DermCafé Privacy Policy

 

DermCafé, and the professional entities to which it provides various business support services (“DermCafé” “we”, “us” or “our”), respects our customers’ privacy and takes great care to safeguard personal information, which includes personal health information. We believe that an important part of protecting privacy is to be clear about how we handle customers' personal information, and to make information about our approach easily accessible. We have developed this DermCafé Privacy Policy which sets the general principles that govern the collection, use and disclosure of our customers’ personal information and provide you with more specific details about our privacy practices supporting our health related products and services. This Privacy Policy is designed to inform you about how we collect, use, and share information about you when you access or use our website www.dermcafecanada.com (the “Site”) and the DermCafé mobile application (the “App”) upon its release. When we refer to the Site and the App together, we will call them the “Services.” Importantly, our Privacy Policy reflects the requirements of Canada’s applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, and applicable provincial health legislation (Personal Information Protection Act (PIPA)) along with our own continuing commitment to customer privacy. The bottom line is that we want you to understand the purposes for which we collect, use and disclose personal information and about our customers. The following is a summary of our privacy practices. 

By accessing or using the Services, you consent to our collection, use, and sharing of your information in accordance with this Privacy Policy. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

 

Collection of Information

 

Information That You GIve Us:

• Account Information

When you register for an account on the Services, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include your name, email address, username, password, and phone number. We also collect other information you provide as part of the registration process and the administration and personalization of your user experience, including demographic information such as your gender and age. We may combine this information with the personal information we collect from you. 

• Health Information

We may collect health information provided by you or generated through your use of the Services. This includes your health card number and version code, full name, phone number, email address, date of birth, gender, pharmacy fax number, past medical history, family history of melanoma, medications, allergies to medications, your main medical concern and its attributes (symptoms, duration, evolution, location, surrounding circumstances), and photos of your skin concern. This also includes details of your informational exchanges with participating doctors and their responses, suggestions, and guidance, and interactions with our digital services. 

• Transaction Information

We may collect and store information about the products you purchase and shipping and billing information. We may also collect limited payment information from you, such as payment method and payment card information; however, we do not store full payment card numbers and our third party payment processor securely processes all transactions.

 

Information We Collect Automatically

When you access or use the Services, the types of information we may automatically collect about you include: 

• Usage Information: We collect information about your usage of, and interaction with the Services. For example, we may collect information about how you communicate with other users, including their names, the content you create and share, and the metadata that is provided with the content.

• Mobile Device Information: We collect information about the mobile device you use to access or use the Sites, including the hardware model, operating system and version, mobile network information and information about your use of our mobile applications. With your consent, we may access and collect information from certain native applications on your device (such as your device’s camera, photo album and phonebook applications) to facilitate your use of certain features of the Services. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see “Your Choices” below.

• Log Information: When you access or use the Services, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Services. 

• Information Collected by Cookies: We and our service providers use various tracking technologies, including cookies, to collect information about you when you interact with our Services, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Services and your experience, see which areas and features of the Services are popular, and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

 

Information We Collect From Third Parties

We may receive information other people provide us, which may include information about you. For example, we may receive notes from Providers regarding their interaction with you during a Telemedicine Consultation. We may also collect information about you when you post content to our pages or feeds on third party social media sites, or when you make purchases using third party payment providers.

 

Use of Information

We may use your information for various purposes related to our operations and your use of the Services. For example, we may use your information to:

• Allow our Providers to provide safe medical care

• Provide, maintain and improve our Services and provide you with relevant information; 

• Send you technical notices, updates, security alerts and support and administrative messages;

• Respond to your comments, questions and requests and provide customer service;

• Monitor and analyze trends, usage and activities in connection with our Services;

• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of DermCafé and others;

• Communicate with you about products, services, offers, promotions, rewards and events offered by us and others, and provide news and information we think will be of interest to you;

• Maintain appropriate records for internal administrative purposes

• Link or combine with information we get from others to help understand your needs and provide you with a better experience; and

• Carry out any other purpose described to you at the time the information was collected.

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Communications

When you use our Services, we use your email address to communicate Service-related results and materials to you, and we will store your communication and our reply for any future correspondence. Beyond our initial reply, we will never use your email address to send you any unsolicited message or information, nor will we share it with or sell it to anyone else for such use. 

When you accept to receive information about our services, promotions, newsletters, press releases, and/or new offers, we use your email address and any other information you give as to provide you with the information or other services, until you ask us to stop (using the 'unsubscribe' instructions provided with each email communication). 

When you request information or other services from us, we use your email address and any other information you give us to provide you with the information or other services that you requested, until you ask us to stop (using the 'unsubscribe' instructions provided with each email, and/or on the site where you signed up, and/or as we otherwise provide), or until the information or service is no longer available. 

We will never use your email address or other information to provide you with any unsolicited messages or information (unless that is part of the service you are requesting), nor will we share it with or sell, rent or lease it to any third party for such use. 

 

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• When you participate in the interactive areas of the Services, information that you provide will be displayed to your health care providers, such as your name, content, health information and other information you choose to provide;

• With vendors, consultants and other service providers who need access to such information to carry out work or perform the Services on our behalf;

• With third party businesses to provide you with information about products and services that may be useful to you;

• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;

• If we believe your actions are inconsistent with our Terms of Use or other policies, or to protect the rights, property or safety of DermCafé or others;

• In connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing;

• Between and among DermCafé and any current or future parent, subsidiary and/or affiliated company; and with your consent or at your direction.

• We also may share aggregated or de-identified information, which cannot reasonably be used to identify you.

 

Third-Party Analytics

We partner with certain third-parties to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from DermCafé. The information collected by third parties using these technologies may be used to engage in analysis and reporting. These third parties may set and access cookies on your computer or other device and may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by DermCafé. In particular, the Services may use Google Analytics to help collect and analyze certain information

for the purposes discussed above. You may review Google Analytics’ security and privacy principles here (https://support.google.com/analytics/answer/2838718?hl=en&ref_topic=2919631) and opt out of the use of cookies in web browsers by Google Analytics by clicking here (https://tools.google.com/dlpage/gaoptout). 

 

How We Respond to “Do Not Track” Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Services do not respond to “Do Not Track” signals and consequently, the Services will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

 

Security

We employ reasonable security measures designed to safeguard and protect personal

information under our control from unauthorized access, use, and disclosure. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Service by Internet or email cannot be guaranteed. At your discretion, you may contact us at the mailing address listed at the end of this document.

 

Links to Third-Party Websites

We may offer you the opportunity to access third-party content, services, or products by linking to a third-party’s website. If you click on a third-party link, you will be directed to that third-party’s website. We do not exercise control over third-party websites and are not responsible for the privacy practices of such third parties. We recommend that you check the privacy policies of third-party websites before providing your Personal Information to them. The fact that we may link to a third-party website or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third

party, nor is it an endorsement of their privacy or information security policies or practices.

 

For emergency purposes. 

We may share personal information with a public authority, agent of a public authority or other party if, in the reasonable judgment of DermCafé, it appears that there is imminent danger to the life, health or security of an individual which could be avoided or minimized by disclosure of the personal information. 

 

Where required by law or applicable regulation. 

We share personal information with law enforcement, other government agencies or other parties if we are required to do so to meet legal and regulatory requirements; for example, if DermCafé is required to provide records to law enforcement in response to a valid court order. 

 

Some of the ways we respect your privacy 

• DermCafé has appointed a Chief Data & Trust Officer to oversee the DermCafé Data & Trust Office. The Office is responsible for maintaining an accountable privacy management program specifically designed to protect your privacy, and for setting policies and procedures to earn and maintain your trust in our data handling practices; 

• DermCafé maintains a robust information security governance program to protect your personal information with appropriate security safeguards. Our safeguards include administrative, physical and technical security controls. We protect the privacy of your personal information through contractual and other means when we are working with other companies;

• We may de-identify personal information for a variety of reasons, including to safeguard it, or where de-identified information will serve the purposes for retaining the information. For example, we may de-identify certain usage or health trend data for long term planning where individual customers' personal information is not required 

• We respond in a timely manner to your requests for access to your personal information; 

• We take privacy and security training and awareness seriously, and we use a variety of different methods to assist our DermCafé team members in respecting and protecting your privacy; 

• We have a team dedicated to responding to your privacy inquiries or concerns; the team can be contacted at info@dermcafecanada.com 

• We use cookies, in a limited manner and for purposes consistent with this Policy. For more information, please refer to our Cookies Notice. 

• Privacy legislation generally sets out certain circumstances under which organizations may collect, use or disclose personal information without consent. Examples include emergency circumstances or the investigation of a contravention of laws. Other than under such specified circumstances, DermCafé will not collect, use or disclose your personal information for any purpose other than those identified in our Privacy Code, your customer Service Agreement, or our Service Terms, except with your consent; 

• DermCafé will continue to review this Commitment to ensure it is relevant, remains current with changing technologies and laws, and continues to meet your evolving needs

 

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will provide notice of such changes, such as by sending an email notification, providing notice through the Services or updating the “Effective Date” date at the beginning of this Privacy Policy. We encourage you to review this Privacy Policy whenever you use or access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

 

Your Choices

Withdrawing Consent, Reviewing, Correcting, and Deleting Your Personal Information  You may have your name removed from one or more of our marketing lists, such as our telephone, mail or email marketing lists. We use these lists to inform you of relevant products, services and special offers that may be of benefit to you. 

You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit our ability to serve you and may force us to cancel some or all of the services you receive from us; 

You may access, correct, and/or request deletion of certain information that you have provided to us by contacting us through the Services, or by emailing Thai Phi, the DermCafé Privacy Officer, at info@dermcafecanada.com. If you email us, for your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will attempt to comply with any

reasonable requests for accessing, correcting, or deleting your information.

For further information about the above options please contact info@dermcafecanada.com. Unless you tell us otherwise, we will assume that we have your consent to continue to collect, use and disclose your personal information for the purposes we have identified to you.

 

Location Information

With your consent, we may collect information about your actual location when you use our mobile applications. You may stop the collection of this information at any time by changing the settings on your mobile device, but note that some features of our mobile applications may no longer function if you do so.

 

Native Applications on Mobile Device

Some features of our mobile applications may require access to certain native applications on your mobile device, such as the camera, photo album and the address book applications. If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting associated information. Note that you can revoke your consent at any time by changing the settings on your device.

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Information Flowing Outside of Canada

As part of our solution to delivering virtual care, some information associated to you or your devices may be flowing outside of Canada. This information is:

-your IP address

This is required by us in order to provide video visits and is only used for the purpose of providing this service.

 

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.

 

Push Notifications

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile applications.

 

Children Under the Age of 18

Our entire Privacy Policy applies for children under 18 as well. However, in order to accept participation of children under 18 in our medical services, we require consent from their parent or guardian, who will take responsibility for their entire involvement with DermCafé.

 

Contacting Us

We encourage you to contact us if you have any questions concerning our Privacy Policy or about our data collection practices. You may reach our Data and Privacy Officer at: info@dermcafecanada.com