our Services means that you have consented to the Policy, as amended, changed, or updated.
Viewing and Updating Your Information
Our Services aim to provide you with access to the information you submit and the means to update it within our Services consistent with applicable law. This can be accomplished by logging into our Services and updating that information, or contacting a customer support representative, although please be advised of the important limitations described below. Under certain circumstances, we may ask you to verify your identity before your request is processed.
Please note that, unless you have administrative rights over another user’s account pursuant to our Healthcare Provider User Agreement, you are not entitled to access, update, or delete the content of another user’s account.
If you have used our Services to share information with another user or a third party, you will not be able to access, update, or delete that shared information. Further, if another user of our Services submits information that identifies you, you will not be able to access, update, or delete that information.
Certain users – such as healthcare providers – may be required under applicable laws or regulations to retain information about you for extended periods of time or indefinitely. Additionally, we may have independent obligations under applicable laws or regulations to retain such information indefinitely. Finally, for disaster recovery and business continuity purposes we retain copies of data stored by our Services for indefinite periods of time.
If you have questions regarding this Policy, please contact us at:
200, 116 Albert Street
Ottawa, ON, K1P 5G3