Privacy Policy — Health Professionals

At Braver, we are committed in protecting your privacy.

This privacy policy (the “Privacy Policy”) let’s you know when and how Braver inc. (“Braver”/“we”/“us/our”) uses, collects, discloses or processes your personal information and that of your patients when you use our products and services or visit the Braver website https://braver.health (the “Website”). To this end, we have outlined below our ten privacy principles, which are based on the principles established by the Personal Information Protection and Electronic Documents Act, S.C., 2000, c. 5 (“PIPEDA”) and the Act Respecting the Protection of Personal Information in the Private Sector C.Q.L.R., c. P-39.1.

Braver’s 10 Privacy Principles

Personal information is information that can be used to identify or contact you individually, as well as other information that Braver needs to provide you with the products and services for which you have subscribed (the “Personal Information”). The Personal Information we collect generally includes your name, gender, date of birth, license number, email address, place of business, telephone number, fax number, credit card number, and/or other payment information for our products and services. In some circumstances, an IP address may be considered Personal Information.

Braver has developed 10 privacy principles, based on those established in PIPEDA. Braver has put in place policies and practices to give effect to these principles. In particular, we have policies and procedures in place to (1) protect Personal Information, (2) receive and respond to complaints and inquiries, and (3) train and communicate information about Braver’s policies and practices to our staff. This Privacy Policy is intended to explain how Braver’s policies and procedures comply with each of these principles.

Principle 1 - Responsibility

Braver is responsible for the Personal Information under its control. To this end, Braver has designated a privacy officer who is accountable for its compliance with our Privacy Policy and PIPEDA (the “Privacy Officer”). The Privacy Officer is also responsible for our compliance with PIPEDA, but other individuals at Braver may be involved in the day-to-day collection and processing of Personal Information and may also be delegated to act on behalf of the Privacy Officer. Braver may also occasionally use separate companies, called third parties, to assist us in providing our products or services to you. Regardless of where these third parties are located, we require that they also comply with PIPEDA and our privacy principles.

Principle 2 - Identifying Purposes for Collection

You have the right to know how your information will be used. Braver is committed to explaining to you why we need your information before or when we collect it, if the purpose is not already clear. We will assume that the purpose is clearly identified when we use your Personal Information to:

  • provide you with the products and services for which you have subscribed;
  • process and make payments, including recurring payments for our products and services for which you are subscribed;
  • communicate with you about the products and services you have subscribed to;
  • ensure that you are properly subscribed and/or enrolled to use our products and services and to obtain any related technical support; and
  • inform you of any updates and/or revisions to the products and services you have subscribed to.

Where applicable, Braver will also collect log information including your IP address and the time you access our service. This information is stored in log files and is used for security analysis, performance improvement, and aggregate and statistical reporting. This log information is not linked to Personal Information collected elsewhere on the Website.

Braver may also use your Personal Information for secondary purposes such as to:

  • inform you of new and/or updated products and services;
  • invite you to participate in customer surveys or other related activities to obtain your feedback on our products and services.

Braver will not disclose your Personal Information to third parties without your consent, except in the following limited circumstances:

  • as reasonably required to fulfill our service or product offering, provided that such third parties are bound by appropriate confidentiality requirements;
  • to comply with a legal process such as a law, regulation, search warrant, subpoena, court order or law enforcement request;
  • to resolve a contractual or extracontractual dispute regarding your and/or a patient’s use of any product or service provided by Braver;
  • to resolve issues related to the use of your account for illegal activities; or
  • in an emergency, to protect the health and/or safety of other users or members of the public.

Principle 3 - Consent

Braver will only collect, use and/or disclose your Personal Information with your knowledge and consent unless permitted or required by law or as set forth in this Privacy Policy. We will not rent, sell or distribute your Personal Information without your permission, unless such use is set forth in this Privacy Policy. Braver is also committed to seeking your consent where the information and/or its transfer is likely to be considered sensitive.

Principle 4 - Limiting Collection

Braver will collect Personal Information only for the purposes we have identified or for the primary uses described above. We will only collect such information by fair and lawful means. We will collect Personal Information in the following circumstances:

  • when you subscribe to use our products and services, whether free or through a paid subscription;
  • when you provide your payment information to sign up for our paid products and services;
  • when this information is provided to us by a third party that you have authorized to share this information with us; and
  • when you contact Braver for information.

We will identify as optional any question involving the transmission of information that is not necessary to our service offering.

Braver uses cookies to collect information and improve our products and services. A cookie is a small data file stored on your device. Cookies cannot be used to view other data on your computer or to identify your email address and/or identity. Your browser may use persistent “LocalStorage” cookies to store your session ID to make it easier for you to connect to our services in the future. We may use session cookies to enable certain features of our services, to better understand how you interact with our services, and to monitor the overall usage and routing of web traffic in connection with our services. You may at any time change your browser options to stop providing cookies or to have your browser ask for your permission before providing cookies. Choosing to decline to provide cookies may affect the quality of your access to our products and services.

Our Website may include links to third party sites. These third-party sites may collect various cookies. Among other things, these cookies may be used to track your involvement in pages for advertising purposes. You may choose not to provide these cookies. Braver does not control these parties, and you should consult their privacy policies to learn more about why and how they collect and use your information.

Principle 5 - Limiting Use, Disclosure and Retention

Braver will not use or disclose your Personal Information other than for the purposes for which it was collected, unless we obtain your consent or unless required or permitted by law. The contents of files about you stored on our service are encrypted and only you can decrypt them. In the event that we need to comply with a legal request and/or procedure, we will verify its validity and disclose only the information legally required. Braver will also make reasonable efforts, within the limits of the law, to notify you in the event that your Personal Information is subject to such disclosure.

Braver will retain your Personal Information only for as long as necessary to fulfill the purposes identified above, as required by law, or as necessary to resolve any disputes and/or requests you and/or your patient(s) may have regarding our services. Braver will follow internally established guidelines and exercise care when disposing of, destroying and/or de-identifying Personal Information to prevent unauthorized third parties from accessing it.

Principle 6 - Accuracy

Braver will keep Personal Information accurate, complete, and up-to-date for the purposes and purposes for which it is collected. Please inform Braver if your contact or other Personal Information changes. To update your Personal Information, go to https://braver.net and/or the mobile app and log into the “Profile” section of your account.

Principle 7 - Security Measures

We protect Personal Information in our possession and control by using security safeguards appropriate to the sensitivity of the information. We work to protect Personal Information from loss, misuse and unauthorized alteration using industry recognized security measures and limit internal access to Personal Information to certain members of our team. When you use our products and services, Braver requires that you create a password with an appropriate level of security. You will need your respective passwords to access files stored on our servers. Braver also provides you with the ability to designate other member professionals as “trusted contacts” who can, if necessary, assist you in resetting your password if it is lost by obtaining a recovery code for you.

YOU MUST SAVE YOUR PASSWORD. Passwords and keys are not stored on the Braver’s system. Therefore, if you lose or forget them, we cannot reset them without the involvement of a trusted contact as described above. If a device used to log into our service is lost or becomes inoperative, you will be able to log into your account management portal via the Internet and/or available applications and deselect the affected device(s). For more information, visit https://braver.net.

We will keep a record of each breach of security measures involving Personal Information under our control. We will notify you of any breach of our security measures involving your Personal Information and that of your patients if it is reasonable under the circumstances to believe that the breach could create a real risk of damage to you or your patients.

Principle 8 - Transparency

This Privacy Policy is an overview of information about our policies and practices relating to the management of Personal Information. If we change any of our privacy practices, we will post the change in this Privacy Policy for thirty (30) days before it becomes effective. We will not retroactively change the practices associated with your Personal Information without your consent. The intent of this Privacy Policy is to answer your questions about our privacy policies and practices. If you would like more detailed information about our privacy policies and practices, please contact our Privacy Officer at vieprivee@braver.health. When you send Braver a request or concern, the Privacy Officer or its nominee will review the request or concern and respond to you within a reasonable period of time, which should not, except in exceptional circumstances, exceed thirty (30) days.

Principle 9 – Access to Personal Information

In response to written request from you, and subject to exceptions required or permitted by law, Braver will inform you of the existence, use, and disclosure of your Personal Information and provide you with access to that information. You will also be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Challenging Compliance with the Principles

Braver maintains procedures for handling and responding to all inquiries or complaints regarding its handling of Personal Information. We will inform individuals who wish to make such complaints or inquiries of the appropriate existing procedures. Our Privacy Officer and staff working under the direction of the Privacy Officer may seek outside advice, as appropriate, before providing a final response to complaints. Braver is committed to taking seriously and investigating any situation that supports a complaint made against us. If a complaint is found to be justified, Braver will take appropriate steps to resolve the issue to which it refers, including, if necessary, amending its policies and procedures.

General Provision

The parties agree that in the event of a discrepancy or a conflict between the French and the English version of this agreement, the French version shall prevail for purposes of its interpretation, performance and enforcement.

For more information

We welcome any comments, questions and/or concerns you may have about our policies, practices and customer service. To do so, please contact our privacy office at privacy@braver.health.