CANADIAN PULSARA PRIVACY POLICY - OPERATORS

 

This Privacy Policy explains how CommuniCare Technology, Inc. dba Pulsara, and its related companies ‎‎(“We”), collect, use, disclose, transfer, store and dispose of your personal information. It also contains information about how you ‎may request access to, or correction of, your personal information and how you may make a complaint ‎regarding our handling of your personal information. ‎


We are subject to Canada’s federal Personal Information Protection and Electronic Documents Act and, in some circumstances, to other applicable provincial privacy (or health privacy) legislation.

This Privacy Policy applies in Canada in respect of the “Pulsara Platform” (delivered via “App” or “Application”, or via a web browser), the ‎website http://pulsara.com/ (“Website”), any other Pulsara products or services (“Pulsara Services”) and any other personal information which we collect, hold, use or disclose. It applies to healthcare workers, patients and any other individuals who visit our Website or otherwise provide us with personal information. This is important information. Please read it carefully.


What is Personal Information?‎


Generally speaking, “personal information” is information about an identifiable individual, other than business contact information. Information or an opinion about an identifiable individual may be ‎personal information (regardless of whether it is true). For the purpose of this Privacy Policy, personal ‎information also includes personal health information as may be defined in applicable Canadian provincial laws.‎


Collection of Personal Information

For Healthcare Workers

When Operators download, register with and use our App, we will collect personal information about them (“You”). This may ‎include personal information that: (1) you submit via the App, such as personal information you provide ‎when you create your personal account, add information to your user profile or contact us with questions or ‎for help; and (2) the hospital or other healthcare facility/provider on behalf of which you are providing ‎health care services to patients in connection with the App provides about you, such as applicable details of your ‎employment (as noted above, the “Organization”).‎


The Application is to be used by you in connection with your provision of medical services to patients. By using the Application, you agree that we can collect and use your personal and other information as described in this Privacy Policy. If you don't agree, please don't use the App.

The personal information we collect includes:

  • Your name, email address, user name, password, department, licensure level, and other registration information.‎
  • If you elect to use the “record” functionality in the App, we will collect audio and/or visual recordings of you.‎
  • Information about your mobile device which you use to access the App, which is limited to information ‎regarding the brand, make, and model and type of operating software your device uses. This ‎information may be personal information when combined with other information we hold about you.‎
  • Your 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 determine your approximate distance from the hospital or ‎other health care facility where a patient is being transported.‎


We may also hold (but do not collect) personal information relating to you that appears in the medical and treatment information of your patients, such as patient treatment response times, and communications about patients transmitted by you the Organisation and other providers who provide healthcare services to your patients.


Your use of the App is governed by the End User License Agreement (“EULA”) you enter into and agree ‎to ‎by downloading the App. To the extent that there is a conflict between this Privacy Policy and the ‎EULA, the ‎EULA will prevail with respect to your use of the App and this Privacy Policy will prevail with ‎respect to our ‎collection, use, disclosure and storage of your personal information.‎

In the course of providing services to Organizations, we may receive or create documents or other communications containing personal health information related to individuals served by you. We will only use and disclose this personal health information as necessary to perform our services for those healthcare providers and Organizations and only as permitted or required by law.

For Users of the Website

We will collect personal information about you when you visit the Website, contact us via the Website, subscribe for updates or otherwise provide any information via the Website, whether for publication or otherwise.


The personal information we may collect via the Website includes:

  • Contact information including name, email address, and any other information you elect to submit via the Website.
  • Technical information, including the domain and host from which you access the Internet, the Internet Protocol (IP) address of the computer you are using, the browser software and operating system you are using, the date and time that you access our Website, the specific pages you visit at our Website, the number of visits you make to our Website, the number of visits to specific pages you make at our Website and products or services viewed at our Website.
  • Information from “Cookies”, which are small pieces of information which the Website stores on your device in order to identify you when you subsequently visit the Website and can later retrieve.
  • Information from “web beacons”, which are graphic image files embedded in web page used to monitor activity on a web page and send back to a server of the host site, a network advertiser or some other third party information from your browser, such as the IP address, the URL of the page on which the beacon is located, the type of browser that is accessing the site, and the ID number of any cookies on your computer previously placed by that server.
  • We may also permit you to provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are entirely optional and are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.

We do not advertise on our website. However, we do use third- party cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about their behavior on this and other websites in order to serve them interest-based targeted (behavioral) advertising solely about our product when visiting other interest-based websites served by our third-party advertising network.


Please be aware that our Website may have links to third-party websites that may collect personal information about you. When you click on one of these third-party links, you are entering another website for which we have no responsibility. This Privacy Policy does not cover the information practices or policies of such third-party websites. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy.

For Patients

If you are treated by a healthcare provider who is using a Pulsara Service, your personal information ‎‎‎(including health information) is collected by and remains under the control of the Organization that your healthcare provider works for or is ‎‎providing services to, not Pulsara. Having said that, your personal information will be handled by ‎Pulsara in accordance with this Privacy Policy and the applicable contract between Pulsara and the Organization.

When you download the App to interact directly with a healthcare provider using Pulsara, verify your identity, and use the App, we collect information by which you may be personally identified such as your name, email address, and phone number (“Personal Information”). This may include personal information that we collect from (1) you when you provide such information, such as when you create your personal account, add information to your user profile, or contact us with questions or for help; and (2) the hospital or other healthcare facility/provider from whom you are receiving medical services through this App (“Organization”).

The Personal Information we collect may include:

  • Your phone number, device ID, type of device and operating system you use, your IP address, and certain metadata about calls you participate in, such as who participated and the time of the call.
  • Other information you input into the App or related services, including search terms and requests for ‎‎information.‎
  • Audio and/or video recordings made via the App.
  • Your personal health information entered or recorded via the App.
  • Information about your mobile device which you use to access the App, which is limited to information ‎‎regarding the brand, make, and model and type of operating software your device uses. This ‎information ‎may be personal information when combined with other information we hold about you.‎

Your use of the App is governed by the End User License Agreement (“EULA”) you enter into and agree ‎to ‎by downloading the App. To the extent that there is a conflict between this Privacy Policy and the ‎EULA, the ‎EULA will prevail with respect to your use of the App and this Privacy Policy will prevail with ‎respect to our ‎collection, use, disclosure and storage of your personal information.‎


We may also collect personal information about you if you enquire about our products and services, if you are a staff member of one of our customers (whether or not you actually use any Pulsara Services, and if you are a staff member of one of our suppliers or other business partners.


Use and Disclosure of Personal Information

For Healthcare Workers

We may use and disclose personal information:

  • To administrate and provide you with the App and its contents and functionalities, and any other information, products or services that you ‎request from us.‎
  • To facilitate communications between you and other healthcare providers and the Organization.
  • To help you and the Organization keep a useful record of health care treatment and health-related information.‎
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and ‎us or the Organization and us.
  • To notify you when App updates are available, and of changes to any products or services we offer or ‎provide though it.‎‎
  • As necessary, to send patients’ healthcare information to you, the Organization and/or other healthcare ‎providers in an emergency, to allow you and them to provide effective care to patients.‎
  • To improve the quality of health care through the performance of quality reviews and similar activities.‎
  • Subject to applicable legal requirements, to conduct health-related research. We will not publish information ‎in peer-reviewed articles that identifies you personally unless you have agreed to this in writing prior to publication.‎
  • To meet legal requirements and to act in accordance with legal authorizations (including purposes authorized by applicable privacy and other law).
  • In any other way we may describe at the time you provide the information, or to fulfill any other purpose for which ‎you provide it or for any other purpose for which you have provided your consent.

We ‎may also need to access and use personal information outside of Canada for the purpose of providing ‎support services to users of the Pulsara Services.‎ Your personal information transferred or stored outside Canada will be accessible by law enforcement and/or regulatory authorities according to the applicable laws of the non-Canadian jurisdiction.
For Users of the Website

We may use and disclose personal information:

  • To provide you with our Website and its functionalities and contents.‎
  • To respond to your enquiries, complaints, and other communications.‎
  • To contact you with information about our products and services, including updating you on special offers, ‎product announcements and other information related to our products and services.‎
  • To cross-reference with other personal information we may have acquired about you or may acquire about ‎you through other sources for profiling and/or demographic purposes including, for example, information gathered from you at trade shows and similar events or by virtue of your interaction with us on social media platforms.‎
  • To meet legal requirements and to act in accordance with legal authorizations (including purposes authorized by applicable privacy and other law).
  • In any other way we may describe at the time you provide the information, or to fulfill any other purpose for which ‎you provide it or for any other purpose for which you have provided your consent.
  • We will transfer your personal information and store it outside of Canada, primarily in the United States.

We may also use your personal information to provide you with information about our products and ‎services, special offers, product announcements, and information about the healthcare industry generally, if you sign-up for such communications (for example, via our Website).‎


We may also occasionally contact you to gather customer service information to help us determine how we ‎can improve our services and products to better meet your needs. We may also use your personal ‎information to send you special promotional offers related to our service, where authorized by law.‎


We use the technical information we collect from you to generate aggregate statistics about visitors to our ‎Website. We may also collect, aggregate and maintain anonymous information about the visitors to our ‎Website. This data can then be used to tailor the Website’s content and advertising to deliver a better ‎experience for our visitors. We may further share such aggregate information about our visitors with ‎advertisers, business partners, sponsors and other third parties.‎

For Patients
We may use and disclose personal information:

If you are treated by a healthcare provider who is using a Pulsara Service, we will use and disclose your ‎‎personal information (including health information) which your healthcare providers submit via the Pulsara ‎Services solely for the purpose of providing the Pulsara Service. We may disclose your personal ‎‎information to other healthcare providers who are providing services to you and the Organization(s) they ‎‎work for, to allow them to provide care to you.

We may use Personal Information that we collect or you provide:

  • To provide you with the App, including its contents and functionality, and any other information, products, or services that you request from us.
  • To facilitate communications between you and your healthcare providers.
  • To help you and the Organization keep a record of health care treatment and health-related information.
  • To further our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the App, improving our services, and identifying usage trends; and
  • To act as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce our Terms and Conditions of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • To notify you when App updates are available, and of changes to any products or services we offer or provide though it.
  • To meet legal requirements and to act in accordance with legal authorizations (including purposes authorized by applicable privacy and other law).
  • In any other way we may describe at the time you provide the information, or to fulfill any other purpose for which ‎you provide it or for any other purpose for which you have provided your consent.

Disclosures of Personal Information
In addition to any specific disclosures described elsewhere in this Privacy Policy, we may disclose your ‎personal information:

  • To our subsidiaries and affiliates, whether in Canada or otherwise for purposes outlined in this Policy‎.
  • To trusted contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose it to them.
  • As authorized or required by law, which can include providing information as required by a court order or subpoena.
  • When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to ‎protect our rights, to investigate fraud, or to respond to a government request.‎
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or ‎other sale or transfer of some or all of Pulsara’s assets, whether as a going concern or as part of ‎bankruptcy, liquidation or similar proceeding, in which personal information held by Pulsara about our App ‎users is among the assets transferred.‎
  • For any other purpose disclosed by us at the time you provide the information.‎

We may also disclose your personal information to third parties for the following legal reasons: (1) to comply ‎with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; (2) to protect ‎and defend us, our subsidiaries and affiliates, and all of their officers, directors, employees, attorneys, agents, ‎contractors and partners, in connection with any legal action, claim, or dispute, and to assert our legal rights where we believe in good faith that this is necessary; (3) to prevent imminent ‎physical harm, such as a physical threat to you or others; and (4) in the event that we find that your actions on ‎our Website or App violate any laws, our Terms of Use, or any of our usage guidelines for specific products or ‎services and reasonably believe we must take action to address this. In the event that we are legally compelled to disclose your personal information to a third party, we ‎will attempt to notify you unless doing so will violate the law or a court order.‎

How We Hold, Store and Secure your Personal Information


To the extent possible, we want to be sure that your personal information is secure, and can't be misused. ‎Therefore, we take steps to protect the security of your personal information which we hold. We hold your ‎personal information:‎

  • On secure servers. We may keep more than one copy so that if one is damaged, another remains available;‎
  • Using electronic security measures such as firewalls and encryption. Encryption changes data into a mathematical code ‎so that unauthorized people can't read it. It helps protect your Personal Information; ‎
  • Only as long as it is needed for the purposes for which it was collected, or for reasonable business and legal purposes;
    Using physical security measures, such as a locked data centre; and
  • In accordance with our administrative security measures, including policies and rules about how our ‎employees access and use Personal Information and who is permitted to access and use Sensitive Information.‎

By using several different kinds of security measures, we endeavour to protect your personal information. However, no ‎security system is perfect, and no security system can prevent all security breaches.‎


While we seek to safeguard the security of your personal information, we also urge you to take every precaution to protect your personal information when you are on the Internet. Despite our efforts to protect your personal information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your personal information over the Internet will be intercepted. Therefore, we cannot guarantee the absolute security of your personal information, nor can we guarantee that information that you provide will not be intercepted while being transmitted to us over the Internet.


Ways You Can Control the Personal Information We Collect or Use: ‎

For Healthcare Workers
The only way you can opt-out of our collection, use and disclosure of your personal information is to not to download or use the Application.
For Users of the Website

To opt out of our collection, use and disclosure of your personal information, please do not provide your personal information to us. 


You are not able to opt out of the uses of your technical information as described in this Privacy Policy. ‎However, you have the ability to manage the use of cookies on your device using controls in your browser. ‎To learn more about how to manage cookies, visit http://www.allaboutcookies.org‎. At this time, we are not ‎honouring “do not track” signals from web browsers. If you do not wish for us to collect your information via cookies, ‎please follow the opt out procedure.‎

For Patients

When you download the App to interact directly with a healthcare provider using Pulsara, understand that the App will be collecting and transmitting personal, medical, and health-related information. BY USING THIS APPLICATION, YOU AGREE THAT WE MAY COLLECT, AND USE, TRANSFER, STORE, DISCLOSE AND DISPOSE OF YOUR PERSONAL AND OTHER INFORMATION as described in this Privacy Policy and the Agreement. If you don't agree, please don't use the App.


If you have received treatment from a healthcare worker via our App, any access/correction request relating to your personal information must be directed to the applicable Organization, as the Organization will control such personal information.


Changes to Our Policies

This Privacy Policy is effective as of Feburary 1, 2021. This Privacy Policy may be updated from time to time, for various reasons. We will tell you about changes to the ‎Privacy Policy for example by posting the new Privacy Policy on the Website, or by inserting a new pop-up box in the ‎App. If you have given us your email address, we might also send the new Privacy Policy to your e-‎mail address (for example, when significant changes are made). It is a good idea to review the Privacy Policy from time to time, both to check for changes, and ‎to remind yourself of how your personal information is collected, used, disclosed, transferred and stored by us.‎

Any revised Privacy Policy will only apply prospectively to personal information collected or modified after the effective date of the revised policy. Modifications will be effective immediately. You accept any such modifications to this Privacy Policy by continued use of our Website and/or App after such modifications are made.

Keeping Kids Safe.

We do not intentionally collect information about children under 13 years old unless a parent or guardian expressly consents to collection of information about that child. If we find out that a user who has provided personal information is under 13 and has not received parental permission, all personal information entered by the user will be permanently deleted. If a parent or guardian becomes aware that a child under 13 years old has provided personal information to us without their consent, please contact us at privacy@pulsara.com. We will permanently delete that information within a reasonable time.

Children under the age of 18: THIS APP IS NOT INTENDED FOR USE BY CHILDREN UNDER THE AGE OF 18. Use by an individual under the age of 18 without parental or guardian consent and supervision is a violation of the Agreement.

Contact Us

If you have any questions, comments, requests, or concerns regarding this Privacy Policy or your privacy with Pulsara generally, ‎please contact us via email at the following address:‎

Or in writing to:‎

CommuniCare Technology, Inc., dba Pulsara
‎2880 Technology Blvd. W., Suite 183‎
Bozeman, MT 59718‎
United States of America