Privacy Policy

PRIVACY POLICY

INTRODUCTION
This Privacy Policy (“Privacy Policy”) describes the data protection practices of UBACARE, a division of NUYU Health & Wellness Inc., DBA, UBACARE “Your Intelligent Health Company” and their respective affiliates (collectively, “UBACARE”, “UBACARE LIFESTYLE”, “UBACARE MEDICAL”, “UBACARE PHARMACY”, “WE”, “US”, or “OUR” “THESE”), including when you visit any UBACARE website that links to this Privacy Policy (collectively, our “Websites”), use any affiliated mobile applications (the “Apps”), or otherwise provide data to UBACARE.  We refer to the Websites, Apps, and other services provided by UBACARE together in this Privacy Policy as the “Services.” This Privacy Policy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Use.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy (“Policy”) summarizes how UBACARE 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 UBACARE 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.

This Privacy Policy contains the following sections:

  • Collecting and Using Your Information
  • Disclosure of Your Information
  • Retaining and Disclosing Your Information
  • Accessing and Correcting Your Information
  • How We Protect Your Information
  • Retention of Your Information
  • Revisions to Our Privacy Policy
  • Contacting Us

COLLECTING AND USING YOUR INFORMATION
UBACARE 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.

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 UBACARE Platform.  An Authorized Physician or Authorized Non-Physician Provider 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 during a Healthcare Service consultation (i.e. verbally or in texts), by viewing the Information that you have entered or uploaded to the UBACARE Platform and/or by creating or compiling Information in the UBACARE Platform.  Information that will be available to Authorized Physicians and Authorized Non-Physician Providers includes: the details that you provide in your consultation request; information you’ve entered or uploaded to profiles and medical records; information created during earlier interactions through the UBACARE Platform with other Authorized Physicians and/or Authorized Non-Physician Providers; the name, email address, phone number, gender and date of birth and province/territory/state that you provided when you registered; and your emergency contact’s name and 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, referral notes, lab and/or imaging requisition and other notes about your interaction with them through the UBACARE Platform. They may export or print copies of your Information that they collect. Authorized Physicians and Authorized Non-Physician Providers may email or text your emergency contact if they believe that you are dealing with a medical emergency during a consultation but are not required. You are responsible for advising your emergency contact that you are providing their name and contact information to UBACARE 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 UBACARE Platform.

INFORMATION 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 UBACARE Platform and by creating or compiling Information in the UBACARE Platform. The Information that they collect and use includes: details that you provide in your request for Informational Services and information that you provided to register to use the UBACARE Platform (name, gender, date of birth and 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.

PROVISIONS OF THE 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 UBACARE Platform.
  • We confirm your eligibility to use the UBACARE Platform for Healthcare Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.
  • We collect your provincial health card number in order to bill provincial health plans for those services that are eligible for coverage by provincial health plans.
  • You may choose to enter or upload and store your Information in the UBACARE Platform such as your medical records, and the name and contact information for your emergency contact.
  • When seeking Healthcare Services, you may also choose to enter or upload and store Information about individuals for whom you have the legal authority to make decisions regarding their healthcare and for whom you have created a profile by providing their first and last name, gender and date of birth (each a “Registered Dependent”). We use their date of birth where applicable and your assertion of their relationship with you to confirm your eligibility to obtain Healthcare Services for them, and their eligibility to receive Healthcare Services.
  • We use Information that you enter, or upload, or which is created as part of an interaction with an Authorized Physician or Authorized Non-Physician Provider to make it available to you when you access your User Account.
  • We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.
  • We may use Information to help us create, develop, operate, deliver, support and improve the UBACARE Platform, its content and advertising provided to you through it (UBACARE’s and third parties’) unless you have decided not to receive such advertising.

Users Eligible for Healthcare Services

  • To request Healthcare Services, you select any applicable symptoms relevant to your request.
  • We facilitate your disclosure to the Authorized Physician or Authorized Non-Physician Provider of that information, along with age and gender to determine whether your request is eligible.
  • 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 UBACARE Platform presents to the Authorized Physician or Authorized Non-Physician Provider 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. Unless you have elected to withhold access to information held in the UBACARE 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.

Users Eligible for Informational Services

  • When you request Informational Services, you select 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 UBACARE Platform presents to the Authorized Physician or Authorized Non-Physician Providers the Information you provided in your request for Informational Services and your name.
  • 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.

Communicating with You

  • 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, UBACARE 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 Useand 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 Useand software are not considered non-essential communications.
  • If you email, fax, write to us or complete a ‘contact us’ form on the UBACARE 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

DISCLOSING YOUR 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 UBACARE’s 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 use or disclose your email address, but never PHI, information to market a product or service, either directly, or through a service provider or partner that performs services on our behalf.

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 YOUR INFORMATION
Unless we otherwise give you notice, we will retain your Information on the UBACARE Platform on your behalf until such times as you or we terminate your User Account. On termination, you will have an opportunity to print or make copies of your Information subject to the following. 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, UBACARE is not the custodian of Information held on the UBACARE Platform; rather it holds Information on behalf of Users or Authorized Physicians and Authorized Non-Physician Providers. On termination of your User Account, once you have been given the opportunity to print or make copies of your Information, we will delete the Information associated with your User Account, except Information that an Authorized Physician or Authorized Non-Physician Provider advises us he or she requires in connection with a consultation or Informational Services the Authorized Physician or Authorized Non-Physician Provider provided. In such circumstances, UBACARE will destroy the Information when the Authorized Physician or Authorized Non-Physician Provider has obtained a copy or terminates his/her account with UBACARE.

ACCESSING AND CORRECTING YOUR INFORMATION
You can access your Information or that of your Registered Dependents to check that it is accurate, complete, and up to date by logging in to your User Account at http://UBACARE/login.  You can 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 when you log in to your User Account. 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 UBACARE Platform or that they hold in their medical records.

HOW WE PROTECT YOUR INFORMATION
UBACARE takes the security of your information seriously. We take a variety of approaches in protecting your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.  However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.  You also play an important role in protecting your privacy and the confidentiality of your Information.  We strongly advise on creating a strong and unique password for your User Account while updating 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.

RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

REVISIONS TO OUR PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically. The date this Privacy Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the Privacy Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Websites or Apps after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this Privacy Policy.

CONTACTING US
If you have any questions about this Privacy Policy or UBACARE’s privacy practices, please contact us at:

UBACARE
Unit 106, 19840 28 Avenue
Surrey, British Columbia
Canada V3Z 6M3
privacy@ubacare.com

116 W. 23rd Street, 4th Floor
New York, NY 10011
privacy@ro.co