Symbi Medical Privacy Policy
Symbi Medical Inc. (the “Symbi Medical”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information, including through our Symbi continuous care platform (“Platform”) that allows physicians (“Physicians”) and medical practice organizations (“Organizations”) to communicate with patients, (“Patients”) or in the case of minors or dependent patients, the parents or caregivers of patients (“Caregivers”), and provide digital care before and after a surgery, procedure or medical intervention (the “Services”).
The privacy of our users is of great importance to us. By visiting our website located at http://www.symbimedical.com/(the “Website”) or using the Symbi Platform or related Services in any manner (as those terms are defined in our Terms of Use), you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.
- WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals or information that is linked to an identifiable individual (“Personal Information”). This Privacy Policy does not apply to the practices of companies that we do not own or control, including those of Physicians who subscribe to the Services.
Physicians and Organizations are responsible for their own privacy practices when using the Platform, including getting consent to collect, use and disclose patient Personal Information and/or personal health information as may be required by law.
- COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
2.1. Physicians, Organization Managers, and Administrators
In order to use the Symbi Platform, Physicians, Organization Managers and Administrator users must have a valid Symbi account to log into Symbi (“Account”). When a user registers for Symbi, Symbi Medical collects:
- first and last names, birthday and email address;
- medical practice information, including: phone number, address, list of Physician’s specialties; and
- billing information, including credit card details and billing address.
Symbi Medical uses the Personal Information to uniquely identify you as a user, authenticate your Account access, and provide access to the Symbi Platform and Services, including access to the Organization’s account. Symbi Medical uses the billing information to process payments for subscription fees in respect of any paid subscriptions to the Services.
Symbi Medical administers surveys and collects responses from Physicians, Organization Managers and Administrator in order to improve user experience and the Symbi Platform and Services.
2.2 Patient Information
Patients must have a valid account in order to use the Services (“Patient Account”). Symbi Medical collects Patients’ names, email addresses and dates of birth from their Physician to allow the Physician to invite the Patients to use Symbi. When a Patient creates a Patient Account, Symbi Medical collects the following Personal Information:
- contact and demographic information, including first and last names, birthday, phone number, gender, address and email address;
- Procedure and medical information, including name of procedure, date and time of procedure, location of procedure, date of any related appointments, physicians performing procedure, specialty procedure belongs to; and
- Digital care and Physician advice, including prescriptions (i.e. medication(s), sprays, creams etc.) with associated dosages and instructions on use, activities to perform (ex. stretching, removing gauze, etc.) and when to do them, appointments with their dates, times, and locations.
The Personal Information above is collected from the Physician or Patient directly. If the Patient is a “dependent patient” user, Symbi may also collect Personal Information from that Patient’s Caregiver. If a Patient invites a Caregiver to be linked to the Patient’s Account, the Caregiver will have access to all of the Patient’s Personal Information, including medical information, in the Patient Account.
It is stored on behalf of the Patients so Physicians can maintain patients records. Information related to the Patient’s medical and procedure history is collected from the Physician and/or Patient to allow Physicians and Patients to utilize the Services.
Symbi Medical administers surveys and collects responses from Patients in order to improve Patient experience and the Symbi Platform and Services.
2.3 Caregivers
Symbi Medical collects Personal Information from caregivers of Patients who create an Account to access the Services on behalf of a Patient (“Caregivers”). When a Caregiver creates an Account, Symbi Medical collects the following Personal Information:
- contact and demographic information, including first and last names, birthday, phone number, gender, address and email address;
Personal Information of Caregivers is used to provide the Services to Caregivers on behalf of Patients.
2.4 Symbi Platform Usage Data
The Symbi Platform tracks certain information about usage of the software Platform, including the entry of Patient information, Platform usage (i.e. time spent on platform, frequency of logins, etc.)
(“Usage Data”). Symbi Medical uses Usage Data in order to diagnose technical issues with the Platform, monitor and improve Platform efficiency, and inform product development and Platform improvement. Aggregated and anonymized Usage Data may be used for marketing purposes to allow Symbi Medical and its partners to provide customized advertising and recommendations.
2.5 Website Data
Symbi Medical may also collect certain information from users of the Website through web forms that collect your first name, last name, email address, phone number, and may also collect Internet addresses, time spent logged into the website, and other usage data (“Website Data”). This information is logged to respond to user queries, provide ongoing email updates, and to constantly improve the quality of the Services.
The Website uses technologies such as cookies, beacons, scripts, and tags. These technologies may be used for analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. Various browsers may offer their own management tools for removing these types of tracking technologies.
In particular, the Platform utilizes session cookies to save browser sessions for automatic log in.
- STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Symbi Medical stores its Platform data, including Personal Information, using cloud services on servers located in Canada and the United States. By submitting Personal Information, you agree to this transfer, storing or processing of your Personal Information in Canada and United States by our service providers (including those listed on our Sub-Processors Page). You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those countries under lawful access regimes or court order.
- DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1. Service Providers and Business Partners
We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Symbi Platform and related Services. In particular, Symbi Medical uses cloud services provided by the Sub-Processors listed on our Sub-Processors Page., which service providers may be replaced or supplemented by Symbi Medical from time to time. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of software licensing, maintenance services, database management, Web analytics and general improvement of the Symbi Platform and related Services.
4.2. Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
4.3. With Your Consent
If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.
- RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.
- ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
- CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.
- ADDITIONAL INFORMATION
Questions regarding this Privacy Policy or Symbi Medical’s privacy practices should be directed to:
Attn: Privacy Officer
Symbi Medical Inc.
900 Lady Ellen Place
Suite #113
Ottawa, ON
K1Z 5L5
Email: cameron@symbimedical.com
Last Updated: July 16, 2019
