OVERVIEW
Cloudcure Inc. (“Cloudcure”, as follows “we” or “us”) updated this Privacy Policy (“Policy”) on November 20, 2023. We reserve the right to amend this Policy to account for changes in Applicable Law, our Services and our Applications. Please check to see if we have amended the Policy since you last used any of our services to ensure you are aware and agree to the current version of this Policy.
This Policy generally describes how we collect, use and disclose personal information about individuals who access and use our website and our services (“Users” or “you”), including:
- to communicate via Cloudcure’s website (including the website hosted at www.cloudcure.ca and any other web domain used by Cloudcure to communicate with users now or in the future) (the “Website”);
- to communicate via any mobile, computer, or tablet-based application offered by Cloudcure (the “Applications”); and
- provide our health and health-related services (collectively, with the Website, the Applications, Medical advice, Coaching, Digital tools for health tracking, Prescriptions, and provision or supply of Medications, Treatments or Pharmaceutical Products, and Provision or supply of Supplements, collectively referred to as the “Services”).
If you have any questions about this Policy, please contact us by sending an email with your questions our privacy office as described below, before accessing or entering any information on the Website.
TABLE OF CONTENTS:
1. INFORMATION WE COLLECT
2. HOW WE COLLECT INFORMATION
3. HOW WE USE AND DISCLOSE YOUR INFORMATION
4. HOW WE OBTAIN YOUR CONSENT
5. HOW LONG WE USE, RETAIN OR DISCLOSE YOUR INFORMATION
6. ACCESSING, CORRECTING & DELETING YOUR PERSONAL INFORMATION
7. ACCOUNTABILITY FOR PERSONAL INFORMATION
8. KEEPING YOUR DATA SECURE
9. USER REFERRAL SERVICE
10.THIRD PARTIES
11. COOKIES
12. CHANGES TO THIS PRIVACY POLICY
13. HOW TO CONTACT US
1. INFORMATION WE COLLECT
We collect your personal information in accordance with PIPEDA and other applicable laws. Our sources may include direct user input or third-party providers upon receipt of your consent or as otherwise permitted by law. The following information is collected:
- Identification information includes but is not limited to your name, contact information and identification, including your Application usernames and passwords.
- Financial information includes payment card details used to purchase Services.
- Health information includes medical screening information, medical history, and diagnostic information
- Insurance information including private insurance details and provincial health numbers for insured services This may also include your employment or business information if the insurance is provided by your employer or business.
- Technical information when you access and use our Website and Applications, we may collect information about your device and internet connection including your device’s unique identifier, IP address, browser type and version, mobile network information, your device’s telephone number, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites and apps.
- Usage information includes information about how, when and where you use our Services.
- Marketing and communications information includes your preferences in receiving marketing from us and third parties and your communication preferences.
We may also collect other information that is not identifiable to you, or may convert your personal information into anonymous data. We use anonymous data for a variety of purposes. Anonymous data is not subject to this Privacy Policy.
In addition, to learn about your experience as a User and to make periodic improvements to the Services, we may collect and retain certain additional information about you. We will automatically record information about your activity on the Website and our Applications. This may include your Internet Protocol (IP) address, operating system, geolocation information, locale preferences, identification numbers associated with your computers and mobile devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata, and other electronic interactions with Cloudcure and the Website.
2. HOW WE COLLECT INFORMATION
We collect your information (“Personal Information”) in accordance with PIPEDA and other applicable laws. This information is collected for marketing, to register Users, create a User account, authenticate login credentials, personalize your experience and improve your experience while using the Applications. We may collect this information from you directly or from third parties where we have your consent, or as otherwise permitted by law.
Information is collected in multiple ways such as:
- Information provided by you to us directly via electronic means or through our Applications
- Information provided by you to us when you disclose or discuss information to a cloudcure healthcare provider or health coach
- Questions, communications or feedback you submit to us electronically
- Information shared by any medical providers not related directly to cloudcure, on your behalf, including medical laboratories
- Your participation in research and surveys
- Requests for customer support or technical assistance electronically or via phone
- Uploads or posts to the Applications
- Employment applications submitted by you to Cloudcure
3. HOW WE USE AND DICLOSE YOUR INFORMATION
We use personal information collected from the Services to:
- To facilitate, administer, and determine eligibility for access to our digital platforms and Applications;
- provide the Services to you and accompanying customer support;
- track purchases, arrange refills and prescription renewals;
- for billing including private insurance and provincial health insurance for insured services;
- notify you about updates and changes to the Services;
- prevent and address technical issues with the Services;
- to advise you about programs and services that may be of interest;
- optimize the content, format and programming of our Services;
- to improve our Services;
- to conduct or publish scientific research based on clinical outcomes;
- to collect comments and feedback about Cloudcure’s operations;
- to help us create, develop, evaluate and improve our platforms and content
- monitor usage of the Services for security, quality and improvement;
- to receive, investigate and address inquiries, complaints, or legal matters, or to enforce our rights arising from any contract or other relationship with you;
- for such other purposes as you may consent from time to time; and
- as otherwise required or permitted by law.
We may disclose your personal information:
- pursuant to your consent
- transferring Personal Information to third party service providers assisting us with the Services, including but not limited to, Physicians, Nurse Practitioners, Pharmacists, in addition to telephone support or data storage and processing providers;
- when we believe such use or disclosure is permitted, necessary or appropriate to
- respond to requests from public and government authorities;
- respond to claims that any content violates the rights of third parties
- enforce the terms of the agreements for our products and services;
- to investigate fraud and other illegal conduct; and
- protect our rights, operations or property, or allow us to pursue available remedies or limit the damages that we may sustain;
- to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or other assets, or other business transaction; and
- to affiliates and subsidiaries of Cloudcure Inc. to deliver products and services to you
- to a third party, if we merge, buy, partner or become acquired by a third party, where assets are transferred from business to another;
- to third party service providers to perform services on our behalf such as billing, sales, marketing, analytics, research, customer service, shipping and fulfilment, data storage, IT and security, fraud prevention, payment processing, auditing and legal services;
- on public forums, where you have posted comments publicly with other users. Please note that any information shared through such features is not confidential and we may use it for any purpose including marketing or testimonials. For instance, if you submit a product review on one of our sites, we may display it on other sites or services owned or used by us.
- on consent to disclose information to an insurer;
- as otherwise permitted or required by law.
We may transfer your personal information to service providers that are assisting us with permitted purposes. We ensure that those service providers are subject to appropriate privacy standards and are required to comply with applicable privacy laws.
4. HOW WE OBTAIN YOUR CONSENT
We obtain consent at the time that Personal Information is collected, prior to the use or disclosure of this Information for any purpose. This Consent could be collected and provided orally, in writing, or electronically. The form of consent and whether it is explicit or implied depends on the sensitivity of the data collected, and reasonable expectations you may have in the circumstances. We may rely on a third party to obtain the consent. You have the right to withdraw consent by providing us with notice, with express instructions to not share, use or disclose your Personal Information without consent from you.
5. HOW LONG WE USE, RETAIN OR DISCLOSE YOUR INFORMATION
We will retain your Personal Information at least until you close your account, unless otherwise notified. We will use, retain and disclose this Personal Information as long as necessary for the Uses for which it was collected, as permitted or required under applicable law.
6. ACCESSING, CORRECTING & DELETING YOUR PERSONAL INFORMATION
You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by applicable laws. You may also request the correction of your personal information that is inaccurate.
If you wish to access or correct your personal information, please send an email to our Privacy Office as outlined below.
So long as your account remains active, we will preserve your personal information in accordance with this Privacy Policy.
You may decline to share certain personal information with us, or, where permitted by law, may qualify your consent to our collection, use and disclosure of your personal information, in which case you may not be able to use the Services, either in its entirety or certain features. We will not charge you a fee without providing an estimate of appropriate costs, if you wish to access your Personal Information in our record or to access our privacy practices.
If you have not accessed your account for a total of 1 years, we may terminate your account, without notice, along with any personal information retained by us. You may be requested to provide sufficient information to permit access to the existence, use, or disclosure of your Personal Information. Any such identifying information requested and required will be only used for this purpose.
We will retain any and all information that we are required to retain under any applicable laws for the full duration of time required under those laws.
7. ACCOUNTABILITY FOR PERSONAL INFORMATION
In most of the provinces we operate, Cloudcure has overall responsibility for protecting the privacy of your Personal Information including information collected in order to provide health care services by a healthcare provider (“Health Data”), such as a physician or nurse practitioner. In Alberta, your healthcare provider has overall responsibility for the privacy of your Health Data. Cloudcure assists the healthcare provider in meeting that responsibility, but under Alberta’s Health Information Act (“HIA”), the healthcare providers are ‘custodians’ for your Health Data, which is collected pursuant to section 20 and section 27 of the HIA.
8. KEEPING YOUR DATA SECURE
We will store your information in electronic format on servers protected by industry-standard measures. Except where required to do so by law, we will not store your personal information in any physical or paper-based format.
Like most companies, we cannot guarantee that our safeguards will always be effective –particularly where the personal information is communicated over the Internet. A breach of security safeguards can result in such risks as phishing and identity theft. In such cases, we act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.
We may also require you to assist us to safeguard your Personal Information. For instance, if you have an account on our Website or Application, you should use unique and strong passwords, not share your passwords with others.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact our Privacy Office as outlined in below, immediately.
Within the permissibility of governing laws in your jurisdiction in Canada, our servers may be located outside of Canada, and thus are potentially subject to the privacy and security laws in force in other countries. While your personal information is outside of Canada, it is subject to the laws of the countries in which it is held – including legal requirements to disclose personal information to government authorities in that country. If you have concerns about your personal information being stored electronically in foreign jurisdictions, please contact us before proceeding to use the Website.
Cloudcure is not targeted to and is not intended for use by European Union (EU) residents located in the EU. EU residents may use the Platform if they are temporary or permanent residents in the province of Alberta, British Columbia, Manitoba, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island, or Saskatchewan or a Canadian territory. By using the Cloudcure Applications, you agree that Personal Information can be stored and processed per the laws of Canada.
9. USER REFERRAL SERVICE
You can choose to provide us with the names and email addresses of individuals or organizations that you feel would be interested in learning more about our products and services. When you choose to engage this service, we may send a preliminary email to each address provided to us, inviting the contact to visit our website. We continue to store the contact details in order to track the success of our referral service. By providing us with the contact information of another person, you are responsible for obtaining their consent to do so.
10. THIRD PARTIES
This Policy does not address, and we are not to be held responsible for any information security or privacy protection of any third parties, including physicians, nurse practitioners and other health care providers using the Services, manufacturers of your electronic devices or software, or other commercial services used by you. You are advised to read the privacy and security policy of these third parties directly to learn about the collection, use, disclosure and security of your personal information.
11. COOKIES
To facilitate the collection of information and to enhance the experience of Users of the Website and our Applications, we use cookies, pixels and other related or similar technologies, which may be stored on Users’ computers and/or devices to provide a more tailored experience. We may adopt additional tracking technologies as we increase our capabilities within the permissibility of applicable laws in Canada. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, changing such settings may result in you not being able to use the Website or our Applications, either in its entirety or certain features. Using cookies, you may have the option to allow us to save your user ID and login password for future logins to the Website or our Applications. Cookies that are stored on your computer and/or device after visiting the Website or our Applications may be recognized for advertising purposes and to show you targeted advertisements after you visit the Website. You can choose to accept or decline our use of cookies. For more information on cookies used, please refer to our Cookie Declaration.
This Policy is intended as a summary of our privacy policies in effect at a given time. As such, we may update this Policy from time to time to reflect changes in our operations. Any updates are effective upon posting to the Website. We will make efforts to communicate any changes to this Policy we deem material, in our sole discretion, via email or notifications on the Website. The Policy was last revised as of the date that appears at the top of this page.
13. HOW TO CONTACT US
If you have any questions or concerns, or wish to make an access or correction request, please contact us our Privacy Office at:
Cloudcure Inc.
ATTN: Privacy Office,
hello@joincloudcure.com
200 – 2020 Winston Park Drive,
Oakville, Ontario. L6H 6X7
