PocketMD Corporation together with our affiliates and
partners (“us”, “we”) respect your privacy and collect, use
or disclose your personal information (“PI”) and personal
health information (“PHI”) only in accordance with our
legislation (“Privacy Laws”).
through: (1) our websites (the “Websites”); (2) our mobile
applications (the “Apps”) and (3) our Virtual Care Platforms
(collectively, the “Platforms”), how we use PI and PHI and
the manner in which PI or PHI may be disclosed or shared by
us. The term "you" refers to the person or entity visiting
the Platforms, browsing or otherwise using the Platforms, or
receiving any services through the Platforms.
and disclosure of PHI by health care professionals ("HCPs")
or personal health assistants (“PHAs”) in the course of
providing telehealth or telemedicine services (“Health
Services”) or assisting with the provision of services
(“Support Services”) respectfully. HCPs are subject to their
own respective privacy laws and professional requirements
that govern how they collect, use and disclose PHI
The Platforms enable HCPs to receive your PI and PHI through
the Platforms and to provide Health Services to you. Your
use of the Platforms neither establishes nor governs your
relationship with the HCP. The Health Services provided to
you by HCP form a bilateral contractual relationship between
you and HCP and we are not parties to this agreement.
Consent for the collection, use and disclosure of personal
When you sign up for or use the Platforms we ask you to
By submitting your PI or PHI through the Platforms, you
consent to the collection, use, and disclosure of such
What PI and PHI do we collect and use?
Generally, you may browse our Websites or the Apps without
providing any PI. You are under no obligation to provide us
with PI, with the caveat that your refusal to do so may
prevent you from using certain portions of the Websites or
As set out above, HCPs and PCAs are responsible for the
collection, use and disclosure of PI and PHI as it relates
to the provision of Health Services and Support Services and
for ensuring that adequate safeguards are in place to
protect that information. The following overview provides
general information about how PHI or PI is collected and
used through the Platforms.
In order to use the Platforms and to receive Health Services
and Support Services you will be required to create a user
account (the "User Account") through the Platforms and be
issued a username and password login credentials ("User
ID"). We collect information such as your name, email
address, phone number, gender, date of birth and province or
territory to create your User Account. If you are issued a
User ID, you will be required to keep your User ID secure.
The Health Services and Support Services are also available
for use by children at the discretion of the HCP or PHA. For
all patients under the age of 18, the holder of the User
Account and User ID, must be the patient’s parent or legal
guardian. You may be asked to provide PI or PHI about your
child in order to register them to use your User Account
Provision of Health Services and Support Services
We collect PI or PHI on behalf of the HSP or PHA when you
request Health Services or Support Services to facilitate
the provision of those services and to assist you in
connecting with the HCP of your choice.
We collect your provincial health card number in order to
bill provincial health plans for those services that are
eligible for coverage by provincial health plans on behalf
of the HCP and/or your financial information to facilitate
payments in respect of your use of the Platforms or the
receipt of any services through the Platforms.
HCPs and PHAs collect and use PI and PHI about you or a
Registered Child in order to provide you or your child with
Health Services and/or Support Services. HCPs and PHAs may
collect PHI about you verbally or by text, including the
reason for your consultation request; relevant health
history and present condition or symptoms. The HCP may
access PHI that you have entered or uploaded to your profile
and medical records or information created during earlier
interactions through the Platforms with other HCPs or PHAs.
HCPs and PHAs must comply with professional regulatory
requirements, including as it relates to confidentiality and
privacy and record keeping, as well as privacy laws.
HCPs may create information such as prescriptions, sick
notes and other notes about your interaction with them via
There are a number of optional services that may be provided
through the Platforms, where authorized. We may collect and
use your PHI or PHI to provide you with services that you
request us to perform on your behalf, e.g., securely faxing
your prescription to your chosen pharmacy, a summary report
about your Healthcare Services to a physician of your
choice; open an account for you with a prescription delivery
service; and, where available, securely transmit your
information to the prescription delivery service
(collectively, "Platform Services").
How do we use your PI and PHI?
We use your PI and PHI for the purposes for which it was
collected, as well as other purposes for which you have
given consent. In addition to those purposes set out above,
this includes, but is not limited to, the following
Administration of your User Account
Marketing: In accordance with anti-spam laws, we obtain
your consent in order to send you commercial electronic
messages.We do not share email addresses or other contact
information with third parties without your permission.
Notifications: We will ask you if you wish to receive
notifications about services that you request. If you
agree, we will send you email or text messages to we
notify you about the status of your consultations and
other requests, such as prescription orders.
We also may use your PI or PHI to comply with our legal
obligations, resolve disputes, and enforce our agreements
and as required and/or permitted by applicable privacy laws.
Disclosing PI or PHI to third parties
We will not disclose, share, sell or rent your PI or PHI
with or to any third party, except with your written consent
or as required or permitted by privacy laws. We may disclose
your PI or PHI as we deem necessary, in our sole discretion,
to comply with any applicable law, regulation, legal process
or governmental request.
In some instances we may retain other companies and
individuals to perform functions on our behalf, including,
but not limited to website developers, service and
technology providers. Third parties may be provided with
access to your PI or PHI to perform the functions for which
they have been retained. Our agreements with third parties
will not permit them to use your PI or PHI for any other
purposes and commit them to comply with applicable data
We have partnered with third parties that license our
Platforms, including telemedicine platforms accessible
through the apps of such third parties and content and
services that support such apps. To use our Platforms as
provided under license by such third parties, you must agree
to all of the terms and policies such third parties impose
upon such Platforms and such third parties bear all
liabilities for your use of the Platforms, including as it
relates to your PI and PHI
Only HCPs and PSAs have access to your PI and PHI. HCPs and
PHAs may disclose PHI about you, including to your emergency
contact, if they believe that you are dealing with a medical
emergency during a consultation and disclosure is necessary
in order to eliminate or reduce the risk of serious harm.
All PI and PHI collected on the Platforms is securely and
digitally stored on servers physically located in Canada.
The Platforms are secured through encryption technologies
and only you and your HCPs and PHAs have access to your PI
and PHI. PHI created in connection with the provision of
Health Services is managed by the HCP in accordance with
applicable privacy legislation. The Platforms are licensed
by us to your HCP and are used by your HCP to communicate
We use physical, organizational and technical
industry-standard security safeguards commensurate to the
sensitivity of data collected, used or disclosed such as
encryption in transit and at rest. We use a variety of
technologies and procedures to help protect the security of
your PI and PHI from unauthorized access, use, or
We have implemented and maintain reasonable and appropriate
security measures, procedures and practices to protect
against the loss and unauthorized access, use, modification,
destruction or disclosure of your PI and PHI while it is our
custody or under our control.
Although we use advanced encryption technology and other
security protocols to protect your PI and PHI and the
privacy of the Health Services and Support Services with
HCPs and PHAs, in using the Platforms there are inherent
risks to any technology however remote that could cause
security protocols to fail or to be breached and which could
result in the unauthorized collection, use or disclosure of
your PI and/or PHI.
Retention of PI and PHI
We will retain your PI and PHI on the Platforms until such
time as you or we terminate your User Account. On
termination, you will have an opportunity to print or make
copies of any PI or PHI held in the Platforms, provided that
we have the appropriate authorization from the applicable
HCP and/or PHA relating to the Health Services or Support
How can I access or correct my PI or PHI?
You can add, edit, or delete optional information appearing
in your User Account at any time in your account settings.
You can edit, but not remove, certain information (like an
email address or any information pertaining to the
cumulative patient profile).
In connection with the provision of Health Services, you
have additional rights under applicable privacy laws. You
may request access or correction to your health records,
withdraw your consent or request limits on the collection,
use or disclosure of your PHI for health care purposes by
contacting your HCP.
We are committed to protecting the privacy of children. The
Platforms are not intended or designed for children. We do
not collect PI from any person we actually know is a child.
Where applicable, a Registered Child may use the Platforms
through their parent or legal guardian.
A "cookie" is a data element that a website can send to your
browser, which may then be stored on your system. The
Platforms use different kinds of cookies and/or use services
which use “cookies”. The cookies used by the Platforms do
not contain any PI or PHI about you, but they may identify
your specific computer or mobile device. We do not save PI
or PHI on cookies without your permission.
evaluating usage of the Platforms, to improve our Platform
and to compile reports on Platform activity. We may also use
cookies to track activity and click-through behavior to
better understand your preferences and browsing habits, and
to provide a more personalized experience while visiting the
Platforms, and for more personalized email alerts.
Most browsers accept cookies automatically, but can be
configured not to accept them or to indicate when a cookie
selecting the appropriate settings on your browser. However,
please note that if you do this, you may not be able to use
the full functionality of the Platforms.
Analytics and Interest-Based Advertising
Our third party vendors or service providers may also use
cookies and web beacons to measure the effectiveness of our
ads and to determine the content and advertising to offer
you based on your interests. To support these activities,
we, our service providers, and business partners may use
information about your visits to our Platforms. You may opt
disabling cookies on your browser. Please note that even if
you choose to disable cookies you will still see
advertisements while browsing online. However, the
advertisements may be less relevant to you and your
We may also use third-party service providers to monitor and
analyze the use of our Platforms. Google Analytics is a web
analytics service offered by Google Inc. (“Google”) that
tracks, monitors and reports traffic on our Platform. Google
tracks information like (i) your IP address; (ii) the type
of web browser and operating system being used; (iii) the
pages of the Platform that you visit; and (iv) other
websites you may have visited before visiting our Platform.
Google may also transfer this information to other third
parties where they are required to do so by law, or where
such third parties process the information on their behalf.
You can opt-out of having your activity on the Platforms
made available to Google Analytics by installing the Google
Analytics opt-out browser add-on. The add-on prevents the
from sharing information with Google Analytics about a
visitor’s activity. For more information on Google’s privacy
practices, please visit:
Where applicable, we will seek your express consent to
contact you, including by way of commercial electronic
messages. This consent is sought by PocketMD and you can
contact us at email@example.com. You can unsubscribe at any
time from receiving commercial electronic messages by
following the instructions in the message.
Even if you have opted out of receiving marketing
communications from us, please be aware that we may still
contact you for other purposes. For example, we may contact
you to provide communications you have consented to receive,
regarding the services we provide to you, or if you contact
us with an inquiry.
Third- Party Sites
The Platforms may contain links to other third-party sites.
When you click on one of these links you are visiting a
website operated by someone other than us and the operator
of that website may have different privacy policies. We are
not responsible for the individual privacy practices of
those sites. We encourage you to investigate the privacy
policies of these third-party operators.
All matters relating to your access or use of the Platforms
shall be governed by the laws of the Province of Ontario and
the laws of Canada applicable therein, without regard to
principles of conflicts of law. You agree and hereby submit
to the exclusive jurisdiction of the courts of the province
you reside in with respect to all matters relating to your
access and use of the Platforms, as well as any dispute that
may arise therefrom.
Should you have any questions or concerns about this Privacy
Policy or our practices, you may contact us at
You may also contact the Office of the Privacy Commissioner
of Canada or provincial
Information and Privacy Commissioner (as applicable) with
any questions or concerns
time and such modifications shall be effective immediately,
as of the date indicated below