Carepath respects the privacy of our application users (“user”, “you”). You have the right to know what we do with your information and the choices you have over your Personal Information. This privacy policy explains how Carepath (“we”, “us”, “ours”) will collect, use, disclose, and safeguard the information you provide through our application. This Privacy Policy may change from time to time.
How We Protect Your Privacy
We handle and protect your personal health information in accordance with Ontario’s Personal Health Information Protection Act, 2004 (PHIPA) and other applicable legislations. We provide training, follow established policies, and take other steps to ensure that our staff and anyone else acting on our behalf protects your privacy. For more information on our privacy practices, please see https://carepathdigitalhealth.ca/assets/privacy, or contact our Privacy Officer as listed at the bottom of this policy.
What Information We Collect
We may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you choose to use, and includes:
2.1 Personal Information You Provide to Us
In short: During your various interactions with the Carepath program, including the Application, you may be required to provide us with Personal Information. For example, we collect Personal Information when you create your account, complete your course work, or speak with your clinician. The Personal Information we collect may vary depending on what you choose to provide over the course of the program.
In Detail: the Personal Information you may provide to us directly are the following:
Name
Email address
Application User ID
Address
Phone number
Personal Health information, such as: diagnosis, treatment, medical records, goals of care, health card number, biologics (e.g., vital signs), mood, free text journal entries, fitness and activity information.
Photos
Videos
Voice notes
The information, as listed above, that you share with us will be used by Carepath to facilitate and support your progress through the Carepath program. While some information is required (such as name, User ID, email, and phone number) for participation in the program, other information is not required and you can share as much or as little as you prefer. 2
2 Personal Information We Collect Automatically When you Use the App
In short: During each of your visits to our sites and mobile applications, we collect information about your connection and your browsing activity through cookies. We also collect information related to Application diagnostics, such as crash logs, to ensure the Application is operating correctly.
In detail: Cookies give us access to the following Personal Information:
Identifiers of the equipment you use (IP address of your computer),
Type of operating system,
Type and version of the browser software,
Dates and times of connection to our services,
Address of the originating Internet page ("referrer"),
Browsing data on our services, content viewed;
Information relating to your use of our sites and applications, and
Information relating to the presence of cookies on your terminal.
Cookies can be implemented by us and also by third-party organizations that are our service providers (for example Google sets a cookie to help us measure our audience).
2.3 Mobile Device Access
We may request access to certain feature of your device, including camera Permissions, microphone permissions, files and documents.
We request access to the above listed device features to facilitate the provision of care to you. For example, you may choose to share a photo with your clinician or have a video call with them. Providing device access is not a requirement for participation in the Carepath program or for use of the Application as a whole, however, some features within the Application, such as video calls, will require you to permit access if you decide to use that feature.
2.4 Mobile Device Data
We may collect information from your mobile device, such as:
Platform (ios/android)
Device identifier
Device Notification tokens
IP Address
Location access (if turned on)
This information will be used to verify the identity of the device and ensure the smooth functioning of the Application. This information may also be used to determine an approximate geolocation for the purposes of identifying region specific technical issues, crash diagnostics, and app diagnostics.
2.5 Google Analytics
We make use of Google Analytics to monitor and analyze the use of our website. You can opt out from the use of Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add On. Google’s Privacy Policy is available here: policies.google.com/privacy.
Purpose for Collection, Use, and Disclosure of Personal Information
By reviewing and accepting this Privacy Policy, the Applications Terms and Conditions https://carepathdigitalhealth.ca/assets/privacy, and the Carepath Consent Form you review and sign during account creation, you have provided your consent for our collection, use, and disclosure of your personal health information for the following purposes:
To provide and assist in the provision of health care to you through our Carepath Application and program;
To manage the running of the Application and perform diagnostics and system maintenance.
To plan, administer, and manage the operation of our services and programs, including risk management and quality improvement;
For educational and training purposes for our care providers;
To conduct research activities as approved by a research ethics board;
To comply with legal and regulatory requirements; and fulfil other purposes that are permitted or required by law.
Carepath will make efforts to use de-identified or aggregate data whenever possible and will not use personal information when non-personal information will suffice.
Any use of your personal health information other than those mentioned above would require your express consent.
3.1 Disclosure of Personal Information
From time to time, we may communicate about your care with your other health care providers with your consent, such as your primary care physician. This disclosure is done for the purposes of providing you with treatment and care.
Carepath does NOT sell any of your personal information of use it for any purposes not listed above.
3.2 Transfers outside of Canada
All clinical and personal health information held by Carepath about you is stored within Canada on secure servers, and is not transferred, stored, or transited through another country.
In the event of an application error or crash, we may send personal information about your application and device information (as referenced in section 2.2. and 2.4 above) to our contracted third-party service provider, located in the United States. This is done for the purposes of generating a crash report and performing error diagnostics. This helps ensure that the application is operating correctly, and that any bug or errors can be promptly addressed to provide an improved experience for the user. Direct personal identifiers such as name, contact information, or the health information you provided is not part of this transfer and remains within Canada.
Your Rights and Choices
PHIPA provides you with certain rights related to your personal health information under our custody or control. Please communicate with our Privacy Contact for more information related to your rights:
To see and get a copy of your personal health information held by Carepath;
To ask us to make corrections to inaccurate or incomplete personal health information;
To withdraw your consent to our collection and use of your personal health information or its disclosure to other health care providers (subject to certain legal obligations); and,
To be informed if your personal health information is lost, stolen, or improperly accessed.
You can choose to delete your account at any time by following the link provided in you Apps user profile. As Carepath must adhere to PHIPA, there are legal requirements to retains certain information related to the care you received through the program. For more information on what information about you can be deleted, please contact our Privacy Officer.
For more information on how to exercise any of your rights, as listed above, please see https://carepathdigitalhealth.ca/assets/privacy or contact our Privacy Officer as listed below.
Our Privacy Contact
For more information or to raise a concern about our privacy practices, please contact our Privacy Contact:
Name: Sherry Hnatyshyn
Phone: 416-595-2720 #34830
Email: shnatyshyn@bayshore.ca
Mailing Address: 2101 Hadwen Road, Mississauga, ON, L5K 2L3
The Information and Privacy Commissioner of Ontario
The Information and Privacy Commissioner of Ontario is responsible for making sure that privacy law is followed in Ontario. For more information about your privacy rights, or if you are unable to resolve an issue directly with our Privacy Contact and wish to make a complaint, contact:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
Email: info@ipc.on.ca
Toll-Free: 1-800-387-0073
TDD/TTY: 416-325-7539