CuePath Privacy Notice
In compliance with British Columbia’s Personal Information Protection Act (PIPA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and The United States’ Health Insurance Portability and Accountability Act Privacy Rule (HIPAA) our Privacy Notice is designed to provide transparency into our privacy practices and principles. Our Privacy Officer is accountable for compliance with privacy legislation and our policies.
Personal information means information about an identifiable individual.
Personal information does not include anonymous information – aggregate or de-identified data – which is information we collect about the use of our website and service or about a group or category of service or users, from which individual identities or other personal information has been removed.
What information we collect
We will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. By giving us personal information when you use our website or service, you consent to your information being collected, used, disclosed and stored by us, only as described in this Privacy Notice.
A pharmacist provides CuePath with the personal information we collect to create an account and a unique CuePath identification number, called a “MedID”, for a patient. This information includes:
- First name
- Last name
- Date of birth
- Phone number
- Email address
A family member, friend or care team member may use the MedID to create an account with CuePath to receive reminders, alerts and notifications about the patient’s medication schedule and adherence. The personal information collected to create the account includes:
- First name
- Last name
- Phone number
- Email address
We will mark information that is not required to provide the service as optional.
When you use our website or service, some information is automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring website, and your activity on the website or during the use of the service. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate only, without personal identifiers.
CuePath does not knowingly or intentionally collect personal information from users who are under the age of 18.
How we use information we collect
We will only use personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes.
We use personal information to:
- To generate a unique CuePath identification number (“Med ID”);
- To send alerts, notices and reminders about scheduled medications;
- To initiate emails, text messages and phone calls from the service;
- To generate medication schedule and adherence reports; and
- Contact you about updates and with notifications relating to our service. For example, we use your email address to let you know about new features and upgrades; and
- For internal business purposes.
We may also use personal information to:
- Assist you with technical support issues. Most technical issues can be resolved without our support team viewing your personal information.
- Comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect CuePath and other individuals as permitted by law.
The promises in this Privacy Notice will apply to your personal information in the event that CuePath is involved due diligence or any corporate action related to financing, bankruptcy, merger, acquisition, reorganization, or a sale of assets. However, your information may be transferred to another entity as part of that transaction.
We may use anonymous information, aggregate or de-identified data that does not identify an individual, to:
- Monitor system usage, server and software performance, to improve system design, to create benchmarks and to conduct trending analyses.
- Perform statistical analyses and generate data related to how our website and service are used.
How we share information we collect
We will only share (“disclose”) personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes.
We may use third parties to help deliver our website and service. In those circumstances, we may share your information with our affiliates or sub-contractors to facilitate providing the service you have requested. In all cases, we will have contracts in place to ensure service providers protect your personal information in compliance with applicable privacy legislation.
We will never ever sell, lease, license, or in any other way commercially distribute your personal information to third parties.
We may share anonymous data with third parties but the information will not identify you specifically.
Updating your information or deleting your account
At any time and without penalty, you can withdraw your consent and delete your account by contacting your pharmacist or CuePath at email@example.com.
Deleting your account permanently deletes your personal information from our database. Once your account is deleted, you will no longer be able to use our service. If you later decide you would like to use our service again, you will have to contact your pharmacist to create a new account.
You can opt-out of most email communication from us by clicking on the unsubscribe link at the bottom of our emails. We may still contact you for administrative purposes, for example to notify you of a change to the service, change to the Privacy Notice, or if there is a service interruption.
Collecting, using or disclosing your personal information without consent
We may collect, use or disclose personal information without knowledge or consent in certain circumstances, including:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source;
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud; or
- To investigate an anticipated breach of an agreement or a contravention of law.
Access to your personal information
You own the information you submit to CuePath. We will inform you of the existence, uses and disclosure of your personal information and give you access to that information if you request it.
Securing personal information
We use industry standard security practices and take reasonable steps to protect your personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. We also train our team to follow privacy and security practices.
Using contracts, we ensure that any third party acting on our behalf in respect of your personal information maintains reasonable and appropriate safeguards. Third parties acting on our behalf are not permitted to use or disclose your personal information for any purpose other than providing the services in question.
We will use appropriate security measures when destroying personal information such as deleting electronically stored information.
We review and update our security policies and controls as technology changes to ensure ongoing personal information security, however please bear in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you share with us.
Location of service
Our company is located in Canada but we may use service providers located outside of Canada. This means that your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those jurisdictions. For more information on where personal information is stored, please contact our Privacy Officer at firstname.lastname@example.org.
Cookies and other tracking technologies
Additional Features and Information
It’s important to guard your privacy when you are online. If our website or service contains links to other websites, this Privacy Notice does not govern those websites. Whether we have posted those links or other organizations or individuals have, you should read their privacy policies and make an informed decision about whether you want to use those websites or their services.
With your consent, CuePath may use your testimonial or comments about our service on our website and in other materials. If at any time you want your name, testimonial or comment removed, please contact us at email@example.com.
Changes to this Privacy Notice
We may update this notice to reflect changes to our information practices but we will not reduce your rights under this Privacy Notice without your explicit consent. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification if appropriate). We’ll also keep prior versions of this Privacy Notice in an archive for your review.
We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices and to contact us if you have any questions or concerns.
Questions and Complaints
You may send your privacy-related questions, concerns or complaints to our Privacy Officer who is responsible for ensuring our compliance with this notice and with the appropriate privacy legislation.
1200 – 555 West Hastings Street, Vancouver, BC, Canada V6B 4N6
If our Privacy Officer is unable to resolve the concern, you may also write to the Information and Privacy Commissioner of British Columbia.