INSIG CORPORATION, TIA HEALTH and VIRTUALCLINIC+

Privacy at TIA HEALTH and VIRTUALCLINIC+

Updated: February 22, 2022
INSIG Corporation (“Insig”) and our parent company WELL Health Technologies Corp. (“WELL”, collectively “us” or “we”) are proud to offer you the TIA Health and virtualclinic+ webpages (the “Webpages”) and the associated TIA Health and virtualclinic+ online clinics and apps (the “Platforms”). Insig is committed to protecting your personal information and complying with applicable data protection and privacy laws. This “Privacy Policy” tells you how we do so.
THIS PRIVACY POLICY DOES NOT APPLY TO THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION BY HEALTH CARE PROFESSIONALS, INCLUDING PHYSICIANS, PHYSICIAN ASSISTANTS, AND THERAPISTS (“HCPS”) WHO USE THE PLATFORMS TO PROVIDE INDIVIDUALS WITH TELEHEALTH OR TELEMEDICINE SERVICES (“HEALTH SERVICES”) OR ASSISTING WITH THE PROVISION OF SERVICES (“SUPPORT SERVICES”). HCPS ARE SUBJECT TO THEIR OWN RESPECTIVE PRIVACY LAWS AND PROFESSIONAL REQUIREMENTS THAT GOVERN HOW THEY COLLECT, USE AND DISCLOSE PERSONAL INFORMATION. WE ENCOURAGE YOU TO READ THEIR RESPECTIVE PRIVACY POLICIES TO UNDERSTAND HOW YOUR PERSONAL INFORMATION (INCLUDING YOUR PERSONAL HEALTH INFORMATION) MAY BE COLLECTED, USED AND DISCLOSED.
We will update this Privacy Policy as necessary. Please check it regularly.

1. What information do we collect?
Webpages – Cookies
Unless you opt-out, our Webpage uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Webpages, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings, language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online interactions.
These Cookies helps us understand how you use the Webpages and the content of the Webpages in order to make improvements. We also may use these Cookies to promote our services through marketing and advertising. These Cookies may be accessed or disclosed to third-parties for the purpose of serving you relevant advertisements.
You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of the Webpages’ features, and may prevent us from providing you with the information and services you have requested.
Webpages – Contact-Us (online form, chat box, or e-mail)
When you submit a form on the Webpages, use our customer service chat messenger, or e-mail us with a question, we will collect personal information about you like your name, e-mail, phone number, and company name. This information will be used by Insig to communicate with you, provide you with the information you requested, and conduct appropriate follow-up.
Webpages – Direct marketing
If you sign up to receive direct marketing or promotional communications from Insig, we will collect your name and e-mail to inform you about Insig and the associated products and services. If you sign-up to receive newsletters or request additional information about WELL, we will share your name and e-mail address with WELL so they can provide you with the information you requested.
Platform – Provider Account Creation
When a HCP registers to become a HCP on the Platforms, we will collect personal information about the HCP like name, e-mail, phone number, billing details, information about their medical practice, and information about their registration with their respective provincial colleges. This information will be used by Insig to create an account for the HCP with Insig and the respective Platform (“HCP Accounts”), verify they have a valid license to act as a HCP with their respective provincial college, confirm their identity in the future, and to contact the HCP with respect to their use of the Platform.
Platform – Patient Account Creation
When an individual registers as a patient on the Platform to access Health Services with a HCP, we will collect their name, e-mail address, phone number, gender, date of birth, province/territory/state of residence, healthcare card, and credit card information or other billing information. This information will be used to create a user account for the individual (“User Account”). While we collect your credit card information, we use Stripe to process all payments, and as such, do not store such information.
The Health Services and Support Services are also available for use by children at the discretion of the HCP. For all patients under the age of 18, the holder of the User Account must be the patient’s parent or legal guardian. The parent or legal guardian may be asked to provide personal information about the minor in order to register them to use the User Account (“Registered Child”).
Platform – Patient Visits
Through the use of the Platforms, HCPs may collect and use personal health information about the patient. HCPs may collect personal health information verbally or by text, including: the reason for the patient’s consultation request, relevant health history, present condition or symptoms and current treatments. This information is used by the HCP to provide the Health Services and /or Support Services. The HCPs may log this personal information about the visit to the relevant User Account on the Platform, which may be referenced by them and other HCPs in the future. Patients are also able to log personal health information into their User Account to allow easy reference by HCPs.
HCPs who use the Platforms and interact with patients are governed by their own privacy policies with respect to the collection, use and disclosure of personal information. HCPs are required to keep logs of each patient visit within their own practice medical records off the Platform. We encourage you to read the HCPs privacy policies to understand how your personal information is collected, used, disclosed and stored.

2. Why do we use personal information?
We use your personal information to:
• manage our relationship with you and provide you with the information or services you request,
• create a HCP Account for HCPs interested in providing Health Services or Support Services through the Platforms,
• create a User Account for patients interested in receiving Health Services or Support Services through the Platforms,
• facilitate the delivery of Health Services or Support Services to patients by HCPs using the Platforms;
• conduct research and evaluate development on the Webpages, including analyzing testing data to improve our services,
• communicate with you regarding inquiries for information or customer service request or employment opportunities,
• detect, prevent or investigate security breaches,
• process insurance, credit card or other payment information as agreed to on the Webpages or through the use of the Platforms,
• protect our business, and
• maintain appropriate records for internal administrative purposes.
Insig reserves the right to aggregate and anonymize personal information (including personal health information) stored on its system and use such aggregated information as it sees fit.

3. Who do we share the personal information with?
We may share some of your personal information, including personal health information, with third-party service providers in order to operate the Webpages, the Platforms, or to provide you with the information you request. We only use service providers that ensure a comparable level of protection for your information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information only for the services requested.
Exceptionally, we may collect, use or disclose personal information without your consent in the following limited circumstances:
• when the collection, use or disclosure of personal information is permitted or required by law or by regulatory proceedings,
• in an emergency that threatens an individual’s life, health, or personal security,
• when we require legal advice from a lawyer,
• to protect ourselves from fraud,
• to a collection agency in order to collect our unpaid accounts, or
• to investigate an anticipated breach of an agreement or a contravention of law.
If we merge with another business, we will inform you of any impact on your personal information.
Webpage
We only share your personal information with service providers, including our affiliates, in order to operate the Webpages. This includes potentially sharing your personal information for:
• providing requested services or information,
• operating and optimizing the Webpages, or
• customer service.
Platform
We may share your personal information, including personal health information, with service providers, HCPs registered on the Platforms, and other third-parties you request (such as pharmacies or HCPs not using the Platforms). This includes sharing your personal information for:
• fraud prevention,
• payment processing via Stripe,
• providing requested services or information,
• operating the Webpages or Platforms,
• customer service, and
• facilitating the delivery of Health Services or Support Services.

4. How long do we keep personal information?
We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with applicable legal and regulatory requirements.
HCPs are subject to their own regulatory and professional rules which require them to retain personal health information, including personal health information they collected on the Platforms, for a minimum length of time. Please consult their privacy policy to understand how long they will retain your personal information.

5. How do we keep personal information accurate?
We take reasonable steps to ensure that any personal information in our custody is accurate and up-to-date but we mostly rely on you to notify us of any changes to personal information you provided us.

6. How do we protect your personal information?
We use reasonable and appropriate physical, administrative and technical measures (including encryption) designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with Insig or WELL is prohibited and constitutes grounds for disciplinary action.
HCPs who utilize the Platforms will have their own security policies and procedures to manage individual’s personal information (including personal health information). We recommend that patients read the HCP’s privacy and security policies to understand how they protect patient information.
Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee no breach will ever occur.

7. Where do we store personal information?
All personal information we collect is stored on secure servers in Canada.
However, personal information processed by our third-party service providers may be done outside of the jurisdiction where the data is stored. While being processed in another jurisdiction, such personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.
HCP’s using the Platforms are required by their respective provincial colleges to maintain appropriate records of each patient visit. This may involve them using electronic medical records or other digital services which store your personal information, including your personal health information, on servers outside of Canada. Please contact your HCP directly to learn more about how and where they store your personal information.
For more information on our service providers or where we store personal information, contact us at info@insighealth.com.

8. Links to third-party sites
Our Webpages or use of the Platforms may lead you to third-party websites, including websites advertising products or services. These websites are separate and distinct from Insig and WELL and have their own separate privacy policies. We are not responsible in any way for how these website collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies before providing your personal information to them.

9. Direct marketing
You may sign up to receive marketing or promotional communications from WELL. Where you have expressly consented, we may use your personal information to inform you about us and our products and our services, including promotional offers and events.
If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:
• using the unsubscribe feature found in our emails and other electronic communications, or
• contacting us via email at info@insighealth.com or marketing@well.company.
We remove your contact information from our distribution list as soon as you unsubscribe.

10. Consent
When you registered for an account with Insig to use the Platforms, we obtained your consent (or the guardian’s consent for a Registered Child) to collect, use or disclose your personal for the purposes of either (i) delivering Health Services and Support Services to you, or (ii) registering you as a HCP on the Platforms. HCPs are required to obtain their own consent for the collection, use and disclosure of patient’s personal health information during appointments. Consent can be provided orally, in writing, electronically, through an authorized representative, or it can be implied when the purpose for collecting, using or disclosing the personal information would be considered obvious, and the patient provides personal information for that purpose.

11. Your rights
You also have the right to:
• make a written request to access your personal information,
• request us to restrict our use or disclosure of your personal information,
• object to our use or disclosure of your personal information,
• request that we edit, but not remove, certain information (like an e-mail address),
• request that we transfer to another organization the personal information you have provided us,
• request us to delete the personal information we hold about you, and
• request we delete your account.
Contact us at privacy@well.company to exercise any of these rights. In order to confirm your identity, we may require you to answer some security questions or provide proof of identity. We will respond within 30 days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons. Please note, any requests with respect to your personal health information will be redirected to the relevant HCP.
We will address all requests with equal attention.

12. Contacting us
Accountability with respect to your personal information is important to Insig and WELL. In the event that you have any questions (including how personal information is managed by Insig or WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company.
If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.

Tia Health and VirtualClinic+ are joining to serve you better 
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