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 mobile applications (“App” or “Application”), the ‎website http://pulsara.com/ (“Website”), any other Pulsara products or services (“Pulsara Services”) and any ‎other personal information which we collect, use, disclose , transfer or store (other than patient end user personal information, which is addressed in our separate Pulsara Canadian Patient End User Privacy Policy .

This Privacy Policy applies to health care workers employed by Pulsara’s health entity customers (“Organizations”) who utilize the App or visit our Website in connection with providing health care services to patients (such health care workers are hereinafter referred to as “Operators”). This Privacy Policy also applies to any other individuals who visit our Website or who otherwise provide us with personal information in the context of our commercial operation. This Privacy Policy does not apply to the personal information of our employees, directors, or officers.

This Privacy Policy contains ‎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

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 App is to be used by you in connection with your provision of medical services to patients. By ‎using the App, 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 or use for Pulsara’s purposes) 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 to the Organization and other providers who provide healthcare services to ‎your patients.‎

Your use of the App is governed by the End User License Agreement (“EULA”) which you agree to when 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, transfer 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 do not advertise third party products 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 you. This may include information about your behaviour on our Website and other websites in order to serve you interest-based targeted (behavioural) advertising (solely about our product) when visiting other interest-based websites served by our third party advertising network.

Personal Information collected on our Website is gathered, for example, through our "Contact Us" form. In the Contact Us form, fields are provided so that users can submit questions or comments and provide contact information including name, email address, and any other data elements they may choose to provide.

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.

Purposes for Collection, Use and Disclosure of Personal Information.‎

We may collect, use and disclose personal information of Operators for the following purposes:‎

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 respond to your enquiries, complaints, and other communications.‎

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).

To achieve marketing purposes as described further below.

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 collect, use and disclose personal information of users of our Website for the following purposes:‎

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.‎

In any other way we may describe when you provide the information, or to fulfill any other purpose for which ‎you provide it or for any other purpose with your prior consent. ‎

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 health care 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.‎

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 (including insurers) and other third parties we use to support our business.‎

As required by law, which can include providing information as stipulated in a court order.‎

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.‎

Transfer of Personal Information outside of Canada

We will transfer your personal information and store it outside of Canada, primarily in the United States.  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.‎

We may also disclose your personal information to recipients who are located outside of Canada, in countries ‎including the United States, for the purposes outlined in this Policy

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.

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; ‎

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 try to protect your personal information. However, no ‎security system is perfect, and no security system can prevent all security breaches.‎ We take steps to ensure, as much as possible, that we will be prepared to take appropriate steps in the event of any information security breach.

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: ‎

The only way health care workers can opt-out of our collection, use and disclosure of their personal information is to not ‎download or use the App.

To opt out of our collection, use and disclosure of your personal information while you are using our Website, please do not provide your ‎personal information to us via the Website. ‎

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.‎

Changes to Our Policies

This Privacy Policy is effective as of 12/17/2020. 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 e-mail 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.

Access to and Correction of Your Personal Information

You may access or request correction of the personal information that we hold about you by contacting us.  ‎Our contact details are set out below. There are some circumstances in which we are not required to give you ‎access to your personal information (for example, when it is subject to solicitor-client privilege or when it is inextricably linked with a third party’s personal information). ‎

There is no charge for requesting access to your personal information but we may require you to meet our ‎reasonable costs in providing you with access (such as photocopying costs or costs for time spent on ‎collating large amounts of material). ‎If we require you to cover costs, we will provide you with an estimate of such costs, so that you may decide whether you wish to continue with your access request.

We will respond to your requests to access or correct personal information within a reasonable time (and within any applicable statutory deadlines) and will take ‎all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date ‎and complete.  ‎

Complaints

If you have a complaint about the way in which we have handled any privacy issue, including a request for ‎access or correction of your personal information, you should contact us. Our contact details are set out ‎below.‎

We will consider your complaint and determine whether it requires further investigation. We will notify you of ‎the outcome of our investigation. ‎

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an ‎independent advisor or contact the Privacy Commissioner of Canada.

Third Party Websites. 

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.

 

How to Opt Out. 

To opt out of our communications, please do not provide your personal information to us, or after providing your personal information to us, please send written notification to us that you no longer wish to receive information and communications from us or otherwise share your personal information with us. With respect to our use of technical information, you are not able to opt out of the uses set forth in this policy. However, you have the ability to manage the use of cookies on your computer using controls in your browser. To learn more about how to manage cookies, visit http://www.allaboutcookies.org. At this time, we are not honoring “do not track” signals from Web browsers. 

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.

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:‎

privacy@pulsara.com

Or in writing to:‎

CommuniCare Technology, Inc., dba Pulsara

‎2880 Technology Blvd. W., Suite 183‎

Bozeman, MT  59718‎

United States of America

 

Updated: 12/17/2020