SELF CARE CATALYSTS INC. PRIVACY POLICY

This Privacy Policy was last updated on October 21, 2014.

 

Who are we and what do we do?

Self Care Catalysts Inc. (“SCC”) is a health solutions company powered by patient intelligence and analytics to promote positive health outcomes. SCC offers a mobile and desktop platform known as Health Storylines (“Platform”), which offers our site users (“Users”) a patient-centered, Web-based, technology-driven, self-care solution. (References to the Platform in this Privacy Policy also include SCC’s website; references to “you” and “your” in this Privacy Policy refer to each individual User.)

Our Platform allows Users to utilize a personalized suite of health apps to achieve personal health-related goals and advance positive health outcomes. SCC conducts patient research, using the data collected from the Platform to evaluate the patient experience in various therapeutic areas. SCC provides its research results solely in an aggregated and de-identified form to our Partners (defined below) to facilitate the improvement of available health care products and services.

 

Accountability

This Privacy Policy explains how SCC collects, stores and uses the Personal Information (defined below) collected from our Users, who are patients and other individuals who have registered to input information and/or participate in surveys on the Platform, including as to how this Information is shared with other parties such as pharmaceutical companies, medical device companies, non-profit organizations and research institutions (“Partners”).

SCC is firmly committed to protecting your privacy and has designated a Privacy Officer to ensure compliance with this Privacy Policy. Other SCC personnel may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of our Users’ Personal Information. However, SCC is accountable and responsible for all Personal Information in its possession or control.

You may always submit concerns regarding SCC’s Privacy Policy or related privacy practices to our Privacy Officer at the address below. If you send an email, please reference the Privacy Policy in your subject line. SCC strives to expeditiously respond to all reasonable concerns and inquiries.

 

Mailing address:
Attn: Privacy Officer
Self Care Catalysts Inc.
101 College Street, Suite 300
Toronto, Ontario, M5G 1L7
Email address: privacy@selfcarecatalysts.com

To the fullest extent applicable to SCC and its Platform, our Privacy Policy and related practices comply with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and Canadian provincial privacy legislation as well as the U.S. Health Insurance Portability and Accountability Act, Children’s Online Privacy Protection Act and other U.S. federal and state privacy laws and regulations.

 

The Platform does not provide medical advice

All the information and material provided via the Platform, including content, survey questions, images and SCC policies, are for informational purposes only and are not intended to serve as, do not constitute and are not a substitute for professional medical advice or treatment. SCC does not recommend or endorse any specific tests, physicians, products, procedures, opinions or other information that you may find on or through the Platform.

Always seek the advice of your physician or other qualified health provider with any questions you may have regarding your health and/or your particular situation. Never disregard professional medical advice or delay seeking advice because of something you have read on or learned via this Platform. SCC is not liable for injury, death or any other damages arising out of your use of the Platform. SCC has not sought or received any regulatory approval from any government agency for the Platform.

If you have or think you have a medical emergency, call your doctor or Emergency Services immediately. If you are currently suffering from a side effect or adverse reaction, you should immediately contact your health care provider, your local health authority or, in Canada, the Canadian Association of Poison Control Centres and, in the United States, the U.S. Food and Drug Administration’s (“FDA”) MedWatch.

 

What kind of information do we collect and how is it used?

Personal Information

For purposes of SCC’s Privacy Policy, “Personal Information” is any information that can be used to identify an individual, and may include, but is not limited to, the person’s name, email address, postal or other physical address, gender, marital status, occupation, and, as applicable, other information required to make the Platform available to you or to process an online inquiry, interaction or transaction that you have requested or initiated.

 

Restricted Data

Certain information input by our Users when registering to use or using the Platform (“Restricted Data”) will not be shared with our Partners, regulatory agencies or any other third parties at any time or for any reason without your express written consent (see “Consent” section below). Restricted Data includes your name and email address. SCC does not sell, rent, share or trade any Restricted Data to third parties for direct or indirect sales or marketing purposes. SCC reserves the right to use your Personal Information solely to improve the Platform.

 

Shared Data

Certain information that Users provide about themselves may be shared with our Partners and other third parties but only in aggregate form (“Shared Data”), which makes it impossible to identify any individual User or his/her Restricted Data. Shared Data includes:

·       Biographical information, e.g., gender, age, location (city, state and country), general notes;

·       Condition/disease information, e.g., diagnosis date, first symptom, family history;

·       Treatment information, e.g., treatment start dates, stop dates, dosages, side effects, treatment evaluations;

·       Symptom information, e.g., severity, duration; and

·       Aggregated survey responses.

 

How Shared Data is used

As stated above, Shared Data is made or may be made available to our Partners and other third parties solely through aggregated reports; Shared Data will be used in market research and other areas to better understand the patient experience in order to improve treatment options and health outcomes. Prior to any provision of Shared Data outside SCC, SCC removes all Users’ Restricted Data to reduce the likelihood of re-identification and employs contractual and other means to ensure that Partners and third parties protect Personal Information to the same extent as SCC.

SCC may report individual adverse event and drug safety information on a blind basis to the FDA, the U.S. Centers for Disease Control and Prevention and/or other regulatory bodies (Canadian, U.S. and international) as well as directly to our Partners; as stated above, SCC will not provide your Restricted Data to any such regulatory agencies, Partners or other third parties. However, subject to the “Consent” section below, SCC reserves the right to contact you for follow-up at the request of any such third party, which may have adverse event reporting requirements with respect to their products or services.

 

Information provided to SCC by third parties (i.e., healthcare providers)

Solely with your express prior written consent, we will collect Personal Information about you directly from any of your healthcare providers, subject to and in accordance with all applicable health care data privacy laws.

 

Consent

Your use of the Platform is always voluntary. After you register as a User on the Platform, you are always free to choose whether or not to participate in a survey, free to choose not to answer any specific non-required questions and free to discontinue your participation on the Platform at any time.

Your registration on the Platform and provision of any Personal Information constitutes your consent to SCC’s collection, use and disclosure of your Personal Information for the purposes stated in this Privacy Policy, subject to and strictly in accordance with the terms of this Privacy Policy. You acknowledge that your Personal Information may be transferred from your country to a country with less stringent data privacy laws but solely for use in accordance with this Privacy Policy. You may withdraw your consent at any time to any further collection, use or disclosure of your Personal Information on written notice to SCC.

From time to time, a Partner or other third party may want to contact you directly (i.e., to fulfill adverse event reporting requirements or for research purposes). In any such event, SCC will obtain your express permission before making any such disclosure.

You will always have access to your Personal Information on the Platform and may amend it at any time to ensure its accuracy and completeness.

Without your express prior consent, SCC may share your Personal Information in response to facially valid judicial or other government subpoenas, warrants or court orders or other legal process in accordance with applicable laws or if SCC believes in good faith that such disclosure is necessary to prevent or take action regarding illegal or suspected illegal activity or to protect the rights or safety of SCC or any of SCC’s Users, Partners or other third parties. SCC will use all reasonable efforts to provide you with written notice of any disclosure of your Personal Information under this paragraph.

SCC does not knowingly collect Personal Information from children under the age of 13. If SCC learns that it has collected Personal Information on a child under the age of 13, SCC will delete that Personal Information from the Platform. SCC encourages parents and guardians to go online with their children.

 

Cookies; Do not track

A “cookie” is a small text file placed on your hard disk by an SCC Web server, containing information that can later be read only by that Web server. SCC uses cookies solely to enable you to sign in to the Platform and display your personalized content. You have the ability to accept or decline any cookie and, if you accept any cookie, you also have the ability to later delete that cookie. However, if you delete SCC’s cookie, any settings controlled by that cookie will be deleted and may need to be recreated each time that you access the Platform.

Some Web browsers offer a "Do Not Track" ("DNT") signal, which is an HTTP header field indicating the User’s preference regarding tracking or cross-site user tracking.  Because there is not yet a common understanding of how to interpret DNT signals, SCC does not currently respond to DNT signals, if any, that SCC may receive from any browsers. SCC takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology.

 

How we protect your information

SCC takes reasonable steps to protect your Personal Information (both Restricted Data and Shared Data) from unauthorized access, use, disclosure or loss. The Platform has reasonable security measures (including online and off-line physical, electronic and managerial safeguards) in place to protect against the loss, misuse and alteration of the Personal Information under SCC’s control. In certain areas, Personal Information is maintained on a secured database accessible only by SCC personnel. SCC uses industry-standard encryption technologies to protect Personal Information submitted by you on the Platform.

However, as with any transmission over the Internet, there is always some element of risk in submitting Personal Information online and SCC will not be liable for any breach of data security caused by circumstances outside its control, including unauthorized network intrusions.

If you have any questions about the security on the Platform or SCC’s website, please send an email to SCC’s Privacy Officer at privacy@selfcarecatalysts.com.

 

Complaints

SCC’s Privacy Officer will investigate all complaints concerning SCC’s compliance with its Privacy Policy and will take appropriate measures to resolve any complaint. The User involved will be informed of the outcome of the investigation regarding his or her complaint.

On any User’s request, SCC will provide further information about its complaint process. The Privacy Officer reserves the right to seek external advice, as and when appropriate, before responding to any User complaint.

 

Changes to this Privacy Policy

SCC may update or otherwise modify this Privacy Policy at any time for any reason so you are encouraged to review the Policy from time to time. All changes will become effective immediately on posting and your continued use of the Platform after any such posting constitutes your consent to that change.