Privacy Agreement for Orbis Health Inc.

www.orbishealth.ca

Please read this Privacy Agreement carefully before using www.orbishealth.ca (“Website”), an Internet site maintained by Orbis Health (“Orbis”). Your use of the Website is subject to your acceptance of these Terms.

Orbis has created this Privacy Agreement to help demonstrate its commitment to privacy. This Agreement describe Orbis’ information gathering and dissemination practices for the Website.

Privacy Policy

The Orbis Privacy Policy was updated on December 9th, 2018. The words and phrases used in this Policy have the same meaning as in Orbis’s Terms of Use. You can also find a list of definitions at the bottom of this Policy or if you still have questions, contact our Chief Executive Officer as indicated below.

Orbis Corporation (“Orbis”, “we”, “us”) uses a number of safeguards to protect the privacy of Users of the Orbis Platform and the confidentiality of their Personal Information including Personal Health Information (collectively referred to together in this Privacy Policy as “Information”). When discussing Healthcare Services, Information typically refers to Personal Health Information (“PHI”), and when discussing Informational Services, Information typically refers to information that is not specifically about you or your health, such as information in questions you would be comfortable asking of an expert during the call-in portion of a radio broadcast on health-related matters. PHI is not required for Informational services, and we advise you to not to submit PHI in the course of accessing Informational Services.

The agreement between Orbis and physicians providing services through the Orbis Platform, (Orbis Health Physician Service Agreement) and the Terms of Use for the Orbis Platform explain the services that Orbis provides to Authorized Physicians and to Users respectively. The agreement between Orbis and Non-Physician Providers providing services through the Orbis Platform, (e.g. Orbis Health Clinician Service Agreement) explain the services that Orbis provides to Authorized Non-Physician Providers and users, respective.

This Privacy Policy (“Policy”) summarizes how Orbis collects, uses, discloses, retains, disposes of, destroys and protects Information as well as Data (information that does not identify an individual) in the course of providing our services. We are committed to complying with this Policy and with applicable Provincial and Federal privacy legislation.

Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Physicians or Authorized Non-Physician Providers. Authorized Physicians and Authorized Non-Physician Providers are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use and retain in the course of providing services through the Orbis Platform. Please feel free to ask any Authorized Physician or Authorized Non-Physician Provider to whom you are referred if you have questions about how he or she will treat your Information.

Collecting and using Information

Orbis collects and uses Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes. For example, we do not record the audio or video portions of interactions between Users and Authorized Physicians and between Users and Authorized Non-Physician Providers through the Orbis Platform.

As mentioned, Authorized Physicians and Authorized Non-Physician Providers are responsible for their collection, use, disclosure, retention, destruction and protection of Information. As a result, the following description is an overview only of the use generally made of Information for the purpose of providing services through the Orbis Platform. A particular Authorized Physician or Authorized Non-Physician Providers may or may not chose to collect or use Information as described below in connection with a particular interaction with a User.

Healthcare Services

Authorized Physicians and Authorized Non-Physician Providers may collect Information about you or any Registered Dependent (as defined below) when you provide it during a Healthcare Services consultation (e.g., verbally or in texts), by viewing the Information that you have entered or uploaded to the Orbis Platform, by creating or compiling Information in the Orbis Platform and/or any other platforms or programs Orbis uses to deliver its Services (e.g. Trioova). Information that will be available to Authorized Physicians and Authorized Non-Physician Providers includes: the details that you provide in your appointment booking or consultation request; information you’ve entered or uploaded to profiles and medical records; information created during earlier interactions through the Orbis Platform with other Authorized Physicians and/or Authorized Non-Physician Providers; the name, email address, phone number, address, city, province/territory, country and the service you’re requested that you provided when you registered or scheduled an appointment; and your contact information. Authorized Physicians and Authorized Non-Physician Providers use Information to provide you with Healthcare Services and/or Informational Services and, as with any healthcare provider, must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Physicians and Authorized Non-Physician Providers may create Information such as prescriptions, sick notes and other notes about your interaction with them through in-person visits (Home and Office) or through virtual visits over platforms service providers may use to deliver their service (e.g. Trioova). They may export or print copies of your Information that they collect. Authorized Physicians and Authorized Non-Physician Providers may, but are not required to email or text your emergency contact if they believe that you are dealing with a medical emergency during a consultation. You are responsible for advising your emergency contact that you are providing their name and contact information to Orbis and Authorized Physicians and Authorized Non-Physician Providers, and for obtaining any necessary consent from them for the provision and use of their information in connection with the Orbis Platform.

Informational Services

Authorized Physicians and Authorized Non-Physician Providers collect and use Information that you provide in the course of obtaining Informational Services, by viewing the information that you have entered or uploaded to the Orbis Platform and by creating or compiling Information in the Orbis Platform. The Information that they collect and use includes: the details that you provide in your request for Informational Services and information that you provided to register to use the Orbis Platform (name, email address, phone number, service requested and address/place of residence) to confirm your eligibility to receive Informational Services. Authorized Physicians and Authorized Non-Physician Providers are bound to comply with privacy legislation applicable to providers of Informational Services.

Provision of the Orbis Platform

We collect and use your Information to register you, create your User Account, authenticate you when you log in and personalize your experience while using the Orbis Platform and/or any other platforms or programs Orbis and its independent Authorized Physician and Authorized Non-Physician Providers uses to deliver its Services (“Other Platforms) (e.g. Trioova). You may choose to enter or upload and store your Information on platforms in which services are delivered by Authorized Physicians and Authorized Non-Physician Providers (e.g. Trioova) such as your Personal Health Information, medical records, and the name and contact information for your emergency contact.

We may use Information to help us create, develop, operate, deliver, support and improve the Orbis Platform, its content and advertising provided to you through it (Orbis’ and third parties’) unless you have decided not to receive such advertising.

Users eligible for Healthcare Services:

To request Healthcare Services, select your requested choice of Healthcare Services and/or Informational Services through our online appointment scheduling application or alternatively, through contacting us by phone or by email. You may also specify general details surrounding your concern at your own risk. We facilitate your disclosure to the Authorized Physician or Authorized Non-Physician Provider of that information, along with your contact information, address, and any other PHI you disclose to determine whether your request is eligible. Once the Authorized Physician or Authorized Non-Physician Provider confirms that your request is eligible, we complete the referral (“Referral”). The Orbis administrative team determines the most appropriate Authorized Physician or Authorized Non-Physician Provider suited for your needs. The Information you provided in your consultation request, your name and, if applicable, the name of the Registered Dependent for whom you’re seeking the consultation, is shared with the respective Authorized Physician or Authorized Non-Physician Provider. Unless you have elected to withhold access to information held in the Orbis Platform about you or any Registered Dependent, the Authorized Physician or Authorized Non-Physician Provider will be able to view it too.

We use your Information to text or email you to notify you about services that you request. For example, we notify you about the status of your consultations and other requests, such as prescription orders.

Users eligible for Informational Services

When you request Informational Services, you may specify any topics for which you are seeking education. On your behalf, we present the information that you provide to an Authorized Physician or Authorized Non-Physician Provider to determine whether your request is eligible for Informational Services. Once the Authorized Physician or Authorized Non-Physician Provider confirms that your request is eligible, we identify the Authorized Physician or Authorized Non-Physician Provider to you. The Orbis Platform presents to the Authorized Physician or Authorized Non-Physician Providers the Information you provided in your request for Informational Services and your name.

Communicating with you

We use your Information to text or email you to notify you about services that you request, for example, about the status of your request for Informational Services.
We may collect location data through the use of GPS technology and your IP address to support you in receiving services, e.g., ensuring you are connected to an Authorized Physician or Authorized Non-Physician Provider who is authorized to provide such services in the jurisdiction where you are located. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.

Medical emergencies associated with requests for Healthcare Services.

Should you submit Information about a medical issue, which is deemed an emergency by an Authorized Physician or an Authorized Non-Physician Provider prior to their acceptance of your request for Healthcare Services, Orbis reserves the right to contact you at any time using any of the contact information you have provided. This contact is strictly for the purpose of informing you that an Authorized Physician or Authorized Non-Physician Provider has viewed your anonymized request and has declined the request based on their belief that your symptoms may represent a medical emergency.

Updates and marketing

From time to time, we may send you service announcements, including policy updates and updates to our Terms of Use and software and keep you posted on our latest products and any upcoming events that may be of interest to you or apply to you. You may opt-out of receiving non-essential communications by logging in to your User Account and updating your preferences. For clarity, service announcements including updates to our policies and Terms of Use and software are not considered non-essential communications.

Customer support

If you email, fax, write to us or complete a ‘contact us’ form on the Orbis Platform, we will collect the name and contact information that you provide to us and will use it to respond to you.

We only permit our Personnel to access Information to the extent necessary to perform their designated functions. We require them to protect the Information and maintain its confidentiality by complying with our policies, procedures and applicable law.

Disclosing Information

We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Physicians or Authorized Non-Physician Providers, emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Orbis’ legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person.

We may disclose Information for the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.

Retaining and disposing of Information

Unless we otherwise give you notice, we will retain your Information you submit when creating an appointment scheduling request on the Orbis Platform on your behalf until such times as you or we terminate your User Account. To ensure that Authorized Physicians and Authorized Non-Physician Providers may exercise any authority they have to withhold Information they compile in connection with Healthcare Services from patients under the law, you will be required to request any access you would like to notes made by an Authorized Physician or an Authorized Non-Physician Provider about your consultation from the Authorized Physician or Authorized Non-Physician Provider. As mentioned above, Orbis is not the custodian of Information held on the Orbis Platform; rather it holds Information on behalf of Users or Authorized Physicians and Authorized Non-Physician Providers.

Accessing and correcting Information

You may update and edit any of your Information except Information an Authorized Physician or Authorized Non-Physician Provider has viewed or created Information during a Healthcare Services consultation on programs or platforms which are used to deliver services (e.g. Trioova). Contact the Authorized Physician or Authorized Non-Physician Provider who provided the Healthcare Services to access or request the correction of Information in their notes on the Orbis Platform or that they hold in their medical records.

Your choices

You may choose whether to use audio, chat, or video for interactions with Authorized Physicians and Authorized Non-Physician Providers on programs or platforms which are used to deliver Healthcare and Informational Services (e.g. Trioova).

When seeking Healthcare Services, you may withhold Information, e.g., consultation information and medical records from Authorized Physicians and/or Authorized Non-Physician Providers. Please be aware that Authorized Physicians and Authorized Non-Physician Providers may be unable to provide you with Healthcare Services as a result. They will advise you of the implications of your choice.

When seeking Informational Services, you may elect to provide the level of information you’d like to disclose to the Authorized Physician and/or Authorized Non-Physician Provider.  PHI is not required for Informational services, and we advise you to not to submit PHI in the course of accessing Informational Services.

You may choose whether to receive communications by email.

Please contact us directly at ask@orbishealth.ca for assistance with using the privacy functionality or with any questions about using the Orbis Platform. Additionally, you may contact us at any time to: stop receiving e-mails or other correspondence from us, seek assistance with viewing and correcting Information, and close your User Account. To protect privacy, we may request information to verify your identity when you contact us.

Safeguarding Information

Orbis takes the security of your information seriously. We store your information in electronic format, using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. These security protocols are also applicable to the different platforms and programs Authorized Physicians and Non-Physician Providers may use to deliver Healthcare and Information Services. As mentioned, Orbis Personnel are obligated to protect Information by adhering to our policies, practices and applicable laws.

You also play an important role in protecting your privacy and the confidentiality of your Information. For example:

Create a strong and unique password for your User Account and update it periodically.
Do not share your User Account or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.
Log out of your User Account once you are finished using it, especially if you share your Device with anyone else.
Have a strong and unique password on your Device, too.
Choose a quiet, private location from which to receive services from Authorized Physicians and Authorized Non-Physician Providers.

Collecting, using and sharing Data

Orbis de-identifies Information on behalf of Authorized Physicians and Authorized Non-Physician Providers. Under their agreement with Orbis, Authorized Physicians and Authorized Non-Physician Providers permit Orbis to collect and use the resulting de-identified data for purposes that include: quality control activities designed to ensure use of the Orbis Platform in compliance with the Orbis Physician Services Agreement, Authorized Non-Physician Provider Agreements such as the Orbis Therapists Agreement,  and the Terms of Use; improving the Orbis Platform and more generally, the use of patient-initiated telemedicine services (through an understanding of usage and utilization patterns by Users and Authorized Physicians and Authorized Non-Physician Providers); conducting academic research and designing surveys (to be posted and completed at the discretion of Users). We will not use Data to re-identify individuals.

Cookies and similar technologies

The Orbis Platform, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. We use these technologies to better understand User behaviour, analyze trends, administer, personalize and improve the experience of using the Orbis Platform. You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, the Orbis Platform might not function correctly. At times, we may use third parties such as ad exchanges and data companies to serve our advertisements on the Orbis Platform. These companies may also use cookies and other technologies to report certain information about your visits to the Orbis Platform and other websites (such as web pages you visit from and your response to ads on the Orbis Platform) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Orbis Platform. By using the Orbis Platform and not turning off cookies, you are consenting to their use for the purposes described in this Policy. To learn more about advertising on electronic sites and opting-out of receiving ads, you can visit the Digital Advertising Alliance website at www.aboutads.info/choices/ or the Digital Advertising Alliance of Canada website at www.youradchoices.ca/choices.

Links and third party websites and applications

The Orbis Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.

Policy changes

We publish the current version of our Policy at www.getOrbis.ca/privacy. We reserve the right to amend our Policy at any time. Check back often to ensure you are aware of our current practices for collecting, using, disclosing, retaining, destroying and protecting Information.

Contact Us

If you have any questions, concerns or suggestions about our privacy practices, please contact our administrative team. Please include your name and contact information if you’d like us to respond to you.

Orbis Health Inc.

ATTN: ADMINISTRATION
ask@orbishealth.ca
(780)-851-5811
Edmonton, AB

Definitions

“Authorized Physician” means a physician who is registered to practice medicine in a Province or Territory of Canada, meets Orbis’s other criteria, and is permitted to provide Healthcare Services and/or Informational Services through the Orbis Platform.

“Authorized Non-Physician Provider” means an independent, regulated health professional (such as a clinical pharmacist, nurse practitioner, psychotherapist or a nurse) registered to provide healthcare in a Province or Territory of Canada, meets Orbis’s other criteria, and is permitted to provide Healthcare Services and/or Informational Services through the Orbis Platform.

“Data” means information collected or compiled through the Orbis Platform which has been de-identified.

“De-identify” in relation to PHI, means to remove information that identifies the individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify the individual.

“Device” means a mobile or desktop device owned or controlled by a User and used to access Orbis Physician Services.

“Health Care” means any observation, examination, assessment, care, service or procedure that is provided by a physician or a non-physician healthcare provider to an individual to diagnose, treat, or maintain the individual’s physical or mental condition, to prevent disease or injury to the individual, or to promote the individual’s health.

“Healthcare Services” means the provision of Health Care by an Authorized Physician or an Authorized Non-Physician Provider through the Orbis platform and/or any other platforms or programs Orbis uses to deliver its Services

“Informational Services” means the provision of general information about a disease or condition, rather than patient specific medical information, for educational purposes only and for clarity, not including a diagnosis, treatment or advice based on observation, examination or assessment of a particular patient.

“Orbis Platform” means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Physicians and Authorized Non-Physician Providers to provide Healthcare Services and Informational Services to Authorized Users.

“Personal Information” means information about an identifiable individual which is not PHI and which is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Orbis Platform.

“Personnel” in relation to Orbis, means its employees and agents including independent contractors and sub-contractors, for whom Orbis is responsible at law.

“PHI” or “personal health information” means information about an individual’s health or healthcare that is subject to Privacy Law and that is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Orbis Platform.

“Privacy Law” means the applicable legislation governing the collection, use, disclosure, and/or protection of PHI in the Province or Territory in which a User resides.

“User” means an individual who has registered and created a Orbis User Account in accordance with our Terms of Use and is thereby eligible to receive Healthcare Services and/or Informational Services through the Orbis Platform or any other platform or program Orbis and its independent Authorized Physicians and Authorized Non-Physician Providers uses to deliver Healthcare or Informational Services