Last modified: February 21, 2022
TravelRx Education Inc. (“TravelRx,” “Us,” or “We”) operates a travel health consultation platform (accessible at travelrx.ca) (the “Platform”). TravelRx connects you, via our Platform, to independent physicians, nurses, pharmacists and pharmacies (collectively, “Healthcare Providers”) to provide you remote medical consultations and access to pharmacy services (collectively, “Healthcare Services”). The Platform may also connect you to independent pharmacies (“Network Pharmacies”) which may offer prescription services, pharmacy products and medical advice. TravelRx does not provide medical advice or medical information. The Platform is solely for educational purposes and is not a replacement for professional healthcare services. Medical advice or pharmacy services are available from the Healthcare Providers and pharmacies that are accessible on our Platform, but TravelRx does not accept any liability or responsibility for the medical information, services or products provided by the Healthcare Providers.
TravelRx respects your privacy and is committed to protecting it by complying with this policy. We take steps to ensure that the Personal Information (as defined below) that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Our privacy practices are consistent with the 10 Fair Information Principles and adherent to applicable federal, provincial privacy and health privacy laws.
This policy describes:
- How we collect, use, disclose, and protect the Personal Information of our customers and platform users (“you“).
- The types of information we may collect from you or that you may provide when you visit our Platform.
- Our practices for collecting, using, maintaining, protecting, and disclosing Personal Information.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including but not limited to:
- Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, government-issued identification, and any other identifier we may use to contact you. (“Personal Information“). Personal Information includes Personal Health Information (as defined below) but does not include de-identified or aggregated information that cannot be associated with a particular individual.
- Personal Health Information, that is regulated by health privacy legislation in the jurisdictions in which our Platform and Healthcare Providers operate (“Personal Health Information”). This may include information that we may collect on behalf of Healthcare Providers or receive from our Healthcare Providers to assist in their provision of Healthcare Services such as information relating to an individual’s physical/mental health, healthcare providers, healthcare related information such as personal health information numbers, medical history, lab results, prescription history, allergy status any other health information that we or our Healthcare Providers deem necessary for the provision of Healthcare Services.
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Platform feature.
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Platform, and usage details.
- Non-personal details about your Platform interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us via electronic, phone and fax interactions.
- Interactions with our independent Healthcare Providers. To facilitate the provision of Healthcare Services may collect information from your Healthcare Providers, Network Pharmacies as well as healthcare professionals in your circle of care.
- User contributions. You may also provide Personal Information for us to publish or display on public Platform areas, TravelRx social media, or transmit to other Platform users or third parties.
- Payment Information, we may collect information when you make purchases through the Platform. Our payment processor does not collect or store credit card information.
- Cookies and Automated Technologies, as you navigate through our Platform. Our Platform utilizes “cookies” and similar technologies thus we may automatically collect usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. We also use marketing analytics providers such as Google Analytics to collect information regarding visitors to our Platform. Certain advertising partners may use our automated collection technologies and cookies to advertise on our behalf. These automated collection technologies and cookies may collect non-personal information which may be used to provide you targeted advertisements within and outside of our Platform.
- Third parties or publicly available sources, such as Google reviews, forums, social media and other publicly available sources.
- For your safety and for quality control, we may record transcripts or videos of your interactions with Healthcare Providers.
HOW WE USE YOUR PERSONAL INFORMATION
We use Personal Information that we collect about you or that you provide to us, including any Personal Information:
- To verify your identity.
- To present our Platform and facilitate your interactions with our Healthcare Providers and Healthcare Services.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
- To allow you to access and if applicable, purchase Healthcare Services from our Platform.
- To carry out our obligations and enforce our rights arising from any contracts with you, including for billing, payment and collection or to comply with legal requirements.
- To notify you about changes to our Platform or any products or services we offer or provide though it.
- To improve our Platform products or services, marketing, or customer relationships and experiences.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may also use your Personal Information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your Personal Information in this way, please adjust your user preferences in your account profile or use the unsubscribe mechanism at the bottom of our e-mails. For more information, see Choices About How We Use and Disclose Your Personal Information.
DISCLOSURE OF YOUR PERSONAL INFORMATION
- To Healthcare Providers and Network Pharmacies to facilitate the provision of Healthcare Services.
- To our parent, subsidiaries and affiliates and for technical support purposes.
- To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
- To our network of Healthcare Providers and Network Pharmacies to promote their services. We contractually require Healthcare Providers and Network Pharmacies to keep Personal Information confidential and to use your Personal Information only for the purposes for which we disclose it to them. The use, retention, storage and disclosure of your Personal Information will also be governed by the respective privacy policies of our Healthcare Providers and Network Pharmacies.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TravelRx, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, patient safety and credit risk reduction.
- In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TravelRx’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by TravelRx about our customers and users is among the assets transferred.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Electronic Communications. You can opt-out of electronic communications via phone call, SMS and email via the unsubscribe link attached to our electronic communications.
- Promotional Offers from TravelRx. If we have sent you a promotional electronic communication, you may unsubscribe by clicking the unsubscribe link we have included in the electronic communication. This opt-out does not apply to information provided to TravelRx as part of a product purchase, warranty registration, product service experience, or other transactions.
CONSENT AND WITHDRAWING CONSENT
When you request Healthcare Services from Healthcare Providers, based on your actions, we will assume that you have provided us with express or implied consent to collect, use, share and store your Personal Information among our Healthcare Providers and Network Pharmacies that are involved in the provision of your Healthcare Services.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [insert customer service email]. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service and may delete your account. We will explain the impact to you at the time to help you with your decision.
Please note, even if you withdraw consent to the use of your personal information, certain healthcare providers and network pharmacies may be required keep your personal information on file to comply with applicable laws and regulations. Please visit their respective websites to read their privacy policies.
COOKIES AND TRACKING TECHNOLOGIES
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool.
You can opt-out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
DATA SECURITY AND STORAGE
The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology.
Your Personal Information is encrypted and stored on third-party cloud servers with data centers that are physically located in Canada. To ensure the availability and safety of your Personal Information, we may store your Personal Information on third-party cloud servers with data centers outside of Canada as well but only as minimally required.
The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.
We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
Personal Health Information is stored in Canada on secure, encrypted servers and is not transferred outside of Canada.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any medical, regulatory, legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Healthcare Providers and Network Pharmacies may be required by federal, provincial law and health profession regulations to keep records of your Personal Information as well as Personal Health Information for certain periods of time even after you no longer receive Healthcare Services. Please refer to the respective privacy policies of our Healthcare Providers and Network Pharmacies prior to accessing their services or providing them Personal Information.
USERS UNDER THE AGE OF MAJORITY AND MINORS
Our Platform is not intended for users under the age of majority in their respective jurisdictions If you are under age of majority in your respective jurisdiction, do not use or provide any information on this Platform or on or through any of its features on the Platform, make any purchases through the Platform use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a minor, we will delete that information. If you believe we might have any information from a minor, please contact us at [insert privacy officer contact email] and we will take steps to remove the data from our servers.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.
You can review and change your Personal Information by logging into the Platform and visiting your account profile page.
If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at [insert email for TravelRx Privacy Officer] to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the Personal Information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
[insert email for TravelRx Privacy Officer]
We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.