Last Updated: July 2018
Welcome to Right Health! – Healthcare on-demand.
"our") collects, uses, discloses and otherwise manages your personal information and personal health information
"PHI", and, collectively
"Website"); (2) the "AKIRA" mobile phone application (the
"App"); and (3) the Akira online platform, and (4) all other services provided by Right Health, as described
on the Website (collectively, the
THE PLATFORM WILL COLLECT AND TRANSMIT PERSONAL INFORMATION ABOUT YOU. BY USING THE PLATFORM, YOU AGREE THAT WE CAN COLLECT,
USE THE PLATFORM.
COLLECTION AND USE OF PERSONAL INFORMATION INCLUDING PHI
Right Health provides on-demand access to physicians (
"Physicians") and personal health assistants (
"PHAs") by secure text and video for telemedicine and telehealth consultations, and related healthcare and
administrative support services (
"Health Services" and
"Support Services", respectively) through the Akira app. For the purposes of providing Health Services and
Support Services and purposes consistent with those purposes, Right Health, Physicians and PHAs collect and use personal
information including PHI that is provided by clients during telemedicine and telehealth consultations or uploaded
by clients to the Platform to complete and update online profiles and personal health histories maintained in secure
client user accounts (
"User Account"). Your PHI may include information or records regarding your medical or health history, health
status and laboratory testing results, diagnostic images, and other health related information. Your PHI may be contained
in medical records, treatment and examination notes, and other health related records maintained by Physicians or PHAs.
Neither Right Health nor any Physician or PHA collects or uses personal information for any other purpose than providing
and facilitating the providing of Health Services and Support Services, and purposes consistent with those purposes,
including but not limited to the following:
Register: You do not have to register in order to browse our Website. However, in order to use the Platform
to receive Health Services or Support 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 your PHI to Physicians and
PHAs in order to enable them to provide appropriate Health Services and Support Services. We use your personal information
to identify who you are, communicate with you, and otherwise administer your use of the Platform to receive Health
Services or Support Services. We do not knowingly allow individuals under the age 18 to create their own User Accounts
that allow access to our Platform. Although individuals under the age of 18 may receive Health Services or Support
Services at the discretion of Physicians and PHAs using their parent or legal guardian’s User Account and in the
presence of that parent or legal guardian.
Purchase a Subscription: If you choose to purchase a subscription to receive Health Services or Support
Services, we may collect your payment information such as your name, address, phone number, email address, billing
address, and payment method information. This information is used to process and maintain your subscription.
Quality of Care: If you receive Health Services or Support Services, your PHI may be used to improve the
quality of Health Services or Support Services provided by Physicians and PHAs through the performance of quality
reviews, training staff and students, for business management, quality improvement and similar activities. Your PHI
may also similarly be used to create de-identified information such as aggregate statistics relating to the use of
Health Services or Support Services.
Job Applications: If you apply for a job at Right Health, 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 PERSONAL INFORMATION
We will not disclose, trade, rent, sell or otherwise transfer personal information, without consent, except as otherwise
We may transfer or disclose personal information as follows:
Circle of Care: If you receive Health Services or Support Services your personal information including your
PHI may be disclosed to and among Physicians and PHAs for the purpose of providing or assisting in the provision
of Health Services or Support Services to you. Your personal information including your PHI to third parties such
as other health professionals, specialists, consultants or pharmacists, pharmacies and laboratories for the purpose
of providing or assisting in the provision of Health Services or Support Services to you.
Service Provider Arrangements: In connection with our Platform, Health Services or Support Services, we
may disclose (or otherwise make available) personal information to third parties who provide Health Services or Support
Services on our behalf. For example, we may use service providers to process payments, host our website and store
information on our behalf. Personal information may be maintained and processed by third party service providers
in Canada and may be accessed by the courts, law enforcement and national security authorities as required under
the laws of those jurisdictions. Our service providers are given the information they need to perform their designated
functions, and we do not authorize them to use or disclose personal information for their own marketing or other
purposes. 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: Right Health may transfer personal information as an asset in connection with a merger
or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Right
Health or as part of a corporate reorganization or other change in corporate control.
Legal: Right Health and our affiliates and service providers may disclose personal information to third
parties as required or permitted by applicable law. Where a disclosure of our clients’ information is required by
applicable law, we promptly notify our client prior to complying with such requirements (to the extent we are not
prohibited from doing so).
We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and
to investigate or prevent actual or suspected loss or harm to persons or property.
INFORMATION ABOUT OUR PLATFORM
As you use the Platform, certain 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 Application, such as
the content of searches you perform on the App.
Access Device and Browser Information: When you access the App from a computer or other device, we may collect
anonymous information from that device, such as your Internet protocol address, browser type, connection speed and
access times (collectively,
Cookies: Our Platform uses a technology called "cookies". A cookie is a tiny element of data that our Platform
sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user when
you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from
our Platform, you may not be able to take advantage of all of the Platform features.
Real-Time Location: Certain features of the App 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 provider who is licensed or authorized
to provide services in the province where you are located.
Mobile Services: We may also collect non-personal information from your mobile device or computer. This
information is generally used to help us deliver the most relevant information to you. Examples of information that
may be collected and used include how you use the application(s) and information about the type of device or computer
you use. In addition, in the event our application(s) crashes on your mobile device we will 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)
Third Party Links: Our Platform may contain links to other websites or platforms that Right Health does
not own or operate. Also, links to our Platform may be featured on third party websites or platforms on which we
without consent. We provide links to third party websites or platforms as a convenience to the user. These links
are not intended as an endorsement of or referral to the linked websites or platforms. The linked websites or platforms
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
SECURITY OF PERSONAL INFORMATION AND PERSONAL HEALTH INFORMATION (PHI)
We understand that data security is a critical issue for our clients and we are committed to safeguarding the personal information
in our custody and under our control.
Right Health 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, modification and disclosure of personal information in our custody and
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 of your personal information including you PHI as required by applicable
privacy laws, including without limitation, PHIPA and PIPEDA and the regulations under those Acts.
ACCESS TO PERSONAL INFORMATION
If we receive a request from an individual to access or update personal information we have collected on behalf of a particular
client, we will direct that individual to the relevant client. We will assist our clients wherever possible in responding
to individual access requests.
If you submit personal information via our Platform or otherwise provide us with your personal information, you may request
access, updating or correction of your personal information by submitting a written request to our Privacy Officer
"Contact Us" below). We may request certain personal information for the purposes of verifying your identity.
We may use de-identified information created by us from your personal information without restriction.
LIMITATION ON DELETION
You may request deletion of your personal information by us, but please note that we may be required (by law or otherwise)
to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply
with your deletion request only after we have fulfilled such requirements). When we delete personal information, it
will be deleted from the active database, but may remain in our archives and we may also retain Anonymous Information
about your use of our Platform. Once we disclose some of your personal information to third parties, we may not be
able to access that personal information any longer as maintained by the third party and cannot force the deletion
or modification of any such information by the parties to whom we have made those disclosures. After we delete personal
information, we will retain de-identified information and will continue to use de-identified information without restriction
You should report any security violations to us by sending an email to
Policy will be posted on the Platform.
Please contact us at the address set out below if:
- you wish to access, update, and/or correct inaccuracies in your personal information; or
- you otherwise have a question or complaint about the manner in which we or our service providers treat your personal
c/o Privacy Officer