Privacy Policy
Last updated : October 27, 2023
Avicenna Digital Health Corp. ("we," "us," "our", “Avee”) takes steps intended to meet privacy principles and requirements with respect to personal information under applicable privacy legislation. This Privacy Policy (the Policy) applies to personal information collected, used, disclosed or otherwise processed in connection with the use of the Avee Services or Panel Avee cares about privacy and is committed to protecting it by adhering to the Policy.
This Policy should be read in conjunction with our Terms and Conditions (avee.health/terms-and-conditions). By accepting the Policy, Users expressly consent to the collection, use and disclosure of their Personal Information in accordance with this Policy.
Any Personal Information collected by Avee on the Panel is subject to this Policy. All capitalized terms not defined in the Policy are defined in our Terms and Conditions.
THE SERVICES ARE MEANT TO BE USED BY AUTHORIZED HEALTH PROFESSIONALS, PATIENTS AND VISITORS (COLLECTIVELY “USERS”). AS SUCH, EACH INDIVIDUAL USER, WHETHER AN AUTHORIZED HEALTH PROFESSIONAL OR A PATIENTIS FULLY RESPONSIBLE AND SHALL BE AWARE OF THIS POLICY AND THE TERMS AND CONDITIONS, INCLUDING ANY UPDATES, CHANGES OR OTHER MODIFICATIONS.
Definitions
In this Policy, the following terms have the following meanings:
- Application means the Avee mobile browser that may be changed or updated from time to time, compatible with various electronic devices including smartphones and tablets, on which the Services can be accessed by Users.
- Authorized Health Professionals means the pharmacies, pharmacists nursing homes, and other health or mental health facilities, and physicians who provide health services to Patients, including their officers, directors, employees and other authorized representatives, and who have entered into an agreement with Avee regarding access to the Services;
- Patient means any patient who benefits from Services;
- Personal Information means information which relates, directly or indirectly, to an identifiable individual;
- Platform means the digital interface developed by Avee and provided to Users to access and provide Services;
- Services means the services offered by Avee, including access to an online platform allowing Users to book a virtual consultation with a physician and physicians to view upcoming appointments and information regarding patients;
- Users collectively refers to Authorized Health Professionals, Patients and Visitors;
- Visitor means any person accessing the Public Panel;
- Panel means the Avee Internet Panel available at https://avee.health/ or other URL address, as applicable from time to time.
Object of the policy
Our main objective is to offer Users a secure, effective and personalized experience when using or benefitting from our Services, via our Application, Platform, or otherwise, or accessing our Panel, provide services and functions that meet individual needs and to personalize our service to make our Users’ experience more secure and friendlier. The information collected about Users is solely information deemed necessary to achieve this objective.
This Policy describes the Personal Information collected from Users by Avee, the reasons why such Personal Information is collected, how it is used and processed, and the circumstances under which such Personal Information can be disclosed. Providing certain Personal Information may be required to access to Panel or benefit from our Services. By using our Services and accessing the Panel, Users indicate that they understand, accept, and consent to the practices described in the Policy.
Collection of Personal Information
In connection with the provision of its Services, Avee will collect and/or process various Personal Information regarding Authorized Health Professionals. Authorized Health Professionals will also have the possibility of using the Services to collect Personal Information regarding Patients who may benefit from the Services. Finally, Avee will collect information regarding Visitors who access the Panel or otherwise contact Avee regarding the Services. In any event, such Personal Information shall only be collected and used as described in this Policy.
In order to benefit from the Services or access the Panel, certain Personal Information may be required. We only collect Personal Information that is necessary to provide our different Services. Where possible, we indicate which fields are required and which fields are optional.
- When signing up, Users will need to provide certain information to allow Avee to authenticate persons and set up any accounts required to access the Services. This information includes but is not limited to an individual’s first and last name, email address, contact information and other information necessary to establish a membership file
- Users will be required to create an electronic patient record for each Patient prior to providing Services to such Patient. As such, Users will need to input various Personal Information in such Patient’s electronic record, including the Patient’s first and last name, date of birth, residential address, medical history, list of prescribed medication, existing health conditions, if any, emergency contact information and any other information required for the Services. An Authorized Health Professional will then be able to download or store in such electronic record any additional Personal Information they may be provided regarding a User. Such Personal Information can be added at the Authorized Health Professional’s discretion, based on the Patient’s needs and applicable ethical and legal requirements. Once created, such records can be used to track and chart the medical services provided to the Patient using the Avee Services. In the event that any prescription must be filled out regarding a Patient by the Authorized Health Professional, information regarding a Patient’s preferred pharmacy may also be collected for the purpose of submitting the prescription.
- Patients benefitting from the Services will be required to provide certain information for payment purposes. Such information includes health insurance provider information, as the case may be, and credit card information.
- Authorized Health Professionals will also be required to supply payment information, including credit card numbers or banking information. Such information is only used by Avee for the purpose of being paid for the Services provided to physicians.
- If a User subscribes to a mailing list, we will collect such User’s name and email address to send them emails about various news and promotions. Even after subscribing to a newsletter or promotional communication from us, Users may elect to modify their preferences by following the “Unsubscribe” link provided in an email or communication received.
- When a Visitor visits our Panel, we may collect information about such visit through cookies and similar technologies (see our section on Cookies and other tracking technologies for more information).
We may collect other information about Users, including information communicated in correspondence and requests sent to us, and exchanges we may have with Users. This information will be used to improve the services we provide.
In addition, Authorized Health Providers may also collect and Users may upload to a Patient’s electronic patient record Personal Information regarding such Patient and their health condition. Note that as a general rule, Avee is not responsible nor shall Avee be held liable for the collection and processing of Patient Personal Information by Authorized Health Professionals.
Use of Personal Information
We collect Personal Information about Users essentially to be able to provide access to our Panel, Services, Platform or Application, as the case may be, and thereby allow Users to benefit from a secure, effective and personalized experience. Users agree that their Personal Information can be used, as the case may be, to:
- allow Authorized Health Professionals to access our Services;
- enable Patients to benefit from such Services, including virtual consultations and follow-ups with Authorized Health Professionals, and preparation of any required prescriptions;
- personalize and improve our services, content and advertisements ;
- obtaining Users’ feedback for the Services rendered;
- contact Authorized Health Professionals and Patients to resolve problems affecting their account or for other reasons authorized by law;
- contact Authorized Health Professionals to inform them of our services and the services of our affiliates, send them niche marketing products and give them access to our updated services;
- prevent, detect and, eventually, investigate fraud and security breaches, activities that may prove to be prohibited or illegal;
- ensure that Patients are appropriately billed for health services received by Authorized Health Professionals using the Services;
- allow Authorized Health Professionals to comply with any ethical or regulatory requirements they may have regarding the retention of patient records; and
- enforce our Terms and Conditions of Use [NTD: insert link] and meet legal, regulatory, insurance and processing requirements, and otherwise with a User’s consent, or as permitted or required by law.
Disclosure of Personal Information
Avee does not sell, trade or rent Personal Information. In addition, Personal Information is not shared with, disclosed to, or used by third parties for purposes other than those for which it was collected, all as more fully described in this Policy, unless required or permitted by law or unless meaningful consent is obtained, as applicable.
Avee will disclose Personal Information if it has legal authority to do so, such as in the following contexts:
- We may disclose or otherwise make available to Patients any Personal Information pertaining to an Authorized Health Professional’s status as a licensed physician;
- We may use and disclose Personal Information in the context of a business transaction, in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of Avee, or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Avee, or our business or assets, may use and disclose User Personal Information for similar purposes as those described in this Policy.
- We may disclose Personal Information, if we reasonably believe such disclosure is required, to meet certain legal, regulatory, insurance, and audit requirements, enforce our Terms and Conditions, respond to claims to the effect that some content breaches the law or the rights of a third person, including intellectual property rights or ensure everyone’s safety and security, and as otherwise with a User’s consent, or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to us or our service providers). In particular, without the need for a subpoena, we are entitled to disclose a User’s Personal Information, including full name, Date of Birth, Personal Health Number, Address, postal code, email address (if available), telephone number (if available), browsing history of our Sites, IP address, and any other information that might seem relevant, in response to a formal request from a regulatory body in connection with a criminal investigation or allegedly illegal activities or any other activity that might expose Avee to legal liability.
- We may share our data, including Personal Information, with our affiliated companies, potential partners and third-party service providers (“Third Party Service Providers”) that are outside our network, and that perform services on our behalf such as data hosting, tech development, payment processing, marketing service providers, and processing to the extent it is necessary for them to complete their function. Third Party Service Providers shall follow privacy practices no less protective than our practices described in the Policy. We may share Personal Information with our contracted service providers that participate in our commercial activities. We are not responsible in any way for how any Third Party Service Provider collects, uses, or discloses Users’ Personal Information, so it is important for Users to familiarize themselves with the privacy policies of these Third Party Service Providers.
In addition, we can disclose Personal Information if we have a User’s consent, or as permitted by applicable privacy laws. If Personal Information must be disclosed outside a User’s jurisdiction of residence, we will do so in accordance with applicable laws, and ensure our external partners do the same. In such circumstances, governments, courts, law enforcement, or regulatory agencies of that jurisdiction may be able to obtain access to Personal Information through the laws of the foreign jurisdiction. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation. By accessing the Platform or Application, offering or benefitting from the Services or visiting the Panel, Users consent to such disclosure of their Personal Information outside their jurisdiction of residence.
Ensuring the Security of Personal Information
Computers located in British Columbia retain and process Personal Information. We take reasonable steps to protect the Personal Information in our custody or control using physical, electronic or administrative security measures that are appropriate having regard to the nature and sensitivity of the information, including firewalls, information filtering and encryption. We use different security techniques to protect collected data against unauthorized access by Avee’s internal and external users and we take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to perform, develop or improve our services, and ensure that those authorized employees and contractors are aware of their responsibilities.
Please note that Authorized Health Professionals also play a part in the safety and security of Personal Information. Authorized Health Professionals’ password is an essential tool to ensure the protection of their account. We advise Authorized Health Professionals to create a password with a unique string of numbers, letters and unique special characters and not to disclose it. If an Authorized Health Professional gives their password to a third party, they will be held liable for everything done using their account identifiers. Authorized Health Professionals are required to notify Avee immediately if they suspect that their password has been compromised, and create a new password without delay. All Authorized Health Professionals are encouraged to use multifactor authentication when using the Services.
Despite all our efforts to preserve the confidentiality of Personal Information, we cannot guarantee the security of any Personal Information transmitted via the Platform or Application, or collected or stored as a result of the Services, and third persons may illegally intercept information housed on our Platform or Application, or our systems’ security may otherwise be breached. In such a case, we cannot be held liable for any loss, corruption or unauthorized disclosure of information that would be beyond our reasonable control.
Tracking Technologies
We use Google Analytics to better understand who is using our Panel, and how people are using it. Google Analytics uses cookies to collect information such as Panel pages visited, places where users click, time spent on each Panel page, Internet Protocol address, type of operating system used, and location. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information. Google may track activity over time and across Panels. Once again, such information is used to target advertisements and content that may be of interest to Visitors, and also to provide statistical insight through features such as Google Analytics and Google Ads.
In some instances, tracking tools used by third-party service providers may be disabled. For example, Google allows users to deactivate cookies designed to target ads by accessing the Opt-Out page of its main Panel. Google Analytics may also be deactivated by downloading the browser add-on available for that purpose. Users may also decline the use of cookies by other third-party vendors by logging on to the Network Advertising Initiative consumer deactivation page.
Finally, if a User downloads or uses our Panel on their mobile device, we might receive data on their location and on the mobile device used, including a unique identifier of such device. Visitors can use the adjustment menus on most mobile devices to activate or deactivate the location services at their convenience.
Links to Other Sites and Voluntary Disclosure of Personal Information
In the event that links to third-party Panels are provided on the Panel or through the Application, Platform or Services, then any User and any other person should keep in mind that these sites operate independently and are subject to their own terms of use and privacy policies. Similarly, in the event that the Services appear to be available on other Internet sites, those sites should not be considered affiliated with Avee or otherwise in connection with the Services. In either case, it is strongly recommended that any User and any other person, where applicable, review the terms of use and policies of such third party Panels, as Avee is not responsible for the content or practices of such Panels and shall not be held liable for how these other Panels collect, use, and disclose Personal Information.
Accessing, correcting and deleting Personal Information
Authorized Health Professionals
By law, Authorized Health Professionals have the right to request access to, the correction and/or a copy of their Personal Information held by Avee. Authorized Health Professionals can also consult and change most of their Personal Information by accessing their account via the Platform or Application and updating their profile.
Once Avee’s contractual relationship with an Authorized Health Professional is terminated, Avee will close all accounts associated with such Authorized Health Professional and any information stored therein shall be permanently erased after a reasonable period of time. As applicable and as required by their regulatory and/or ethical requirements, Authorized Health Professionals are responsible for ensuring that adequate copies of Patient Personal Information, as needed, are made and stored appropriately. Upon request, Avee can generate a data file of all information associated to an Authorized Health Professional’s Account, and assist such Authorized Health Professional with the migration of such information to another service provider.
Note that by requesting the deletion of their Personal Information or by withdrawing their consent to the collection of Personal Information, Authorized Health Professionals may no longer be able to access the Services provided by Avee. Avee will inform Authorized Health Professionals of the consequences of the deletion of their Personal Information or withdrawal of their consent at that time to assist in the decision process.
Before acting on a request received by an Authorized Health Professionals regarding their Personal Information, we may ask for specific information to help confirm such Authorized Health Professional’s identity. In some cases, applicable law may require us to refuse to provide an Authorized Health Professional access to some or all of their Personal Information, in accordance with our legal record-keeping obligations and privacy best practices. If that is the case and subject to any legal or regulatory restrictions, we will advise such Authorized Health Professional of the reasons why access is prohibited.
Patients
A Patient’s electronic record is not immediately accessible to such Patient. In the event that a Patient wishes to obtain a copy of, correct or otherwise access their Personal Information, such a request must be formulated in accordance with applicable laws. Any such request must be directed at (and shall be processed by) the relevant Authorized Health Professional. In the event that Avee is contacted by a Patient with regards to their Personal Information, Avee shall redirect such Patient to the relevant Authorized Health Professional.
Conservation of Personal Information
Subject to applicable laws and unless a User consents otherwise, Avee will only store Personal Information for the purposes disclosed in this Policy, and for as long as necessary to accomplish the purposes described herein. However, Avee may keep Personal Information after the specific purpose for which it was collected is achieved, if required to prevent fraud, for troubleshooting, to cooperate in connection with any investigation, to comply with the legal requirements prescribed by law and to fulfill any other purposes for which it was collected. Once Personal Information is no longer required, it will be deleted or anonymized in accordance with applicable laws.
Changes to this Privacy Policy
Avee reserves the right to change or modify this Policy from time to time. Any material changes will be brought to the attention of Users before taking effect via a web banner or other means. Thereafter, the Policy will be made available and easily accessible on the Platform and on the Panel. An updated version of this Policy will also be posted whenever a minor change is made. Anyone can tell if this Policy has changed by looking at the effective date at the top of this Policy. Continued use of the Services and/or access to the Panel constitutes acceptance of any such changes to the Policy.
Contact us
Any questions or comments regarding this Policy, as well as any relevant requests, must be addressed to Avee using the following information:
Ali Salemi
privacy@avee.health
401 - 68 Water St, Vancouver, BC. V6B 1A4
info@avee.health