“LifePath Remote Patient Monitoring Platform” is a platform (the “Platform”), created by Elastic Care, which allows users of the LifePath Patient Application (the App”) to gather certain personal and health related information and communicate such data it to the user's chosen healthcare practitioners or professionals i.e. registered clinician or doctor (the “Clinician”). The App and Platform are used for the purposes of direct medical consultation (“Consultation”) between users and the Clinician they choose to have their information sent to. The Platform, the App, the website www.elasticcare.com (the “website”) and the information and services made available through these, are collectively referred to as the “Services”.
For the purposes of this Policy, “Personal Information” or “PI” means Personal Information about an individual which allows them to be identified. “Personal Health Information” or “PHI” means information about an identifiable individual that relates to the individual's physical or mental health. PHI includes name of the user, gender, date of birth, past medical history and treatments, allergies, medications taken, smoking status, symptoms, vital signs and symptoms experienced. PHI may be submitted by the user for review by their Clinician.
We take the privacy of our users very seriously and are committed to safeguarding your Personal Information and PHI. Accordingly, we make the following commitments to you, as a user of our services.
We may collect the following information from you when you download the LifePath App and register for a LifePath account (“Account”) or when you use the Services:
When you register for a LifePath Account, we will collect identification and contact information. When you use the App and the Platform, we will collect and store Personal Health Information and other PHI information for transmission, unaltered, to your designated Clinician. Your Clinician may or may not use the information you provide to assess your condition, exercise clinical judgement, make diagnoses and suggest possible treatment or remedial actions.
The Services made available via this App and Platform are offered free of charge to users. There are no fees for use of the App or the Platform. Please be aware, however, that your Clinician may charge you or your health insurance provider for any medical consultation or service rendered using the LifePath Service. Elastic Care has no involvement in such fees and receives no compensation or payment from users or Clinicians for providing the LifePath Platform, App or Service.
When you access and use the Services, we may automatically collect certain technical information about your visit, including the date, time, browser type, your internet service provider, your IP address, device information (including device identifiers), geo-location information, computer and network performance data, any URL that you are coming from and your navigation history. This information is gathered in order to customize your experience of the Services, to improve our Services and for research purposes only.
We will transmit and disclose your Personal Information, including PHI, only to the healthcare professional whom you designate as your Clinician, in the App. We collect such information from you, with the sole purpose of passing it on, unaltered, to the Clinician of choice.
If any information is required to be disclosed to a third-party, not associated with us or with LifePath, we will only make such disclosure after obtaining your express consent. Note, however, that your Clinician may provide information related to you, to other third parties in the course of their medical practice. We exercise no control or influence over this. If you wish that your Clinician should not share your PI or PHI with any third party, you should communicate this to your Clinician directly.
We do not provide you with any healthcare services and cannot guarantee the accuracy, fidelity, timely transmission or receipt of your Personal Information, including PHI to your Clinician or that your Clinician will take any timely or correct action.
Access to your Personal information will be logged and controlled. We will put in safeguards, and perform audits to ensure that your Personal Information is accessed, read or retrieved only by persons specifically authorised to do so, that such authorization is issued only for reasons related to maintaining or improving the LifePath Platform and /or App and that the information is only accessed on a 'need to know' basis. We may retain your Personal Information on our customer support systems and software for the purposes of user technical support.
We may transfer your Personal Information, including PHI to a third-party service provider for processing and storage in Canada. Whenever we engage such a a third-party service provider, we will ensure that the information is properly safeguarded at all times at a comparable level of protection the information would have received if it had not been transferred.
We may use your Personal Information to detect, investigate, address and prevent fraudulent or illegal activities. We reserve the right to disclose your personal information as required by law, when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal process served on us and to defend against legal claims. These situations may include, but are not limited to, disclosing potentially life saving information during medical emergencies and reporting infectious diseases.
We may disclose and share your Personal Information to explore and/or undertake a corporate transaction, including a merger, acquisition, amalgamation, IPO, reorganization or sale of Elastic Care. Your Personal Information relevant to such transaction, will used and disclosed solely for the purposes related to the transaction and will be protected by security safeguards appropriate to the sensitivity of the information.
This section does not relate to your PHI, which will not be disclosed and will remain confidential.
Elastic Care does not retain your PI, PHI or other records beyond the periods described here. If you wish to have a copy of your patient information, you must obtain it directly from your Clinician or from the App where it is stored locally (i.e. on your mobile phone).
The information held in the LifePath App or Platform is only as accurate as the information what you enter into your App. We will not modify, correct, update, interpret or check for accuracy, any information you provide using the App, the Platform or your Service.
When conducting product development or research we will only use anonymized, de-identified and aggregated information.
Elastic Care is committed to information security and protects Personal Information and PHI through physical, technological and administrative controls and safeguards. We have implemented access and security controls at various levels, to protect infrastructure and applications against unauthorized access.
Secure Storage: We store all Personal Information and PHI in a secure, data centre in Canada, owned and operated by Pathway Communications, an affiliated company of Elastic Care. The Pathway data center carries the following certifications: PCI DSS (Payment Card Industry Data Security Standard), HIPAA compliance (Health Insurance Portability and Accountability Act), ISO 27002, ISO 27018, SOC 2 Types I and II, Tier III (Uptime Institute)
Privacy Policies and Training: Elastic Care has implemented written policies and procedures that specifically address the privacy and security of your PHI. All employees and contractors receive privacy training on Personal Information safety and risk mitigation and are legally bound by confidentiality and non-disclosure agreements.
There is no guarantee against data breaches. However, Elastic Care has taken reasonable measures to prevent a breach, as described above. In the event of a data breach, we will immediately apply remedial measures and notify users of the breach at the first reasonable opportunity.
If we decide to make material changes to this Policy, we will notify you and other users by placing a notice on our Website and App. You should periodically check the Website and the App for updates.
If you wish to contact us in respect of our privacy practices or this Policy please do so, by email to our Designated Privacy Contact at firstname.lastname@example.org . If we are unable to resolve your issue to your satisfaction, you may file a complaint with the local privacy authorities in your state, province or county or with the Office of the Privacy Commissioner of Canada.