SEAMLESS PRIVACY POLICY

Your privacy is very important to us. This Privacy Policy is both an agreement hereby entered into by you and Seamless Mobile Health, Inc. (“Seamless”, “we”, “us”, “our” or other similar terms), and also a policy that describes how our services handle and secure the information we collect through the Seamless Mobile Health platform (the “Platform”, as defined in the End User License and Services Agreement). By accepting our privacy policy during registration for the Platform, or by visiting and/or using the Platform, you expressly consent to our collection, use and disclosure of your information as set out in this Privacy Policy. If you do not agree to these terms, do not use the PLATFORM.

INTRODUCTION

The Platform includes healthcare software and services that allow you to complete health questionnaires, track your self-management tasks and access patient education.

 

The information that you generate on the Platform may be provided to your health care providers, depending on how they choose to use the Platform.

HOW WE COLLECT INFORMATION

Any information that you provide to the Platform is safeguarded in accordance with applicable laws. The following describes the information collected by the Platform:

Personal Information

We collect Personal Information, which may include but is not limited to your name, telephone number, and email address, in order to create an account and provide you with the Platform. Depending on how your healthcare provider configures the Platform, this may change the type of Personal Information we collect. Depending on how you use the Platform, you may also choose to provide similar Personal Information about caregivers in order for them to also access the Platform.

Health Information

We collect the Health Information you provide to the Platform, including but not limited to, your surgeon, your surgery date and the information you record using our Platform, including but not limited to your responses to health questionnaires and your completion of tasks,.

Usability Information

We collect Usability Information from your activity on the Platform for the purpose of operating and improving the Platform, including but not limited to, the buttons you click, the content you view, the features you use, how long you spend on each page of the Platform, the date and time of when you use the Platform and other information about how you interact with the Platform.

By virtue of using the Platform, you are consenting for your Personal Information, Health Information and Usability Information to be collected and used by Seamless in the manner outlined below.

HOW WE USE INFORMATION

We seek to limit our exposure to the Personal Information we collect.  However, we may use the Personal Information, Health Information and Usability Information we collect for any purpose related to your access and use of the Platform and our maintenance and development of the Platform, including but not limited to:

Š      operate, maintain, manage and administer the Platform, including processing registrations, and providing customer support;

Š      respond to questions and communications, which we retain in the ordinary course of business;

Š      safeguard and protect our Platform, the information they safeguard, the rights of third parties and in response to legal process

Š      facilitate communication between you and us, your health care team, physician, or hospital, and any other individuals or entities in connection with your use of the Platform;

Š      improve the Platform and monitor our services, including without limitation, analysing the performance and effectiveness of the Platform, and identifying your needs and preferences.

HOW WE DISCLOSE INFORMATION

By virtue of using the Platform, you grant us the permission to disclose your Personal Information, Health Information and Usability Information to any individual or entity that may assist us in providing you with access to and the use of the Platform, including, without limitation, to:

Š      your caregivers who you consent to be involved in your care;

Š      your treating physician, hospital, other members of your health care team, which may include providing the data to your health care provider’s electronic medical record systems;

Š      the pilot or research study team who you consent to have access to this information for research purposes (should your healthcare team be utilizing this information as part of a research study);

Š      third party service providers, business partners, or other trusted individuals and entities that may assist us in providing you with access to, and use of, the Platform, who will be under an obligation of confidence in respect to your Personal Information, Health Information and Usability Information;

Š      third parties in connection with a sale or transfer of some or all of the shares or assets of Seamless or in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, who will be under an obligation of confidence in respect to your Personal Information, Health Information and Usability Information; and

Š      any individual or entity if required by applicable law or to cooperate with by law enforcement if permitted by applicable privacy laws.

To render the services described in the End User License and Services Agreement, your Personal Information may be transferred, accessed and/or processed by us, our affiliates and other third party service providers in Canada or the United States to the extent permitted by the applicable privacy laws.  Your Personal Information may be subject to the laws of the jurisdiction to which the Personal Information was transferred, accessed and/or processed; and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in that jurisdiction in accordance with the laws of that jurisdiction.

HOW WE USE AGGREGATED INFORMATION

We may use, and disclose (to a third party) aggregated and de-identified Health Information and Usability Information from the Platform, such that it is not associated with any individual account that personally identifies you (“Aggregated Information”). We reserve the right to collect, use, disclose, distribute and otherwise exploit any and all Aggregated Information to the extent that such data is not linked to any particular individual.

Accessing and Updating Your Information

If you discover unwanted or incorrect Personal Information and Health Information associated with your Seamless account, you should contact your healthcare provider who will then communicate with Seamless to potentially remove or correct such information. We will make reasonable efforts to promptly remove or correct such information so long as it is information within our control and generated as a result of the Platform.  Please understand that removal of unwanted Personal Information and Health Information, or the entry of inaccurate Personal Information and Health Information may mean we may not be able to provide accurate or timely Platform.

SECURITY

We have implemented security measures to protect against unauthorized use, misuse, or modifications to information stored on our servers, your computer, or your mobile device. We use software, encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorized access to your information.

Seamless has in place effective administrative, technological and physical safeguards to stop theft, loss and unauthorized access, copying, modification, use, disclosure or disposal of information. These safeguards are consistent with industry practice.

SEAMLESS’ PERSONNEL

Seamless will ensure that its personnel are aware of and agree to be bound by the privacy laws applicable to Seamless’ business.

THIRD PARTY PRIVACY POLICIES

We do not have control over the privacy policies and practices of third-party websites.  There may be links to other websites and pages provided by third-parties on our Website and/or the Platform.  Any information you choose to provide to a third-party is provided directly to that third-party and is subject to that third-party's privacy policy. We are not responsible for, nor do we endorse, the privacy policy or privacy practices of other web sites and third-parties.

UPDATING THIS PRIVACY POLICY

We may occasionally update this Privacy Policy with or without notice to you. We encourage you to review this Privacy Policy from time to time to stay informed about how we are protecting the information that we collect.  If you continue to access or use our Platform, or any other related products and services after we have updated the Privacy Policy, you accept and agree to such changes in the Privacy Policy.

CHILDREN

The Platform is not intended for children under the age of 13, without the consent and supervision of the parent or legal guardian.  We are in compliance with the requirements of COPPA (the Children’s Online Privacy Protection Act) and do not knowingly collect information from anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us information without their consent, please contact us. Access to and use of the Platform for minors must be through the parent or legal guardian’s account or with the parent or legal guardian’s express permission. If we become aware that a user of the Platform is under the age of 13 and has provided us with information without parental consent, we will delete such information and suspend access to the Platform.

CONTACTING SEAMLESS

If you: (a) have any questions, comments, or concerns about this Privacy Policy; (b) wish to review or make changes to your Personal Information or Health Information; or (c) wish to withdraw your consent in respect of the collection, use, or disclosure of your Personal Information or Health Information, please contact our privacy and compliance officer at: privacy@seamless.md.

If you withdraw your consent, you will no longer be able to access or use the Platform.  We may continue to use the information you previously provided to us to the extent required for us to enforce any contractual obligations that you may have to us or to the extent required by us to fulfill any of our contractual obligations. 

I HAVE READ, UNDERSTAND AND CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF MY INFORMATION PURSUANT TO THE TERMS OF THIS PRIVACY POLICY AND BY CLICKING ON THE “I ACCEPT” BUTTON BELOW, I AGREE TO AND SHALL BE BOUND BY THIS PRIVACY POLICY.

Up to date as of November 5, 2016