Privacy Policy

Updated: November 1, 2022
Cloud Practice Inc. (“Cloud Practice”) and its parent company WELL Health Technologies Corp. (“WELL”), are proud to offer you the JunoEMR website (the “Website”) and electronic medical record (“JunoEMR”). 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.
We will update this Privacy Policy as necessary. Please check it regularly.

1. What information do we collect?
   Website Access
   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 for the purpose of 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.
   Website Form
   When you submit a form on the Website, or contact us directly, we will collect information like your name, e-mail, phone number, clinic/organization you work for, information about your clinic or organization, and the province in which the clinic or organization is located. This information will be used by Cloud Practice or WELL to communicate with you to provide you with the information you requested.
   Electronic Medical Record
   JunoEMR is a cloud based EMR that enables the collection of personal health information by health care practitioners and provides the ability to store and retrieve all appointment, lab and consult information. As a health care practitioner using JunoEMR, information like your name, clinic, and contact details will be collected by Cloud Practice to administer your account (“Account”). As a patient of a health care practitioner that is using JunoEMR, all personal health information in relation to your visit with the health care practitioner can be securely stored on JunoEMR. Cloud Practice does not collect or use any patient information and will only ever access patient information if WELL is requested to provide technical assistance by the healthcare practitioner. If technical assistance is provided, no patient information is collected or saved by Cloud Practice.
   Direct marketing
   If you sign up to receive direct marketing or promotional communications from WELL, we will collect your name and e-mail to inform you about WELL and our products and services.
2. Why do we use personal information?
   We use your personal information to:
   • manage our relationship with you and provide you with the information or services you request,
   • conduct research and evaluate research and development on the Website including analyzing testing data to improve our services,
   • communicate with you regarding inquiries for information or customer service request or employment opportunities,
   • detect, prevent or investigate security breaches,
   • process credit card or other payment information as agreed to on the Website,
   • protect our business, and
   • maintain appropriate records for internal administrative purposes.
   Cloud Practice reserves the right to aggregate and anonymize Account information (or other information) and use such aggregated information as it sees fit.
   Cloud Practice does not use any patient personal health information for any reason, and will never access any patient personal health information stored within the EMR, unless required to provide technical assistance to health care practitioners.
3. Who do we share the personal information with?
   We only share your personal information with service providers in order to operate the Website and JunoEMR and offer you the information or services you request. This includes sharing your personal information for
   • fraud prevention,
   • payment processing,
   • providing requested services or information,
   • operating the Website, and
   • customer service.
   We only use service providers that ensure a comparable level of protection for your personal information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information for the services requested.
   Exceptionally, as allowed or required by law, we may have to disclose your personal information to law enforcement agencies where they demonstrate they have the legal authority to request it.
   If we merge with another business, we will inform you of any impact on your personal information.
4. How long do we keep personal information?
   We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with applicable legal and regulatory requirements.
   Health care practitioners using JunoEMR are required to comply with different statutory and regulatory requirements and store personal health information for a minimum length of time. We encourage you to speak with your healthcare practitioner directly on how long they are required to store your personal information.
5. How do we keep personal information accurate?
   We take reasonable steps to ensure that any personal information in our custody is accurate and up-to-date but we mostly rely on you to notify us of any changes to personal information you provided us.
6. How do we protect your personal information?
   We use reasonable and appropriate physical, administrative and technical measures 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 Cloud Practice is prohibited and constitutes grounds for disciplinary action.
   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.
7. Where do we store personal information?
   All personal information we collect is stored on secure servers in Canada; however, personal information processed by our third-party service providers may be done outside of Canada.
   While outside of Canada, personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.
   For more information on our service providers or where we store personal information, contact us at privacy@well.company.
8. Links to third-party sites
   Our Website may lead you to third-party websites, including websites advertising other products or services. Those organizations are separate and distinct from Cloud Practice or WELL and have their own separate privacy policies. We are not responsible in any way for how any third-party collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies of these websites before providing your personal information to them.
9. Direct marketing
   You may sign up to receive marketing or promotional communications from WELL. 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 destroy your information as soon as you unsubscribe.
10. Your rights
    You also have the right to:
    • make a written request to access your personal information,
    • request us to restrict our use or disclosure of your personal information,
    • object to our use or disclosure of your personal information,
    • request that we edit, but not remove, certain information (like an e-mail address),
    • request that we transfer to another organization the personal information you have provided us, and
    • request us to delete the personal information we hold about you.
    Contact us at privacy@well.company to exercise any of these rights. 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.
11. Contacting us
    Accountability with respect to your personal information is important to Cloud Practice. In the event that you have any questions (including how personal information is managed by Cloud Practice), 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.