Privacy Policy

Overview

This Privacy Policy outlines how personal health information (PHI) and personal information (PI) are collected, used, disclosed, and protected by charlie Medical It aims to ensure transparency and compliance with regulatory requirements, including HIPAA and PIPEDA, regarding the handling of PHI and PI.

charlie Medical reserves the right to amend our Privacy Policy at any time to account for changes in the Applicable Law, our practices, and the charlie Medical platform. Please check to see if we have amended the Policy since you last utilized our services to ensure you are aware, and agree to our current privacy practices.

Definitions:

Assessment: Evaluation of treatment requests carried out by a Licensed Healthcare Professional through charlie Medical.

Applicable Law: Legal statutes and regulations governing charlie Medical, Licensed Healthcare Professionals, and/or Users within their respective jurisdictions.

Licensed Healthcare Professional: Inclusive of "Licensed Healthcare Professionals," referring to Physicians and Nurse Practitioners authorized to practice medicine in Canadian provinces or territories.

Authorized Non-Practitioner Professionals: Regulated healthcare professionals, excluding Physicians and Nurse Practitioners, licensed to practice in Canadian provinces or territories.

Content: General health-related information disseminated by charlie Medical, intended for informational purposes only and not as a substitute for healthcare services.

charlie Medical Platform: Comprising the collective hardware, software, websites, content, products, and services owned and/or operated by us, facilitating the delivery of remote healthcare services to Users, among other functions.

Personal Health Information (PHI): Identifiable data pertaining to a patient’s health status, encompassing health history, medical care, and eligibility for healthcare service coverage.

Personal Identifying Information (PII): Identifying information; this may include, but is not limited to, name, address, and phone number‍.

User/Patient: An individual registered to use the charlie Medical Platform

charlie Medical Collection & Usage of Patient Information

Telemedicine Services

Personal information is gathered by Authorized Healthcare Professionals through the Platform. This information may be collected before the Assessment, during asynchronous chat, or via video call, depending on the type of Healthcare Service requested. Data accessible to Authorized Healthcare Professionals may include, but is not restricted to, your name, email address, phone number, gender, date of birth, province of residence, medical history, and emergency contact details (if provided) upon registration with charlie Medical.

Audio or video segments of Assessments are never recorded. Authorized Healthcare Professionals may generate data within the charlie Medical platform, such as prescriptions and Assessment notes.

Authorized Healthcare Professionals may, at their discretion, communicate with your emergency contact via email or text if they suspect a healthcare emergency. You are responsible for informing your emergency contact that their name and contact details are being shared with charlie Medical and Authorized Healthcare Professionals, and for obtaining any required consent from them for the utilization of that information in connection with the charlie Medical Platform.

charlie Medical Pharmacy Network

Licensed Non-Practitioner Professionals gather Personal Information from Users who opt to have prescribed treatments dispensed via the charlie Medical Pharmacy Network. This data may be collected through the Platform, telephone conversations, and faxed prescriptions. Information accessible to Licensed Non-Practitioner Professionals may encompass, but is not confined to, name, email address, phone number, gender, date of birth, mailing address, and relevant medical history.

As stipulated in the Terms of Service, by authorizing a "Third Party Payer" to cover fees for Healthcare Services or Other Services, you affirm to charlie Medical—and we will rely on this affirmation—that you consent to:

1. Inform the Third-Party Payer that you have sought Healthcare Services or Other Services, facilitating the charlie Medical Pharmacy Network to process payment for said services.

2. Notify the Third-Party Payer of any alterations to or termination of your access to the charlie Medical Pharmacy Network.

Third-Party Service Providers

charlie Medical uses third-party software and service providers for a variety of services including technical and operational support, as well as for marketing purposes. All charlie Medical affiliates and other third parties engaged to perform Healthcare Services or Other Services on our behalf are provided with Personal Information to the extent necessary. All service providers are contractually required to observe the intent of this Policy and our privacy practices.

For additional details about charlie Medical third-party service providers, please see our list of subprocessors.

Additional Services

charlie Medical offers additional services to aid in the delivery of Telemedicine services. These may encompass:

1. Receiving, assessing, and uploading laboratory test results onto the charlie Medical Platform.

2. Transmitting prescriptions via fax to pharmacies, both within and outside of the charlie Medical Pharmacy Network.

3. Providing medication delivery services to Users whose treatment originates from the charlie Medical Pharmacy Network.

4 Gathering requisite information for scheduled appointments.

Unless specifically indicated otherwise, these services are administered by charlie Medical employees ("Agents"). Both charlie Medical agents and third-party service providers, with whom we maintain contractual agreements, undergo mandatory privacy and security training to ensure adherence to charlie Medical's obligations regarding Information.

Other Data Collection and Utilization charlie Medical acquires and utilizes Information as necessary for various purposes, including but not limited to:

• Facilitating, managing, and determining eligibility for User access to the charlie Medical Platform.
• Monitoring purchases made through the charlie Medical Platform to facilitate refills and prescription renewals.
• Informing Users about programs and services that may be of interest.
• To gather User feedback regarding charlie Medical's operations.
• Assisting in the enhancement, evaluation, and development of the charlie Medical Platform and Content.
• Investigating legal claims.
• Employing measures for loss prevention, anti-fraud, and regulatory compliance.
• Pursuing other lawful purposes, for which charlie Medical may seek out consent.

Storage of Personal Information

Personal Information collected (collectively referred to as PHI and PII within this section as needed) is stored at the offices of charlie Medical and/or within data centers of our service providers located in Ontario, Canada.

The charlie Medical Platform is exclusively intended for and targeted at Ontario residents. By utilizing the charlie Medical Platform, you consent to the storage and processing of Personal Information in electronic form in Ontario, Canada. This process involves the utilization of computer systems with limited access and housed within facilities employing physical security measures.

Retention and Removal of Information

Unless otherwise notified, your Personal Information will remain on the charlie Medical Platform until you (or charlie Medical) decide to close your account. We will utilize and disclose Personal Information for as long as necessary to fulfill the purposes for which it was collected, and as permitted or required by law.

pon termination, you will have a limited period during which you can request a copy of your Information stored in the charlie Medical Platform. Following this period, we will securely delete the Information associated with your Account, except for Information mandated to be retained under Applicable Law or required by Authorized Healthcare Professionals in connection with Healthcare Services.

Disclosure of Information by charlie Medical

Personal Information (referred to as PHI and PII within this section as needed) is shared with meticulous care, adhering to appropriate privacy standards. Instances in which this sharing may occur include:

• Sharing with third-party service providers, with whom charlie Medical maintains contractual agreements, to facilitate the provision of Healthcare Services and Other Services.
• Disclosure to potential acquirers in connection with transactions involving the sale of some or all of charlie Medical.
• Sharing with emergency contacts as outlined previously.
• Compliance with Applicable Law or similar obligations mandating the provision of information.

Users who opt to have prescribed treatments dispensed via the charlie Medical Pharmacy Network may select to receive purchases via mail. Information provided to third-party shipping carriers may include:

• First and last name
• Shipping address
• Telephone number
• Email address

Disclosure is limited to the information that is needed to perform courier duties and provide you with your ordered products and services. charlie Medical is not responsible for any additional information you provide directly to third parties. Users must contact the third party directly to manage privacy preferences.

Accessing and Correcting Information

We are committed to maintaining your Personal Information (referred to collectively as PHI and PII in this section) as accurate and current as possible. We do not routinely update User Personal Information unless deemed necessary. Users are expected to provide updates to their Personal Information when necessary.

Users can submit a written request to review any Personal Information we have collected, used, or disclosed. We will provide such Personal Information to the extent required by law, presented in a format that is readily understandable. We aim to respond to each written request from Users within 30 days of receipt. If we are unable to meet your request within this timeframe, we will inform you in writing. You have the right to file a complaint with the Privacy Commissioner of Canada and/or the appropriate provincial privacy regulatory body.

We do not impose any charges for Users to access their Personal Information in our records or to access our privacy practices without first providing an estimate of applicable costs, if any. Users may be asked to provide sufficient information to allow access to the existence, usage, or disclosure of their Personal Information. Such identifying information will be used solely for this purpose.

Users can update or correct Information, except for Information viewed or created by an Authorized Healthcare Professional. To update or correct Information viewed by an Authorized Healthcare Professional or to request a correction to Information created by an Authorized Healthcare Professional, please contact us using the provided information so your request can be directed accordingly.

Safeguarding Information

charlie Medical has instituted physical, organizational, contractual, and technological security measures to safeguard Personal Information (referred to in this section collectively as PHI and PII) from loss, theft, unauthorized access, disclosure, copying, use, or alteration. Despite our diligent efforts and commitment to Information protection, we cannot guarantee the security or flawless transmission or storage of Information. The utilization of electronic means to transmit and store Information entails inherent risks. While these risks can be mitigated, they cannot be entirely eliminated, even with the implementation of suitable security measures, such as those employed by charlie Medical. These risks encompass interception, loss, corruption, unauthorized access to, use, and disclosure of Information, as well as delays in Information availability.

Access to your Personal Information is restricted solely to Personnel or third-party service providers with a bona fide business 'need-to-know' or whose responsibilities reasonably necessitate access to such information. Upon onboarding, Personnel are mandated to undergo privacy and security training and are required to adhere to our policies, procedures, and Applicable Law, as indicated in their employee agreement.

Users are advised to observe the following precautions to safeguard their privacy and information:

• Establish and periodically update a robust and unique password for your Account.
• Refrain from sharing your Account password with others. We never solicit User passwords; therefore, do not disclose them and promptly notify us if such a request is received.
• Log out of your Account promptly after use, especially on shared devices.
• Implement password protection on devices utilized to access your Account.

‍Cookies and De-identified Data

charlie Medical may gather and utilize data derived from de-identified Information, rendering it incapable of identifying a User ("Data"). This Data may be employed for monitoring Users' and Authorized Healthcare Professionals' compliance with the Terms of Service of the charlie Medical Platform, enhancing accessibility, and improving the experience for both Users and Authorized Healthcare Professionals. Additionally, we may utilize or disclose Data for product and marketing research purposes. We pledge not to utilize Data to re-identify Users or for any other purpose prohibited by Applicable Law. Any de-identification of Information will be conducted in accordance with Applicable Law.

The charlie Medical Platform, email communications, and marketing tools utilize "cookies" and other technologies like pixel tags and web beacons to assist in understanding User patterns and usage of the charlie Medical Platform, analyzing trends, and delivering, customizing, and enhancing the experience for both Users and Authorized Healthcare Professionals within the charlie Medical Platform.

We may also allow third-party service providers, such as analytics and advertising partners, to place cookies on your device to collect information about your online activities across different websites. These cookies are subject to the respective third parties' privacy policies.

Users have the ability to control and manage cookies through their browser settings. Most web browsers allow you to block or delete cookies, as well as set preferences for accepting cookies from specific websites. However, please note that blocking or disabling certain cookies may affect the functionality of our Website.

Consent for Collection, Use, and Disclosure of Personal Information

As a User of charlie Medical, your agreement with charlie Medical, along with your rights and responsibilities, as well as those of charlie Medical, are outlined in the Terms of Service and Consent to Use Virtual Care Tools and Electronic Communications.

Consent is obtained at the time Personal Information (referred to in this section collectively as PHI and PII) is collected, before its utilization or disclosure for any purpose. Consent may be given orally, electronically, or in writing. The type of consent required, whether expressed or implied, largely depends on the sensitivity of the information and reasonable expectations of the User in the given circumstances. We may rely on a third party to obtain your consent for sharing Personal Information with us. You have the right to revoke consent by notifying us, explicitly indicating that your personal health information not be used or disclosed for healthcare purposes without consent.

Contact Information:

charlie Medical Platform

For medical records access requests, Questions, concerns, complaints, or suggestions regarding the Terms of Use or Privacy Policy please direct to the charlie Medical Health Privacy Officer, Judy Graves, at Privacy@charlieMedical.ca

charlie Medical

Attention: Judy Graves, charlie Medical, Privacy Officer

5040 Mainway Unit 3D

Burlington, ON L7L 5Z1 Canada

charlie Medical Pharmacy Network Contact Information

Silver Scripts Inc.

‍Ontario College of Pharmacists Certificate of Accreditation No. 308397

5040 Mainway Unit 3D, Burlington, ON L7L 5Z1

Pharmacy Manager: Ludmilla Queiroz

Ontario Privacy Legislation:

Legislation:

Personal Health Information Protection Act

Complaints and/or concerns can be directed to:

Information and Privacy Commissioner of Ontario

By using our services you acknowledge that you have read and understood this Privacy Policy and agree to its Terms and Conditions.

charlie Medical Inc.

Burlington, ON L7L 5Z1

© 2024 charlie Medical Inc.

charlie Medical is not a pharmacy or a drug manufacturer.

By using this platform you accept our Terms of Service and Privacy Policy.