Privacy Statement

Policies and Procedures

Last updated: December 2024

Introduction

Adracare Inc. (“Adracare”, “we,” “us,” or “our”) to WELL Digital Health Apps Inc. doing business as Adracare and its parent company, WELL Health Technologies Corp., its subsidiaries and affiliates (collectively, “Adracare”, “we”, “us”, or “our” provides an end-to-end practice management and virtual care platform that helps healthcare providers and administrators run their practices. We are committed to protecting your personal information and complying with applicable data protection and privacy laws. This “Privacy Policy” tells you how we do so.  

This Privacy Policy outlines the measures we take to protect your privacy and personal information. Adracare Inc. has developed this Privacy Policy to explain how we collect, receive, use, share, and retain your information. This Privacy Policy is applicable to all users of our website (the “Website”) and the services accessible through our Website and Web Platform (collectively referred to as the “Services”). By visiting our Website and/or using our Services, both Operators and Service Recipients acknowledge that they have read, understood, and agreed to the terms outlined in this Privacy Policy, in addition to the Terms of Use, which are incorporated herein. 

Information We Collect

Adracare Inc. collects the following types of information via the Website, obtained both directly from you and indirectly through our third-party service providers (our “Providers”). 

Personal Information

“Personal Information” refers to any information or data that identifies or could reasonably be used to identify a natural person. When you purchase or utilize our Services, you may be required to provide Personal Information such as your name, address, phone number, and email address. Service Recipients may also be asked to provide Personal Information related to their medical history, encompassing past and present medical conditions, medications, and ailments (“Health Information”). We may employ Providers to collect and process credit card, debit card, and relevant financial data (such as expiration dates, billing addresses, and activation codes) as necessary to complete transactions on the Platform, and we do not retain such information. We do not collect Personal Information from Visitors, Operators, or Service Recipients unless it is voluntarily provided. It is important to note that Personal Information does not include information related to corporate entities, encoded or anonymized information, or publicly available information that has not been combined with non-public Personal Information. 

Webpages

Adracare Inc. collects the following types of information via the Website, obtained both directly from you and indirectly through our third-party service providers (our “Providers”). 

Cookies

Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Website, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings, language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online interactions. 

These Cookies helps us understand how you use the Website and the content of the Website in order to make improvements. We also may use these Cookies to promote our services through marketing and advertising. These Cookies may be accessed or disclosed to third-parties, such as Google Analytics and Facebook Pixel, for the purpose of analyzing site usage and better serving you relevant advertisements.   

You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of the Website’s features, and may prevent us from providing you with the information and services you have requested. 

Adracare Web Platform

We collect the following information from the Healthcare Provider (HCP) or patient: 

  • HCPs collect and use personal health information about the patient as part of the provision of healthcare. HCPs may collect personal health information verbally or by text, including but not limited to: the reason for the patient’s consultation request, relevant health history, present condition or symptoms and current treatments. This information is used by the HCP to provide the Health Services and /or Support Services. HCPs may log this personal information about the visit to the relevant User Account on the Platform, which may be referenced by them and other HCPs in the future. Patients are also able to log personal health information into their User Account to allow easy reference by HCPs. 
  • In some cases, some HCPs who use Services and interact with patients are governed by their own privacy policies with respect to the collection, use and disclosure of personal information to comply with the laws of the HCP’s local jurisdiction. HCPs are required to keep logs of each patient visit within their own practice medical records off the Platform. 
How We Use Information​
Website

Adracare may use your Personal Information from the website for the following purposes:  

  • To respond to your requests.  
  • To provide and enhance the Website and the Services.  
  • To notify you about changes to the Website and/or the Services.  
  • To send you notifications (such as emails, mailings, etc.) regarding Services you are receiving and for billing and collection purposes.  
  • For any other purposes disclosed at the time the information is collected and to which you have given consent. 
  • As otherwise specifically described in this Privacy Policy.  
Adracare Web Platform

Adracare Inc. may use your Personal Information on the Platform for the following purposes: 

  • To manage our relationship with you and provide you with the information or services you request. 
  • To enable Healthcare Providers (HCPs) to provide Health Services through the Platforms. 
  • To facilitate the delivery of Health Services to patients by HCPs using the Platforms, including maintaining patient health records as required by different provincial laws and HCP governing bodies. 
  • To conduct research and evaluate development on the Webpages, including analyzing testing data to improve our services. 
  • To communicate with you regarding inquiries for information or customer service request or employment opportunities.
  • To detect, prevent or investigate security breaches. 
  • To provide HCPs the data and Provider connection to be able to manage insurance, and payment transactions as agreed to on the Webpages or through the use of the Platforms. 
  • To protect our business. 
  • To maintain appropriate records for internal administrative purposes. 
Who Do We Share Information With?

We may share some of your personal information, including personal health information, with third-party service providers in order to operate the Webpages, the Platforms, or to provide you with the information you request. We only use service providers that ensure a comparable level of protection for your information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information only for the services requested.  

Exceptionally, we may collect, use or disclose personal information without your consent in the following limited circumstances: 

  • when the collection, use or disclosure of personal information is permitted or required by law or by regulatory proceedings, 
  • in an emergency that threatens an individual’s life, health, or personal security, 
  • when we require legal advice from a lawyer, 
  • to protect ourselves from fraud,  
  • to a collection agency in order to collect our unpaid accounts, or 
  • to investigate an anticipated breach of an agreement or a contravention of law. 

If we merge with another business, we will inform you of any impact on your personal information.  

Webpage

We only share your personal information with service providers, including our affiliates, in order to operate the Webpages. This includes potentially sharing your personal information for: 

  • providing requested services or information, 
  • operating and optimizing the Webpages, or 
  • customer service. 
Adracare Web Platform

We may share your personal information, including personal health information, with service providers, HCPs registered on the Platforms, and other third-parties you request (such as pharmacies or HCPs not using the Platforms). This includes sharing your personal information for:  

  • fraud prevention,  
  • payment processing via Stripe,  
  • providing requested services or information, 
  • operating the Webpages or Platforms,
  • customer service, and 
  • facilitating the delivery of Health Services or Support Services. 
Adracare Web Platform

We may share your personal information, including personal health information, with service providers, HCPs registered on the Platforms, and other third-parties you request (such as pharmacies or HCPs not using the Platforms). This includes sharing your personal information for:  

  • fraud prevention,  
  • payment processing via Stripe,  
  • providing requested services or information, 
  • operating the Webpages or Platforms,
  • customer service, and 
  • facilitating the delivery of Health Services or Support Services. 
How We Protect Your Information

We use reasonable and appropriate physical, administrative and technical measures (including encryption) designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with Adracare is prohibited and constitutes grounds for disciplinary action. Email communication with us may not be secure, so exercise caution when deciding what information to send via email. 

Certain HCPs who utilize the Platforms will have additional security policies and procedures to manage individual’s personal information (including personal health information).  

Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated, and we cannot guarantee no breach will ever occur. 

Where Do We Store Personal Information?
Website

All personal information Adracare collects on the Website is stored in secure servers in Canada 

Adracare Web Platform

All personal information Adracare Inc. collects is stored in secure servers respective of the country where the environment is set up.  

  • Canadian environments are stored in Canada 
  • United States of America environments are stored in the United States of America

However, personal information processed by our third-party service providers may be done outside of the jurisdiction where the data is stored. While being processed in another jurisdiction, such personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information. 

HCPs on the Platforms are required by their respective provincial colleges to maintain appropriate records of each patient visit. This involves them using electronic medical records or other digital services which store your personal information, including your personal health information, which may be on servers (or have back-ups) located outside of Canada. 

Please note that Adracare is a Service Provider. Depending on the request, we will not be able to permanently delete personal or personal health information without the explicit consent of the custodian (this could be the healthcare organization or HCP). 

For more information on our service providers or where we store personal information, contact us at privacy@well.company. 

Links to Third-party Sites

Our Webpages or use of the Services may lead you to third-party websites, including websites advertising products or services. These websites are separate and distinct from Adracare and WELL and have their own separate privacy policies. We are not responsible in any way for how these website collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies before providing your personal information to them. 

Direct Marketing

You may sign up to receive marketing or promotional communications from WELL Health or Adracare. Where you have expressly consented, we may use your personal information to inform you about us and our products and our services, including promotional offers and events. 

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by: 

  • using the unsubscribe feature found in our emails and other electronic communications, or 
  • contacting us via email at marketing@well.company .  

We remove your contact information from our distribution list as soon as you unsubscribe

Artificial Intelligence

Adracare does not currently utilize artificial intelligence (AI) technologies as part of the operation of the Platform.

For more information on Adracare use of these technologies, please contact privacy@well.company 

Consent

By registering for an account with Adracare to use the Platforms, Adracare and the HCPs obtained your consent (or the guardian’s consent for a Registered Child) to collect, use or disclose your personal for the purposes of (i) delivering Health Services and Support Services to you, and (ii) registering you as a HCP on the Platforms.  

If you no longer wish for your personal information to be processed for these purposes, please contact privacy@well.company and stop using the Platform. 

Your rights

Based on the applicable laws of the province where you live and receive health care, you may have the following rights over your Personal Health Information (PHI) :  

  • updating or withdrawing your consent to the use or disclosure of personal information,
  • requesting access your personal information, including your personal health information, 
  • requesting restrictions on our use or disclosure of your personal information,  
  • objecting to or making a complaint to our use or disclosure of your personal information,  
  • requesting that we edit or correct, but not remove, certain information (like an e-mail address),  
  • requesting that we transfer to another organization the personal information you have provided us, and  
  • requesting deletion of the personal information we hold about you, where permitted.  

Contact us at privacy@well.company to exercise any of these rights. If you request access to your personal health information, we may refer your request to the relevant healthcare provider to comply with your request. We will respond within 30 days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons. 

We will address all requests with equal attention.   

Contact Us

Accountability with respect to your personal information is important to Adracare. If you have any questions (including how personal information is managed by Adracare), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company. 

If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.