At Braver, we are committed in protecting your privacy.
This privacy policy (the “Privacy Policy”) lets you know when and how Braver inc. (“Braver”/“we”/“us”/“our”) uses, collects, discloses or processes your personal information when you and/or the healthcare professional(s) of your choice (your “Professionals”) 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 (“ARPPIPS”).
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 your Professionals with the products and services for which they have registered you (the “Personal Information”). The nature and quality of the Personal Information we collect is purely at the discretion of the Professionals responsible for its integration into our products and services, but generally includes your name, health insurance number, certain elements of your medical history and associated conditions. 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:
- allow your Professionals to analyze and review all data relevant to their management of your medical condition;
- allow your Professionals to communicate, share and coordinate the necessary and/or related actions to manage your medical condition;
- ensure that your Professionals are properly subscribed to use our products and services and to receive any associated technical support; and
- inform you of any significant revisions or updates to our products and services.
Braver may also use your Personal Information for secondary purposes such as to:
- inform you and/or your Professionals of the release of new products and services and/or updates to them; and
- invite you to participate in patient 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, which must be obtained by your Professionals, 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 Professional’s use of any product or service provided by Braver;
- to resolve issues related to the use of your Professionals’ account, if any, 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 consent through your Professionals, 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, through your Professionals, when 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 your Professionals have subscribed you to use our services with your prior consent, whether free of charge or via a subscription paid by your Professionals;
- when this information is provided to us by a third party that you have authorized to share this information; and
- when you contact Braver for information.
For the purposes of clarity and transparency, we believe that the Personal Information that may be collected by your Professionals and shared through our products and services may be divided into the following categories:
- observations, opinions and comments resulting from physical and/or mental examinations and/or medical and/or paramedical treatments to which you have previously consented;
- photographs, x-rays, ultrasounds or any other information relevant to your health condition transmitted via a visual device to which you have previously consented;
- the nature and character of the tests, evaluations or treatments to which you have previously consented;
- progress notes ancillary to the treatments, tests or investigations to which you have previously consented; and
- the results of laboratory tests to which you have previously consented.
We will identify as optional any question involving the transmission of information that is not necessary for us to provide service to you and/or your Professionals.
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 your Professionals 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 Professionals may have regarding our services. Braver will follow internally established guidelines and exercise care in the disposal, destruction and/or de-identification of 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 your Professionals, who may contact Braver, if your contact or other Personal Information changes.
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 your Professionals use our service, Braver requires the creation of a password with an appropriate level of security. Your Professionals therefore need their respective passwords to access files stored on our servers. Braver also provides your Professionals with the ability to create a backup of your Personal Information and encryption keys, if any, by naming other Professionals who use our products and services as trusted third parties. In the event of loss, these trusted third parties may, upon request by your Professionals, ask Braver to reset the passwords and/or access keys to their accounts.
Your Professionals will need to save their respective password and key in a safe place. Passwords and keys are not stored on Braver’s system. Therefore, if your Professionals lose or forget them, we will only be able to reset them following the safe third-party process described in the previous paragraph. If a device used to log into our service is lost or becomes inoperative, your Professionals will be able to log into their account management portal via the Internet and deselect the affected device(s).
We will keep a record of each breach of security measures involving Personal Information under our control. We will notify your Professionals of any breach of our security measures involving your Personal Information if it is reasonable under the circumstances to believe that the breach could create a real risk of damage to you.
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 privacy@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 a written request from you, and subject to exceptions required or permitted by law, Braver will inform your Professionals of your request and ask them to confirm the existence, use and disclosure of your Personal Information and to provide you with access to that information. You will also be able to challenge the accuracy and completeness of your information and have it amended by your Professionals as appropriate.
Your Professionals will also have the ability and obligation, upon your written request, to provide a copy of all information contained in our products and services to the entity of your choice within a reasonable time.
We invite you to contact Braver of any reluctance, undue delay or refusal by your Professionals to provide you with the above information so that we may respond accordingly.
Principle 10 - Challenging Compliance with the Principles
Braver maintains procedures for handling and responding to all inquiries or complaints from patients and/or Professionals regarding its handling of Personal Information. We will inform individuals who wish to make such complaints or requests of the appropriate existing procedures. If you have any questions about the process and/or wish to make a complaint, please contact our Privacy Officer at privacy@braver.health.
Our Privacy Officer and staff working under the direction of the Privacy Officer may seek outside advice, if necessary, 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.