Privacy Policy
Updated: October 12, 2023
WELL Digital Health Apps Inc. (“WELL”/“we”/”us”) is proud to offer you our website decisionsupport.wellhealth.ai (the “Website”) and WELL AI Decision Support, an AI-powered care pathway platform that enables physicians to identify patients at risk of a rare disease as further described in our Terms of Service (the “Application”). This Privacy Policy describes how we collect, store, use and distribute information about the healthcare practitioners who use the Application and their patients.
By using the Website or using the Application, you consent to the use of personal information as described in this Privacy Policy.
WELL’s customers are healthcare practitioners who are utilizing the Application. If you are a patient of a healthcare practitioner who uses the Application and do not wish for your personal information to be collected and used in the manner described in this Privacy Policy, you must inform the healthcare practitioner that you do not consent to the use of your personal information by the Application.
Due to the rapid evolving nature of WELL’s products, we update this privacy policy frequently. We suggest you review the privacy policy every three months to stay current.
- What personal information do we collect, and how?
Website Access
Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Website, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings, language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online interactions.
These Cookies help us understand how you use the Website and interact with the content of the Website in order to make improvements. We also may use these Cookies to promote our services through marketing and advertising.
Some of the information mentioned above that are collected by Cookies can constitute personal information of the person visiting the website. You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of the Website’s features, and may prevent us from providing you with the information and services you have requested.
Website Form
When you submit a form on the Website, or contact us directly via e-mail, we will collect the information provided by you like your name, e-mail, phone number, clinic/organization you work for, and any other information you may include in your message. This information will be used by us to communicate with you to provide you with the information you requested.
Direct Marketing
If you sign up to receive direct marketing or promotional communications from WELL, we will collect your name and e-mail and any other information you may provide to inform you about WELL products and services.
Application
Healthcare Practitioner Information
The Application is available for use by healthcare practitioners. Information like the healthcare practitioner’s name, electronic medical record provider, billing information, and contact details will be collected by WELL to administer their account (“Account”).
Patient Information
The Application only collects the personal information which is entered into it by the healthcare practitioners or which is recorded by the Application when it is being used by the healthcare practitioner.
The Application does not collect any personal information directly from patient. The Application is a platform used by healthcare practitioners in their assessments of their patients.
- Why do we use personal information?
Account Information
We use Account information and other information collected from the Website to:
- manage our relationship with users and provide them with the information or services requested,
- conduct research and evaluate improvements,
- communicate with you regarding inquiries for information or customer service request or employment opportunities,
- detect, prevent or investigate security breaches,
- process credit card or other payment information,
- protect our business, and
- maintain appropriate records for internal administrative purposes.
We deidentify personal information and may be used on its own or aggregated for analytical and quality improvement purposes, and to better understand and report on trends about certain rare diseases or complex conditions. We use generally accepted best practices for de-identifying and aggregating personal information.
As set out in WELL’s Terms of Service agreed to by healthcare practitioners, WELL reserves the right to use the deidentified data in the future, not only to improve the Application’s performance.
WELL relies on the healthcare practitioners to obtain consent for the collection, use and disclosure of patient’s personal information to be used by WELL. If a healthcare practitioner does not have a patient’s consent for their personal information to be used in this manner, the healthcare practitioner must not use the Application for that patient.
- Who do we share the personal information with?
We only share your personal information with service providers to operate the Website and the Application. This includes sharing your personal information for:
- fraud prevention,
- payment processing and notifications,
- providing requested services or information,
- operating the Website and Application, and
- customer service.
We only use service providers who ensure a comparable level of protection for your personal information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and not use your personal information for their own purposes.
We may have to disclose your personal information to law enforcement agencies where they demonstrate they have the legal authority to request it.
We may also disclose your personal information in connection with a corporate re-organization, amalgamation, or sale of the business (or potential sale of our business). We shall ensure that all such information disclosed as part of such process is protected in a manner consistent with this Privacy Policy.
- How does WELL use artificial intelligence?
WELL uses a third-party artificial intelligence service provider (the “AI Service Provider”) to help provide the Application and process the data as per the Terms of Service. Our contract with our AI Service Provider ensures that they do not collect, use or disclose any information provided to them, except to provide the services we specifically request.
- How long do we keep personal information?
We retain personal information, including personal health information for as long as required to provide the services for which it was collected or as agreed to in our contractual arrangement with you, otherwise, in accordance with applicable legal and regulatory requirements.
Healthcare practitioners using the Application are required to comply with different statutory and regulatory requirements and store personal health information for a minimum length of time. We encourage patients to speak with healthcare practitioners directly on how long they are required to store your personal information.
- How do we keep personal information accurate?
We take reasonable steps to ensure that any personal information in our custody is accurate and up-to-date but we mostly rely on our healthcare practitioners to notify us of any changes to personal information they provided us.
- How do we protect your personal information?
We use physical, administrative and technical measures designed to help secure personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with WELL is prohibited and constitutes grounds for disciplinary action.
Our contracts with our service providers require them to use administrative, physical and technical measures to protect your data. The service providers have agreed to not use the information we provide them for their own purposes.
Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee a breach will never occur.
- Where do we store personal information?
All personal information we collect are stored on secure servers in Canada; and our AI Service Provider processes all information on servers located in Canada.
While we will make all commercially reasonable efforts to ensure that all data is processed and stored in Canada, our data centres and service providers may change, and some processing and storage may occur outside of Canada.
While outside of Canada, personal information is subject to that jurisdiction’s laws, which may give governmental authorities the right to access your personal information.
For more information on our service providers or where we store personal information, contact us at privacy@well.company.
- Links to third-party sites
Our Website may lead you to third-party websites, including websites advertising other products or services. Those organizations are separate and distinct from WELL and have their own separate privacy policies. We are not responsible for how any third-party collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies of these websites before providing your personal information to them.
- Direct marketing
You may sign up to receive marketing or promotional communications from WELL. Where you have expressly consented, we may use your personal information to inform you about us and our products and our services, including promotional offers and events.
If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:
- using the unsubscribe feature found in our emails and other electronic communications, or
- contacting us via email at privacy@well.company
We will stop sending you marketing e-mails within 7 days of receiving your unsubscribe request.
- Your rights
You also have the right to:
- make a written request to access your personal information,
- request us to restrict our continued use or disclosure of your personal information,
- object to our continued use or disclosure of your personal information,
- request that we edit, but not remove, certain information (like an e-mail address),
- request that we transfer to another organization the personal information you have provided us, and
- request us to delete the personal information we hold about you.
Contact us at privacy@well.company to exercise any of these rights. We will respond within thirty (30) days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons.
We will address all requests with equal attention.
- Contacting us
Accountability with respect to your personal information is important to WELL. In the event that you have any questions (including how personal information is managed by WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email.
Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company.
If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.
