Last Updated: January 2024
What is Personal Information and Personal Health Information
Personal information is any information that identifies you, or by which your identity could be deduced (“Personal Information”). This may include information such as your address, phone number, email address, payment details (for example, your credit card information), transaction history and other information you provide us.
Personal health information (“PHI”) is identifying information about you in oral or recorded form that relates to the details of your healthcare. This may include your health history and health conditions or diagnoses. VCR shall be designated the Health Information Custodian with regards to PHI that it collects from you and Dr. Christopher Saieva shall be the designated contact person for the Health Information Custodian.
What Personal Information and PHI Do We Collect and Why Do We Collect It?
We collect and store any Personal Information and PHI that you provide us directly when you use the Services (including, without limitation, by participating in sessions or consultations or otherwise communicating with health care providers engaged by VCR), interact with our Sites, or contact us.
We use your Personal Information to: (a) provide our Services to you; (b) communicate with you from time to time via email; (c) improve and optimize our Sites (for example, by generating analytics about how visitors browse and interact with the Sites, and to assess the success of our marketing and advertising campaigns); (d) include you in any direct marketing activities (only after obtaining your express consent if done electronically); and (e) other business purposes.
When you make a payment to us, we use third-party services to process payments and do not have access to your payment information. The third-party services will be responsible for securely managing your personal and financial data in accordance with payment card industry data security standards (also known as PCI DSS).
We may also use a technology called web beacons to collect general information about your use of our website and your engagement with special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.
Personal Health Information
We collect your PHI in order to provide our Services to you, in particular, in order to assess your needs and provide appropriate advice and consultation.
PHI will only be used for the purposes for which it was collected. The PHI is retained only as long as necessary and destroyed in accordance with applicable legislation, our policies, guidelines and procedures.
Sharing Personal Information
(a) facilitating the provision of healthcare and related health services to our users via our telehealth platform;
(b) providing transactional information (such as dates of sessions and amounts paid) to your referring health care providers, to the extent necessary to substantiate payment of referral fees (if applicable);
(c) providing Personal Information and PHI to your primary care physician and/or other health care providers who you identify to us, in connection with referrals and to support your continuing care;
(d) processing, monitoring, verifying or reimbursing claims for payment under any Act;
(e) anonymizing or de-identifying the information
(f) by internal employees or independent contractors of VCR in order to deliver, audit, and improve and respond to inquiries related to our Services;
(g) by internal employees or independent contractors of VCR in order to confirm your transactions, understand our customer demographics and preferences, and communicate with you;
(h) by third party service providers to provide certain services, such as processing payment card information, videoconferencing, scheduling, web hosting, and email service providers;
(i) when we are required, authorized or permitted by law to do so, including but not limited to averting an imminent or significant risk of harm to an identifiable person or group; and
(j) as otherwise consented to by you.
We may sell data which has been aggregated or otherwise de-identified and which does not contain your Personal Information or PHI.
We may share your Personal Information or PHI to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights, subject to applicable laws.
Your Personal Information may be used by us or our service providers to provide you with targeted advertisements or marketing communications which may be of interest to you. For example, we may use Google AdWords remarketing to market our site across the web. We place a cookie on a browser and then a 3rd party (Google) reads these cookies and may serve an ad on a 3rd party site. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of certain targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
Additionally, you can opt out of certain services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
How Long Do We Keep Your Information?
We retain your Personal Information and PHI as long as required to provide our Services, or as long as required for VCR to fulfill our business requirements, agreements, contracts, and legal obligations.
It is your responsibility to ensure your information provided to VCR is accurate, current, and complete. If you wish to update, correct, review, or validate any Personal Information or PHI, you can do so through your User Account or by contacting us using the contact details provided below. Upon request for access, you will be given access to your Personal Information and PHI within a reasonable time. VCR may charge an administrative fee in connection with any access requests. Certain access requests may be limited for legal, security, business reasons, and reasons related to prohibitive cost.
How Do We Get Your Consent?
Your consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice.
How Do We Keep Your Information Safe?
VCR takes reasonable precautions to protect your Personal Information and PHI from loss, theft, unauthorized access, disclosure, copying, use or modification. You are also responsible for keeping your devices secure, to prevent unauthorized use and access of your Personal Information and PHI. Among the steps taken to protect your information are the use of two-factor authentication and internal password and security policies. Email is not a 100% secure medium, and you should be aware of this when sending any information to us.
You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about our privacy practices or how your personal health information has been handled.
Do You Have Any Other Questions?
Please contact us if you have any questions or requests.
Contact Email: email@example.com