ClearMe Group Inc.. / ClearMe.ca
At ClearMe our mission is to put an accessible and affordable health services in the hands of all people. We are passionate about high-quality and convenient healthcare. We are also passionate about privacy. We strive to be market leaders when it comes to healthcare and privacy, and always to comply with applicable privacy laws.
This policy explains how we collect, use, disclose and otherwise process your personal data when you use our healthcare services and products in Canada, the United States of America, and the rest of the world or visit or use the App or any of our websites that link to this policy (collectively, our “App”).
We want to help you understand how we utilize your data, so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this policy. We may update this policy from time to time and we will notify you when we do so.
This policy covers:
Who we are;
What personal data we hold and how we get it;
What we use your personal data for;
Sharing your personal data;
Data security and transfers; and
If you have any questions about how we process your information, please don't hesitate to get in touch by contacting our Privacy Officer at firstname.lastname@example.org.
1. Who we are
Your relationship is with CLEARME GROUP INC When this policy talks about ‘ClearMe', 'us', 'we' or ‘our’, it means CLEARME GROUP INC.
2. What personal data we hold and how we get it
We use the following categories of personal data:
When you register with us, you complete forms and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. You will also provide us with a copy of identification documentation for ID checks to be carried out on our behalf by one of our service providers, and health card number/provincial health insurance number for the purposes of us billing the public health system. You are responsible for the accuracy of the information that you provide to us.
Health and medical information
The main type of information we hold about you is health and medical information: information about your health, symptoms, treatments, test results, consultations and sessions, medications and procedures. This includes details of your consultations with our doctors, nurses, phlebotomist and interactions with our digital services. Your interactions with our digital services may be shared with our doctors in order to provide you with a better experience and for the purposes of providing you health care and pertinent information related to travel or assurance compliance by a third party.
We get some of this information directly from you, when you register with us and when you use our healthcare services. Any correspondence we receive from you is uploaded electronically to your ClearMe download portal. We may also get this information from third parties, such as laboratories or other healthcare professionals.
We may retain recordings of our consultations and interactions with you for record keeping. This can include your use of our digital tools, and monitoring services, video and audio recordings or audio-only recordings. This is in order to provide you with an easy way to check your consultations where you wish to, so that we can ensure high quality care is provided to you, and with your consent, to allow us to learn from them to improve our services. To monitor our service quality, we may retain records of when you contact our support teams via email or phone. Recordings are held securely in accordance with our retention policy. You can access recordings of your consultations or interactions with us (depending on the format) by contacting ClearMe.
We may also hold information about you and your health from other apps, devices and services where you have given your consent to that data being shared with us. Examples include where you decide to share information collected from a smart watch or similar device with our App.
If you make any payments on the App, your credit/debit card details are processed directly by a third party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.
Technical information and analytics
When you use our App or visit our website, we may automatically collect the following information where this is permitted by your device or browser settings:
technical information, including the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system platform type and version, device model, browser or app version, time zone setting, language and location preferences, wireless carrier and your location (based on IP address); and
information about your visit (such as when you first used the App and when you last used it, and the total number of sessions you have had on that App), including products and services you viewed or used, App response times and updates, interaction information (such as button presses or the times and frequency of your interactions with the communications we deliver to you in the App or otherwise) and any phone number used to call our customer service number.
We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services. You can change your device settings to block cookies, or to notify you before a cookie is set. If you block cookies, you may not be able to use all the features of our App. You can prevent the setting of cookies by adjusting the settings on your browser or your mobile phone.
Information obtained from third party services
You may choose to connect your existing devices (such as wearables) in the future with our services and we may receive information from your device. Provided we are acting in accordance with data protection laws, we may also use information from other sources, such as specialist companies that supply information, online media channels, our commercial partners and public registers. This information can for example, help us to improve and measure the effectiveness of our services.
3. What we use your personal data for
The purposes for which we use your personal data and the grounds on which we do so are set out below. We generally use personal data with your consent, except where the use of personal data without consent is permitted by law.
Providing you a service
We obtain and use your personal details and financial details in order to establish and deliver our contract with you and (if applicable) charge you correctly.
We obtain and use your medical information because this is necessary for medical, travel or assurance purposes.
Making healthcare accessible
Where you have provided your explicit consent, we will use your information (always having removed personal identifiers, such as your name, address and contact details) to improve our products and services, and our artificial intelligence system, so that we can deliver better healthcare to you and other ClearMe users. This information (with your personal identifiers removed in the way described above) may include your medical record (both records received and created by us), transcripts and recordings of your consultations, and your interactions with our artificial intelligence services, and other digital tools. This does not involve making any decisions which would have a significant effect on you – it is only about improving our products, services and software so that we can deliver a better experience to you and other ClearMe users, and help achieve our aim of making diagnostics affordable and accessible to everyone. Strict confidentiality and data security provisions apply at all times. This consent relates to information that can identify you.
We may obtain and use data about your precise location where you give your consent (through providing us access to your location through your App or browser settings or your address), for example, to help direct you to the nearest pharmacy as an example. We may also derive your approximate location from your IP address.
Keeping you up to date
We use your email address, phone number and/or details to contact you or present you with occasional updates and marketing messages where you have not opted out, based on our legitimate interest in marketing our services to you and subject to your right to opt out at any time.
As part of providing you with high quality preventative and occupational health care services, we may contact you by SMS, email and/or other means to offer you helpful information or invite you to make appointments, for example for free healthcare screening programmes.
Based on our legitimate interest in managing and planning our business, we may analyze data about your use of our products and services to, for example, troubleshoot bugs within the App or our website, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you that would have a significant legal effect on you – it is only about improving our App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
We also store your medical information, such as notes from consultations, recordings of our consultations with you as well as your interactions with our digital services including interactions with our questionnaires, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with lawful requests by regulatory bodies or as otherwise required by law or regulation.
Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.
4. Sharing your personal data with others
If you are a user of the ClearMe App provided by your employer, we may share this de-identified, aggregated data with third parties, such as your employer.
We may share your personal data with members of our corporate group to help us deliver our services to you.
We share personal data (with identifiers removed) with members of our corporate group to help us develop, improve and maintain our software and artificial intelligence system (where you have explicitly consented to this use of your data).
We may share your personal data with companies we have hired to provide services on our behalf, such as data hosting and processing, technical support, billing and payment processing, marketing and communications. These service providers are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
Where you access our services through public or private health insurance, and where you have given your consent, we will need to let your insurance company know your name, email address, policy number, location (based on IP address), demographic information, that you had an appointment with us, the date of the appointment, details of your diagnosis, prescription, pharmacy location, whether or not you had a referral made and other similar information about your appointment with us.
Information sharing with other healthcare providers
We will, where necessary for your treatment or care, share your information with your other health and social care providers. For example, your GP, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, diagnosis centers chosen by you for the purpose of imaging requests, and other health and care bodies. This may include sharing information with such services for safeguarding purposes in accordance with our legal or professional obligations.
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.
Except as described above, we will never share your personal information with any other party without your consent.
We retain your personal data and medical records for as long as necessary to provide the services you have requested and otherwise in accordance with legal, regulatory and self-regulatory requirements.
6. Data storage, security and transfers
We do not store your personal health data on your mobile device. We store all your personal health data - including your primary care information and diagnostic information, on secure servers.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
We do not store any credit or debit card information. Payments are processed via a third-party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.
Your data may be processed stored or accessed by ClearMe or our service providers from inside or outside of Canada, including the European Union, the United States and other countries. In either case, personal data will be protected in accordance with data protection law and subject to strict safeguards. For example, when we do transfer personal data outside of Canada, we strive to minimize the amount of personal data that we transfer. Notwithstanding these safeguards, while outside of Canada, personal data may be accessible by foreign government agencies under applicable law.
7. Your rights
As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting ClearMe at email@example.com.
You may also have the right to:
Request access to the personal data we hold about you. Recordings of your appointments with us and other medical notes can be accessed by request. For any other information, you can make a request by email;
Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
Ask us to restrict our processing of your personal data or object to our processing; and
Ask for your data to be provided on a portable basis.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org or by mail using the details provided below:
1315 Lawrence Avenue East., Unit 312, Toronto, Ontario, M3A 3R3, Canada