Effective February 1, 2019

Welcome to Akira! – Reimagined Healthcare.

This Privacy Policy governs how Right-Health Inc. (“Akira,” “us,” “we, “or “our”) collects, uses, discloses and otherwise manages your Personal Information and your Personal Health Information (collectively, “Information”). For the purposes of this Privacy Policy, “Personal Information” includes your name, phone number, email address, gender, birth date and payment information (including your credit card number and its expiration date), but excludes Personal Health Information; “Personal Health Information” means information that is collected or created by our healthcare team in the course of providing healthcare services to you, including information concerning your physical or mental health history, health status, symptoms, diagnosis, laboratory testing results and diagnostic images, your health insurance plan number, information concerning any healthcare service and advice provided to you by us, including referrals, recommended follow up or next steps, and other health-related information. This Privacy Policy applies to our privacy practices on (1) the Akira website located at https://www.akirahealth.ca/ (the “Website”); (2) the Akira mobile phone application (the “App”); (3) the Akira online platform, and (4) all other services provided by Akira, as described on the Website (collectively, the “Akira Platform”).

Collection and use of Information

Akira provides individuals with access to physicians, nurse practitioners, nurses, mental health therapists, dietitians and naturopaths (“Health Care Practitioners”) and personal health assistants (“PHAs”) by secure text, video and audio chat for virtual care consultations (“Health Services”), and related healthcare and administrative support services (“Support Services”) through the Akira Platform (together referred to as “Services”). For the purposes of facilitating the provision of Services by Health Care Practitioners and PHAs and purposes consistent with those purposes, Akira collects and uses Information that is provided by clients during virtual care consultations or uploaded by clients to the Akira Platform to complete and update online profiles and personal health histories maintained in secure client user accounts (“User Account”).

Provision of Services: Akira collects and uses Information for the purpose of providing and facilitating the provision of the Services.

Registration on the Platform: You do not have to register in order to browse our Website. However, in order to use the Akira Platform to receive Services, you will need to register to create a User Account and provide your name, contact information and a password that you select. You will also need to disclose information about your current health condition and health history to Health Care Practitioners and PHAs in order to enable them to provide you with appropriate Services. We use your Personal Information to identify who you are, communicate with you, and otherwise administer your use of the Akira Platform to receive Services. Individuals under the age of 18 may access Services at the discretion of Health Care Practitioners and PHAs, and in collaboration with a parent or legal guardian of the individual under the age of 18, as appropriate.

Purchase a Paid Service: If you choose to purchase Services from us, we may collect your payment information such as your name, address, phone number, email address, billing address, and payment method. This information is used to process your payments and, if you purchase a recurring Service, to renew your subscription. We use a third party service provider who is PCI DSS compliant to facilitate secure payment processing.

Quality of Care: If you receive Services, members of the Akira team may review your Personal Health Information in order to evaluate and/or improve the quality of Services, including responding to any inquiries from you.

Technical Support: We may use your Personal Information in order to verify your account information in the context of providing you with technical support.

Job Applications: If you apply for a job at Akira, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a telephone number) along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service, service offerings, and our Platform.

Disclosure of Your Information

We will not rent, exchange or sell your Personal Information or your Personal Health Information.

We may transfer or disclose Information as follows:

Circle of Care: If you receive Services through the Platform, we may to disclose your Information to and among Health Care Practitioners and PHAs for the purpose of providing or assisting in the provision of Services to you. We may disclose your Information to third parties such as other health professionals, specialists, pharmacists, pharmacies and laboratories for the purpose of providing or assisting in the provision of Services to you.

Employers/Benefits Providers: If your access to the Akira Platform was facilitated through your employer or benefits provider, we may provide general information about the status of your account to them. For example, we may disclose to your employer or benefits provider whether you activated your account, what email address you provided and when you last accessed your account. We will not disclose any Personal Health Information to your employer or benefits provider. Non-identifiable Personal Health Information may be shared with your employer at an aggregated level.

Service Provider Arrangements: In connection with the Akira Platform and/or Services provided by Akira, your Information may transit through third parties who provide services on our behalf. For example, we may use service providers to process payments, host our website and store information on our behalf. Our service providers are given only the Information they need to perform their designated functions. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.

Sale of Business: Akira may transfer Information as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Akira or as part of a corporate reorganization or other change in corporate control.

Legal: Akira and our affiliates and service providers may disclose Information to third parties where required or permitted by applicable law (which may include access by courts, law enforcement and national security authorities in Canada).

Information About our Platform

As you use the Platform, certain Personal Information may be passively collected by Cookies, navigational data like Uniform Resource Locators (URLs) and third party tracking services, including:

App Activity Information: We may keep track of some of the actions you take on the Akira Platform, such as the content of searches you perform on the App. We use this information in order to improve our products and services and to protect your data from unauthorized access.

Access Device and Browser Information: When you access the App from a computer or other device, we may collect information from that device, such as your Internet protocol address (IP address), browser type, connection speed and access times (collectively, “Usage Information”). We use Usage Information in order to improve our products and services and to protect your data from unauthorized access.

Cookies: The Akira Platform uses a technology called “cookies”. A cookie is a tiny element of data that the Akira Platform sends to your browser, which may then be stored on your hard drive so that we can recognize your browser when you return. We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Akira Platform, you may not be able to take advantage of all of the features of the Akira Platform.

Real-Time Location: Certain features of the App request your permission to use GPS technology to collect real-time information about the location of your device so that the App can connect you to a Health Care Practitioner who is licensed or authorized to provide services in the area where you are located.

Device and Usage Information: We may also collect device-related information from your mobile device or computer. This information is used to help us authenticate you, deliver content appropriate for your device’s capabilities, and to deliver push notifications to notify about activity on your account, such as messages from our Health Care Practitioners. Examples of information that may be collected and used include your device’s unique identifier, manufacturer, model, and operating system version. In addition, in the event our application(s) crash(es) on your mobile device we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s)

Real-Time Video and Audio Conversations: You may be required to connect with Health Care Practitioners and PHAs through a real-time video and audio call to receive certain Health Services such as diagnoses and advice, and to verify your identity. All video and audio calls conducted through our Platform are confidential and end-to-end encrypted and accessible only to you and the Health Care Practitioners and PHAs responsible for your care. These calls are never recorded or stored and cannot be accessed at a later date.

Text-based Chat: Many of our Services are accessed primarily through text-based chat. The contents of your chat conversations are stored as part of your health record and are protected in the same way as all other Personal Health Information in Akira’s custody.

Third Party Links: The Akira Platform may contain links to other websites or platforms that Akira does not own or operate. Also, links to our Platform may be featured on third party websites or platforms on which we advertise. Except as provided in this Privacy Policy, we will not provide Information to these third parties without consent. We provide links to third party websites or platforms as a convenience to our users. These links are not intended as an endorsement of, or referral to, the linked websites or platforms. The linked websites or platforms have separate and independent privacy statements, notices and terms of use. We do not have any control over such websites or platforms, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use or disclose, secure and otherwise treat personal information.

Security of Information

We understand that data security is a critical issue for our clients and we are committed to safeguarding the Information in our custody and under our control.

Akira has implemented a comprehensive information security program that includes written policies and procedures, and security controls. We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, loss, modification and disclosure, of Information in our custody and control.

Akira’s security policies, procedures, and controls are tested and audited by a third party on an ongoing basis, using industry-standard practices such as SOC 2 reporting and penetration testing.

Our privacy practices are intended to comply with applicable privacy laws, including without limitation, the Personal Health Information Protection Act (Ontario) (“PHIPA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We will maintain the privacy and security of your Information as required by applicable privacy laws, including without limitation, PHIPA and PIPEDA and the regulations under those Acts. We are pleased to advise that all Personal Health Information is stored in Canada. Personal Information (but not Personal Health Information) may be stored outside of Canada.

Access to Information

Akira takes reasonable steps to ensure your Information is accurate, complete, and up to date. If you become aware that any Information in our possession about you is not correct, please contact our customer support. Contact information may be found under the heading “Contact Us”.

You are entitled to a copy of the Information that we have in our possession or under our control; if you would like a copy of such Information, please contact us. We will take reasonable steps to verify your identity before granting access or making corrections. In addition, your right to access or correct your personal information is subject to certain legal restrictions.

Anonymized Information

We may use non-identifiable information created by us from your Information in order to better understand and improve the Akira Platform and our service offerings.

Retaining Your Information

We will retain any and all Information that we are required to retain under any applicable laws and regulations for the full duration of time required under those laws and regulations. We may also retain non-identifiable information and continue to use this information in accordance with this Policy.

You may request that we delete the Information that we maintain about you, but please note that we may be required to maintain certain Information in order to meet our legal obligations (in which case we will comply with your deletion request only after we have fulfilled such obligations). When we delete Information, it will be deleted from the active database, but may remain in our archives and we may also retain Usage Information. After we delete Information, we may retain non-identifiable Information and will continue to use non-identifiable information as permitted under this Privacy Policy.

Report Violations

You should report any privacy or security violations, including any suspected or actual unauthorized access, use or loss, of Information, to us by sending an email to support@akirahealth.ca.

Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes to our practices. The revised Privacy Policy will be posted on the Platform.

Contact Us

Please contact us at the address set out below if:

  • you have any questions or comments about this Privacy Policy;
  • you wish to access, update, and/or correct inaccuracies in your Information; or
  • you otherwise have a question or complaint about the manner in which we or our service providers treat your Information.

Akira
c/o Privacy Officer
252 Adelaide Street East, Level 200
Toronto, ON
M5A 1N1 support@akirahealth.ca

This Privacy Policy was last updated on February 1, 2019.