Aifred Health

PRIVACY POLICY

Aifred Health Inc. (“ Aifred”) believes that protecting your privacy is important, so Aifred-Lite (the “ Application”) is designed to minimize the collection and use of the data of its users (collectively, “ Users” and each “ User”) and provide transparency and control over your personal information. We encourage you to read the privacy policy set forth in this Section II (the “ Privacy Policy”) thoroughly.

Keeping your personal information safe and increasing transparency is important to us. We are committed to upholding the highest standards of data protection and we thank you for placing your trust in us.

Aifred may be the controller or processor of your personal information provided to us by you or collected by us from you during your use of the Application, as outlined below. If you use the Application, you consent to the collection, use, disclosure and processing of your personal information in accordance with this Privacy Policy. You have the choice to opt-out of sharing your data, as described below, and control how we collect, use, disclose and process your data.

In matters pertaining to Canadian and European laws for the protection of privacy, our Privacy Officer is David Benrimoh.

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@aifredhealth.com.

    1. Definitions

      1. Aifred Systems” refers to the Application, collectively with Aifred’s other digital information systems (including websites, other applications, servers or other digital platforms).

      2. Circle of Care” refers to the network created when Users in the Application become linked to each other.

References to “ You” and “ Your” refer to the User using the Application. References to “ Us”, “ We” or “ Our” refer to Aifred.

    1. Types of Information Collected

Aifred collects two types of information about you through the Application:

      1. Personally Identifiable Data” is any type of information that could be used to identify you personally. This includes, but is not limited to, your full name (first and last name), email address, street address, telephone number, date of birth and photo.

      2. Deidentified Data” is any information that cannot be used to identify you personally and that is kept separate from Personally Identifiable Data. This includes, but is not limited to, your age, gender, occupation, city or country of residence, hospital number, health insurance number, pharmacy contact information, and health information including but not limited to measures and reports of your symptoms and treatments.

We do not require you to include sensitive information (e.g. racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic data, biometric data, or data concerning sexual orientation). In the event that you provide such sensitive information as listed above, you acknowledge that you have provided us explicit consent to collect, use, disclose and process such information in accordance with these Terms and Conditions.

    1. When We Collect Information

We may collect Personally Identifiable Data and Deidentified Data from you at several different points, including but not limited to the following:

      1. when we correspond with you as a User or prospective User;

      2. when you download the Application;

      3. when you register as an end-user of the Application and an account is created for you;

      4. when you use the Application in the ways described in these Terms and Conditions;

      5. when you provide us with information, such as survey information;

      6. when you contact us for help; and

      7. when the Application sends us error reports or application analytics data.

    1. Lawful Basis for Processing

We will only collect and process your Personally Identifiable Data where we have a lawful basis. Our lawful basis includes consent (where you have given it), where processing is necessary for the performance of a contract with you, and for the purposes of our legitimate interests or the legitimate interests of our third parties, provided that such interest does not outweigh your rights and freedoms. Examples of legitimate interest include but are not limited to: (i) complying with applicable law, (ii) protecting against security or other threats, (iii) administration of our business interests, including improvements and enhancements of our business, and (iv) customer relationship issues.

    1. Retention

We may retain the Personally Identifiable Data that is to us for (i) as long as your account is active or (ii) otherwise for a limited period of time as long as we need to fulfill the purposes for which we have initially collected it, unless otherwise required by law or regulatory authority (including for the purpose of complying with regulatory audits from time to time).

We may retain Deidentified Data indefinitely.

    1. Your Rights: Access, Correction, Deletion

You have the right to request access to the Personally Identifiable Data that the Application has about you. You can do this by contacting us at support@aifredhealth.com. In order to comply with your request, we may have to verify your identity.

If you believe that the information that we have about you is incorrect, you can contact us at support@aifredhealth.com with the request. Note that any data that is no longer needed for the purposes specified in Section II.6 will be deleted upon your request.

You have the right to request the deletion of any Personally Identifiable Data that we have about you. If you wish to do so, please contact us at support@aifredhealth.com.

Note that Aifred may not be able to delete any Deidentified Data. Once this any personal information has been deidentified, it may no longer be possible to determine which user it came from. By using the Application, you provide explicit consent to have your data anonymized and used for the purposes described in these Terms and Conditions.

    1. How We Use Your Information

      1. Consent to use of Deidentified Data. By using the Application, you accept and agree that Aifred will be allowed to use any information that that you have provided through the Application (and in the case of a Patient, any information that has been provided by any User within that Patient’s Circle of Care), provided that Aifred has deidentified such information (meaning that we will make the information anonymous by removing your name and other Personally Identifiable Data). Aifred may use your Deidentified Data for various research, quality-improvement and business purposes including, but not limited to, medical research, and the development, creation or improvement of commercial products, software and technologies.

      2. Consent to use of Personally Identifiable Data . Aifred may use Personally Identifiable Data that we collect about you to:

        1. deliver the products and services that you have requested;

        2. manage your customer relationship and provide you with customer support;

        3. perform analysis about your use of the Application;

        4. communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you;

        5. enforce these Terms and Conditions and other agreements between Aifred and you;

        6. manage our business;

        7. respond to investigation, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, or as otherwise required by law; and

        8. perform functions as otherwise described to you at the time of collection, or with your consent if not described at such time.

    2. How We Share Your Information

      1. Consent to Share Personally Identifiable Data . By using the Application, all you accept and agree that your Personally Identifiable Data may be shared as follows:

        1. with other Users in in your Circle of Care,

        2. when we store Personally Identifiable Data in locations outside the direct control of Aifred (for example, on servers or databases co-located with hosting providers),

        3. with third parties which perform services necessary for our operations, or with third parties who offer products or services which may be of interest to our Users. In such case, those third parties must contractually agree to use or process your information in accordance with this Privacy Policy and enter into confidentiality undertakings. However, you agree that Aifred will not be liable for any damages that may result from the misuse of your Personally Identifiable Data by these third parties.

Except as contemplated by Section II.7(d), Aifred will not sell your Personally Identifiable Data to any third party, or share your Personally Identifiable Data with insurance companies, or other third parties that which could use such Personally Identifiable Data to limit your access to healthcare. Except as described in this Section II.7(a), we will not disclose your Personally Identifiable Data without notifying you of our intent to share the Personally Identifiable Data and giving you an opportunity to prevent your Personally Identifiable Data from being shared.

      1. Consent to Share Deidentified Data Aifred may disclose any User’s Deidentified Data pertaining to use of the Aifred Systems (including, without limitation, usage statistics, activity logs, and click-throughs) to third parties. Deidentified Data may also be disclosed to with researchers and strategic partners to advance research or to improve Aifred’s products, software and technologies.

      2. Additional Permitted Disclosure. Aifred reserves the right to disclose Personally Identifiable Data and/or Deidentified Data when required by law or legal process, including a subpoena or other legal proceedings. Aifred may also disclose Personally Identifiable Data and/or Deidentified Data if we reasonably believe it necessary to (i) comply with requests of law enforcement or other applicable law; (ii) to enforce any agreement between you and us; (iii) to protect the security and integrity of the Aifred Systems; and/or (iv) to protect us, our Users or others.

      3. Sale Transactions. We may be involved in an acquisition or divestiture of our business, products or services, whether in whole or in part, including pursuant to a sale of shares holding more than 50% of the voting rights attached to all shares in the share capital of Aifred, a sale of all or substantially all of our assets, an amalgamation or another form of business combination (each, a “ Sale Transaction ”). Personally Identifiable Data and/or Deidentified Data may be sold or transferred in connection with a Sale Transaction. By accepting these Terms and Conditions, you accept that your Personally Identifiable Data or Deidentified Data may be sold to a third party buyer in connection with a Sale Transaction.

      4. Testimonials. You may be contacted to ask you if you want, on an anonymous basis, to make a statement about your use of the Application. If at any point you wish to update or delete your testimonial, please contact us at privacy@aifredhealth.com.

    1. Where We Store and Process Your Information

Any Personally Identifiable Data that we collect from you is currently stored and processed in Canada. If you are accessing the Application outside of Canada, you consent to the transfer of your personal information to Canada. Please be advised that Canada’s laws may not offer the same privacy protections as the law in your jurisdiction.

Deidentified Data can be stored in any other country in which Aifred or its affiliates or service providers maintain operations.

The Personally Identifiable Data collected by Aifred may be processed and/or stored in Canada, the United States, member nations of the European Union, or any other country in which Aifred or its affiliates or service providers maintain operations.

Aifred may transfer information that we collect, including Personally Identifiable Data and/or Deidentified Data, to affiliated entities, or to other third parties across borders and from your country or jurisdiction of domicile to other countries or jurisdictions.

If you are located in the European Union or other regions with laws restricting transferring and location of storage of data, please note that we will comply with laws applicable to us.

If applicable to you, pursuant to the EU Data Protection Laws, Aifred shall act as a processor or subprocessor, and not a controller with respect to any Personally Identifiable Data collected on behalf of our Users. If you are a User who uses our services and you collect personal information on citizens within the [European Economic Area], we ask that you contact privacy@aifredhealth.com to request a Data Processing Addendum (“ DPA”). This DPA implements the GDPR’s Article 28 terms for processors and also incorporates the European Commission’s Standard Contractual Clauses (processors) of 2010 (also known as “model processor clauses” or “SCC 2010”) to facilitate the lawful transfer of Personally Identifiable Data from the European Union to outside of the European Union, where necessary and as required.

    1. How We Protect Your Information

Aifred is concerned with protecting your privacy and data, and therefore we use industry-standard technologies when transferring and receiving User data exchanged between Aifred and third parties (eg. companies that host the Application’s server) to help ensure its security. The Application has security measures in place designed to protect the loss, misuse and alteration of the information under Aifred’s control. The Application’s servers are backed up regularly and protected by security systems. NOTWITHSTANDING THE FOREGOING, WE DO NOT ENSURE OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US OR GUARANTEE THAT YOUR INFORMATION ON OUR SERVERS OR DATABASES MAY NOT BE ACCESSED, DISCLOSED, ALTERED OR DESTROYED BY UNAUTHORIZED BREACH of any of our industry standard physical, technical or managerial safeguards. If you have any questions about security on Aifred Systems, you can contact us at privacy@aifredhealth.com.

    1. Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies, by themselves, do not tell us your e-mail address or other Personally Identifiable Data unless you choose to provide this information to us by, for example, registering for an account using the Aifred Systems. However, once you choose to provide the Aifred Systems with Personally Identifiable Data, this information may be linked to the data stored in the cookie. We use cookies to understand usage and to improve the content and service of the Aifred Systems. We also may use cookies to offer you products or services, including those offered by third parties. You have many choices with regard to the management of cookies on your computer. Most major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies, please consult the privacy features in your browser.

    1. Links

Aifred Systems may create links to other web sites. Aifred will make a reasonable effort to link only to sites that meet similar standards for maintaining each individual’s right to privacy. However, many other sites that are not associated or authorized by Aifred may have links leading to our site. Aifred cannot control these links and Aifred is not responsible for any content appearing on these sites.

    1. Children’s Privacy

Unless otherwise specified by the laws of the jurisdiction where you live, if you are under the age of 18 you should use the Application ONLY with the consent and the involvement of a parent or guardian.

We do not knowingly collect any Personally Identifiable Data from anyone who we know to be under the age of 13. If we discover that a person under the age of 13 has provided us with any Personally Identifiable Data, we will use commercially reasonable efforts to delete such person’s Personally Identifiable Data from all Aifred Systems.

    1. Contacts

If you have any questions about this Privacy Policy, the Application or our practices, or wish to request access, changes or deletion of information we have about you, you can contact support@aifredhealth.com.

    1. Opt-Out

The Application provides users the opportunity to opt-out of receiving communications from Aifred, except transactional correspondence. To opt-out of receiving our communications, you can: (i) send email to support@aifredhealth.com; (ii) use the appropriate settings in the end user application; or (iii) click the unsubscribe link in any electronic communication you receive from us.

Date of last update : July 25 2019.