TulipHealth Privacy Policy

This Privacy Policy (“Policy”) summarizes how Tulip Health collects, uses, discloses, retains, disposes of, destroys and protects Information as well as Data (information that does not identify an individual) in the course of providing our services. We are committed to complying with this Policy and with applicable Provincial and Federal privacy legislation.

Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Physicians or Authorized Non-Physician Providers. Authorized Physicians and Authorized Non-Physician Providers are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use and retain in the course of providing services through the Tulip Health Platform. Please feel free to ask any Authorized Physician or Authorized Non-Physician Provider to whom you are referred if you have questions about how he or she will treat your Information.

Collecting and using Information

Tulip Health collects and uses Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes. As mentioned, Authorized Physicians and Authorized Non-Physician Providers are responsible for their collection, use, disclosure, retention, destruction and protection of Information. As a result, the following description is an overview only of the use generally made of Information for the purpose of providing services through the Tulip Health Platform. A particular Authorized Physician or Authorized Non-Physician Providers may or may not chose to collect or use Information as described below in connection with a particular interaction with a User.

Healthcare Services

Authorized Physicians and Authorized Non-Physician Providers may collect Information about you or any Registered Dependent (as defined below) when you provide it during a Healthcare Services consultation (e.g., verbally or in texts), by viewing the Information that you have entered or uploaded to the Tulip Health Platform and/or by creating or compiling Information in the Tulip Health Platform. Information that will be available to Authorized Physicians and Authorized Non-Physician Providers includes: the details that you provide in your consultation request; information you’ve entered or uploaded to profiles and medical records; information created during earlier interactions through the Tulip Health Platform with other Authorized Physicians and/or Authorized Non-Physician Providers; the name, email address, phone number, gender and date of birth and province/territory that you provided when you registered; and your emergency contact’s name and contact information. Authorized Physicians and Authorized Non-Physician Providers use Information to provide you with Healthcare Services and/or Informational Services and, as with any healthcare provider, must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Physicians and Authorized Non-Physician Providers may create Information such as prescriptions, sick notes and other notes about your interaction with them through the Tulip Health Platform. They may export or print copies of your Information that they collect. Authorized Physicians and Authorized Non-Physician Providers may, but are not required to email or text your emergency contact if they believe that you are dealing with a medical emergency during a consultation. You are responsible for advising your emergency contact that you are providing their name and contact information to Tulip Health and Authorized Physicians and Authorized Non-Physician Providers, and for obtaining any necessary consent from them for the provision and use of their information in connection with the Tulip Health Platform.

Informational Services

Authorized Physicians and Authorized Non-Physician Providers collect and use Information that you provide in the course of obtaining Informational Services, by viewing the information that you have entered or uploaded to the Tulip Health Platform and by creating or compiling Information in the Tulip Health Platform. Authorized Physicians and Authorized Non-Physician Providers are bound to comply with privacy legislation applicable to providers of Informational Services.

Provision of the Tulip Health Platform

We collect and use your Information to register you, create your User Account, authenticate you when you log in and personalize your experience while using the Tulip Health Platform. We confirm your eligibility to use the Tulip Health Platform for Healthcare Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.

You may choose to enter or upload and store your Information in the Tulip Health Platform such as your medical records, and the name and contact information for your emergency contact.

When seeking Healthcare Services, you may also choose to enter or upload and store Information about individuals for whom you have the legal authority to make decisions regarding their healthcare and for whom you have created a profile by providing their first and last name, gender and date of birth (each a “Registered Dependent”). We use their date of birth where applicable and your assertion of their relationship with you to confirm your eligibility to obtain Healthcare Services for them, and their eligibility to receive Healthcare Services.

We use Information that you enter, or upload, or which is created as part of an interaction with an Authorized Physician or Authorized Non-Physician Provider to make it available to you when you access your User Account.

We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements;

Users eligible for Healthcare Services:

To request Healthcare Services, you select any applicable symptoms relevant to your request. You may also specify whether you’re seeking to renew a prescription or obtain a sick note. We facilitate your disclosure to the Authorized Physician or Authorized Non-Physician Provider of that information, along with age and gender to determine whether your request is eligible. We do not identify you, or, if applicable, the Registered Dependent for whom you’re seeking the Healthcare Services. Once the Authorized Physician or Authorized Non-Physician Provider confirms that your request is eligible, we identify the Authorized Physician or Authorized Non-Physician Provider to you. The Tulip Health Platform presents to the Authorized Physician or Authorized Non-Physician Provider the Information you provided in your consultation request, your name and, if applicable, the name of the Registered Dependent for whom you’re seeking the consultation. Unless you have elected to withhold access to information held in the Tulip Health Platform about you or any Registered Dependent, the Authorized Physician or Authorized Non-Physician Provider will be able to view it too. We use Information that you enter to provide you with services that you request us to perform on your behalf, e.g., securely faxing your prescription to your chosen pharmacy. We use your Information to text or email you to notify you about services that you request.

Users eligible for Informational Services:

When you request Informational Services, you select any topics for which you are seeking education. On your behalf, we present the information that you provide to an Authorized Physician or Authorized Non-Physician Provider to determine whether your request is eligible for Informational Services. We do not identify you. Once the Authorized Physician or Authorized Non-Physician Provider confirms that your request is eligible, we identify the Authorized Physician or Authorized Non-Physician Provider to you. The Tulip Health Platform presents to the Authorized Physician or Authorized Non-Physician Providers the Information you provided in your request for Informational Services and your name. We use your Information to text or email you to notify you about services that you request,

Communicating with you

Should you submit Information about a medical issue, which is deemed an emergency by an Authorized Physician or an Authorized Non-Physician Provider prior to their acceptance of your request for Healthcare Services, Tulip Health reserves the right to contact you at any time using any of the contact information you have provided. This contact is strictly for the purpose of informing you that an Authorized Physician or Authorized Non-Physician Provider has viewed your anonymized request and has declined the request based on their belief that your symptoms may represent a medical emergency.

Disclosing Information

We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Physicians or Authorized Non-Physician Providers, emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Tulip Health’s legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person.

We may disclose Information for the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.

Retaining and disposing of Information

Unless we otherwise give you notice, we will retain your Information on the Tulip Health Platform on your behalf until such times as you or we terminate your User Account. On termination, you will have an opportunity to print or make copies of your Information subject to the following. To ensure that Authorized Physicians and Authorized Non-Physician Providers may exercise any authority they have to withhold Information they compile in connection with Healthcare Services from patients under the law, you will be required to request any access you would like to notes made by an Authorized Physician or an Authorized Non-Physician Provider about your consultation from the Authorized Physician or Authorized Non-Physician Provider. As mentioned above, Tulip Health is not the custodian of Information held on the Tulip Health Platform; rather it holds Information on behalf of Users or Authorized Physicians and Authorized Non-Physician Providers. On termination of your User Account, once you have been given the opportunity to print or make copies of your Information, we will delete the Information associated with your User Account, except Information that an Authorized Physician or Authorized Non-Physician Provider advises us he or she requires in connection with a consultation or Informational Services the Authorized Physician or Authorized Non-Physician Provider provided. In such circumstances, Tulip Health will destroy the Information when the Authorized Physician or Authorized Non-Physician Provider has obtained a copy or terminates his/her account with Tulip Health.

Accessing and correcting Information

Healthcare Services

You can access your Information or that of your Registered Dependents to check that it is accurate, complete, and up to date by making a request to info@tuliphealth.ca.

You may update and edit any of your Information except Information an Authorized Physician or Authorized Non-Physician Provider has viewed or created Information during a Healthcare Services consultation making a request to info@tuliphealth.ca. Contact the Authorized Physician or Authorized Non-Physician Provider who provided the Healthcare Services to access or request the correction of Information in their notes on the Tulip Health Platform or that they hold in their medical records.

Informational Services

You can access Information you provided in your request(s) for Informational Services by making a request to info@tuliphealth.ca.

Your choices

You may choose whether to use audio, chat, or video for interactions with Authorized Physicians and Authorized Non-Physician Providers.

When seeking Informational Services, any previous Information collected, will not be accessible by the Authorized Physician or Authorized Non-Physician Provider providing the services unless you specifically elect to provide access.

You may choose whether to receive communications by email or SMS.

Please contact us directly at info@tuliphealth.ca for assistance with using the privacy functionality or with any questions about using the Tulip Health Platform. Additionally, you may contact us at any time to: stop receiving e-mails or other correspondence from us, seek assistance with viewing and correcting Information, and close your User Account. To protect privacy, we may request information to verify your identity when you contact us.

Safeguarding Information

Tulip Health takes the security of your information seriously. We store your information in electronic format within Canada, using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Tulip Health Personnel are obligated to protect Information by adhering to our policies

Cookies and similar technologies

The Tulip Health Platform, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. We use these technologies to better understand User behaviour, analyze trends, administer, personalize and improve the experience of using the Tulip Health Platform. You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, the Tulip Health Platform might not function correctly. At times, we may use third parties such as ad exchanges and data companies to serve our advertisements on the Tulip Health Platform. These companies may also use cookies and other technologies to report certain information about your visits to the Tulip Health Platform and other websites (such as web pages you visit from and your response to ads on the Tulip Health Platform) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Tulip Health Platform. By using the Tulip Health Platform and not turning off cookies, you are consenting to their use for the purposes described in this Policy. To learn more about advertising on electronic sites and opting-out of receiving ads, you can visit the Digital Advertising Alliance website at www.aboutads.info/choices/ or the Digital Advertising Alliance of Canada website at www.youradchoices.ca/choices.

Links and third party websites and applications

The Tulip Health Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.

Contact Us

If you have any questions, concerns or suggestions about our privacy practices, please contact . Please include your name and contact information if you’d like us to respond to you.

Tulip Health info@tuliphealth.ca 647-326-4285 2467 Bloor St W. Toronto, ON M6S 1P7

Definitions

“Authorized Physician” means a physician who is registered to practice medicine in a Province or Territory of Canada, meets Tulip Health’s other criteria, and is permitted to provide Healthcare Services and/or Informational Services through the Tulip Health Platform.

“Authorized Non-Physician Provider” means an independent, regulated health professional (such as a psychotherapist or a nurse) registered to provide healthcare in a Province or Territory of Canada, meets Tulip Health’s other criteria, and is permitted to provide Healthcare Services and/or Informational Services through the Tulip Health Platform.

“Data” means information collected or compiled through the Tulip Health Platform which has been de-identified.

“De-identify” in relation to PHI, means to remove information that identifies the individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify the individual.

“Device” means a mobile or desktop device owned or controlled by a User and used to access Tulip Health Physician Services.

“Health Care” means any observation, examination, assessment, care, service or procedure that is provided by a physician or a non-physician healthcare provider to an individual to diagnose, treat, or maintain the individual’s physical or mental condition, to prevent disease or injury to the individual, or to promote the individual’s health.

“Healthcare Services” means the provision of Health Care by an Authorized Physician or an Authorized Non-Physician Provider through the Tulip Health Platform.

“Informational Services” means the provision of general information about a disease or condition, rather than patient specific medical information, for educational purposes only and for clarity, not including a diagnosis, treatment or advice based on observation, examination or assessment of a particular patient.

“Tulip Health Platform” means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Physicians and Authorized Non-Physician Providers to provide Healthcare Services and Informational Services to Authorized Users.

“Personal Information” means information about an identifiable individual which is not PHI and which is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Tulip Health Platform.

“Personnel” in relation to Tulip Health, means its employees and agents including independent contractors and sub-contractors, for whom Tulip Health is responsible at law.

“PHI” or “personal health information” means information about an individual’s health or healthcare that is subject to Privacy Law and that is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Tulip Health Platform.

“Privacy Law” means the applicable legislation governing the collection, use, disclosure, and/or protection of PHI in the Province or Territory in which a User resides.

“User” means an individual who has registered and created a Tulip Health User Account in accordance with our Terms of Use and is thereby eligible to receive Healthcare Services and/or Informational Services through the Tulip Health Platform.