LAST UPDATED: December
We value the trust that you have placed in 2706442 Ontario Inc. dba The
PrEP Clinic or Ontario Prevention Clinic (“The PrEP Clinic”, “we”, “our”, or “us”) and protecting your
discloses the practices of The PrEP
Clinic, and our affiliate Equality Access Care Inc. dba Equality
Access Care, regarding the
collection, use, safeguard, disclosure, transfer, access, disposal and other
processing (collectively, “Processing”) of personal information of
individuals who visit one of our
physical clinics, use our application(s) (“Application”) or visits our
website(s) (“Website” and together with our Application, referred to
herein as our “Platform”) or otherwise engage with us (collectively, our
“Services”). For the purposes of this Policy, personal
information (“Personal Information”) shall mean information that can identify
an individual directly or indirectly through reasonably available information, but
does not include information that is used solely for the purpose of
communicating or facilitating communication with an individual in relation to
their employment, business, or profession.
This Policy is The PrEP Clinic’s way of making sure you are fully informed of The
PrEP Clinic’s Personal Information handling practices and policies relating
This Policy is effective as of the date “Last Updated”, above, and will
remain in effect except with respect to any of its provisions that are changed
in the future. We reserve the right to change this Policy at any time. Changes,
modifications, additions, or deletions will be effective immediately upon their
posting to the Platform or upon you being otherwise notified. Your continued
use of our Services after we post any such modifications will constitute your
acknowledgement of the modified Policy and your agreement to abide and be bound
by the modified Policy. We will also revise the “Last Updated” date found at
the beginning of this Policy when we post changes to it.
Subject to certain legal and contractual limitations, you have the right
to withdraw your consent from us Processing your Personal Information. This may
limit our ability to provide you with our Services, act on your behalf or
engage with you as you would like. To withdraw your consent to certain
Processing by The PrEP Clinic, you may declare to the Privacy Officer (contact information provided
below) in writing, at any time, of your desire to withdraw consent. The PrEP
Clinic will inform you of the
implications of such withdrawal within thirty (30) days of your written
request. Any withdrawal of consent will apply thereafter and not to information
handling practices that have been previously undertaken based on prior consent.
The PrEP Clinic will not knowingly obtain consent from those
individuals who are minors, seriously ill, or mentally incapacitated and we
shall therefore obtain consent from a parent, legal guardian or person having
power of attorney of such an individual.
If you are an individual under
the age of majority, you must access or use the Platform only with the
permission and involvement of your parent or guardian.
The Personal Information which the PrEP Clinic may collect includes, but is not limited to:
Patient identification information including your name,
date of birth, address, province of residence, email address, phone number, gender,
personal health number and contact person in case of emergencies.
Medical records including the name(s) of your healthcare
practitioner(s) at each visit, medical history, current medications, any photos
you upload to the Platform or otherwise provide to The PrEP Clinic, records of
examinations carried out by healthcare practitioners and clinical notes for
each patient encounter, requisitions for treatment or investigation, consents
to treatment obtained in writing, records of treatment you receive from healthcare
practitioners through our Services, reports of investigative procedures and
reports of the results of laboratory, pathology, consultations, diagnostic
imaging examinations or tests, diagnoses and a record of missed and/or
Real-time audio and video calls with healthcare practitioners
conducted through the Platform. We do not make recordings of these calls.
Account and login information including your username
Payment information including your credit card details,
bank account information, and payment or other information required when you choose
to purchase Services from us that are not covered under a provincial or private
Feedback on your experience using the Platform or
visiting one of our on-site clinics.
Marketing and communications information including your
preferences in receiving marketing from us, and your communication preferences.
Computer information including device type, device
identifiers, IP address, MAC address, location, browser type, operating system
and platform, protocol, sequence information, cookies, beacons, pixel tags,
browser language and type, and domain name system requests.
Internet or other electronic network activity including
browsing, session, interaction, search history, duration of use, frequency of
use, material and pages viewed, time and date of access, number of bytes
transferred, number of clicks per visit and other user behaviour related to our
information which you voluntarily provide to us, our healthcare practitioners, our
employees, or our contractors.
In addition, if you contact us,
we may keep a record of your communication to help solve any issues you might
Personal Information may be collected by The PrEP Clinic for purposes that include,
but are not limited to:
1. Providing our Services and access to the Platform.
2. Maintaining a healthcare and service
relationship with you.
3. Verifying your identity and updating your
4. Maintaining and improving our Services and
otherwise running and managing our business in the ordinary course, and keeping
our records up to date.
5. Receiving communications from us in regard to
e-news, emails, bulletins, notifications, newsletters, programs, events and
6. Assisting you when you contact our customer
support services, including to direct your questions to appropriate
individuals, investigate and address any of your concerns, and to improve and
monitor our customer support responses.
7. Administering and protecting our business and
Platform, including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data.
8. Marketing to be presented on the Platform.
9. Administering surveys and otherwise
requesting feedback on our Services.
10. Using data for business development and
market research to understand demographics, interests, usage patterns, and
other characteristics of individuals and to track and analyze trends and
11. Complying generally with all laws and
applicable statutory requirements.
Personal Information may be
collected by The PrEP Clinic in a
number of ways, including in person, our Platform, by mail, by email, by fax
and from third parties whom you have authorized to disclose Personal
Information to us, including other physicians and specialists, pharmacists and
If you provide information about a third-party or authorize a third-party
to do so, we will assume you have taken proper measures to obtain informed
Information is collected by The PrEP Clinic when you consult with
our healthcare practitioners or other staff members through video and audio
conversations on our Platform or in one of our in-person clinics or otherwise
request related healthcare and administrative support services, such as prescription
services and laboratory requisitions. Our healthcare practitioners and support staff
may include physicians, nurse practitioners, registered practical nurses,
social workers and counsellors, patient care specialists, patient support
specialists, clinic assistants, pharmacists and pharmacy technicians.
participate in certain presentations and in-person outreach events to provide educational
information to the public and an overview of the Services we offer. We may
collect Personal Information from you if you indicate your interest in learning
more about our Services and interacting with us further.
For the purpose of maintaining
quality service, telephone calls to The
PrEP Clinic’s customer services lines may be recorded. If your call is
subject to a quality assurance program, you will be advised prior to speaking
to a representative.
The PrEP Clinic may collect Personal Information through cookies on
our Website. Cookies are small text files inside your computer that contain a
unique identifier, allowing us to recognize you when you visit our Website
again. This helps us to understand your preferences based on previous or
current Website activity, allowing us to provide you with improved services,
tailor our content to meet your needs and for advertising purposes. We also use
cookies and navigational data to gather information regarding the date and time
of your visit and the information for which you searched and viewed, or on
which of the advertisements displayed on our Website you clicked.
The Website may use retargeting ads
Google to track visitors. This tracking enables the third-party vendors to
display our ads to people on various sites across the internet based on their
visits to our Website.
We may also use web beacons (small
pieces of data that are embedded in images on the pages of our Website) and
auditing software to track page views and entry and exit points to and from our
Website. We may use web beacons, cookies, customized links and/or similar
technologies to determine whether electronic newsletters sent by us to those
who have requested them from us have been opened and which links are clicked.
Any data collected will only be used in an aggregate form and will not contain
any Personal Information.
Some cookies are automatically
deactivated upon your access and use of the Website. However, unless you
activate cookies, you may be unable to fully utilize and access all areas and
features of the Website. You may activate cookies by visiting our Website and
clicking “Activate Cookies”. Some third-party service providers may also place
When you visit The PrEP Clinic Website, we may also collect
clickstream data (e.g. server address, domain name, device type, browsing
software) which may be stored on the Website’s server. This information can be
combined with information you have provided to us which will enable us to
analyze and better customize your visits. We may use clickstream data for
traffic analysis or e-commerce analysis of the Website, to determine which
features of the Website are most or least effective or useful to you.
The PrEP Clinic’s Website features may be
accessible from web-enabled mobile devices. The intent is to provide screens
that are optimized for the size of the screen and operating systems. On some
devices, functionality may be limited. If you use mobile-enabled services
provided by our Website, we may receive information about you from your mobile
device. This may also include information about your precise location if you
have enabled location-based services on your mobile device. Some devices may
allow you to opt-out of this collection or access, and in those cases, you may be
able to subsequently stop the collection or access. Please review your device
settings for more information.
Certain features of the Application request
your permission to use GPS technology to collect real-time information about
the location of your device so that The PrEP Clinic can confirm your
eligibility to receive Services or help you locate a clinic or other services
in your area. This service is provided for your convenience only, and your
permission for this use is voluntary. This location data is not retained or
used for any other purpose.
If you post a review, make a
comment, or otherwise submit Personal Information on a public forum such as
social media accounts or public forums on our Platform, your communications may
be viewable by the public. When voluntarily disclosing Personal Information
about yourself with other PrEP Clinic users,
we are unable to control what may be done with that content. You should take
all necessary precautions to protect your private information by not posting or
publishing any information that you do not want in the public domain. While we
strive to provide the highest level of confidentiality, you should review your
personal privacy settings to further restrict any or all parts of your profile
or other certain content or information.
The PrEP Clinic may collect Personal Information when you interact with
our Platform, including when you access the Platform, request healthcare
services, register, create or edit your account, sign up to receive newsletters
and information, fill out online or in-person surveys or forms, send or respond
to our emails or text messages, or otherwise communicate with us.
The PrEP Clinic utilizes technology which may
collect Personal Information to make predictions, recommendations or decisions
about you based exclusively on the automated processing of your Personal
Information. You may request information with respect to any automated decisions
that have been made based on the collection of your Personal Information, and
the reasons and parameters which led to that decision. You may also correct the
Personal Information that was used to render the prediction, recommendation or decision,
and have the right to submit observations to the Privacy Officer who may review
and re-assess the decision which was made by automated means.
Although you are
entering into an agreement to disclose your Personal Information to The PrEP
Clinic pursuant to this Policy, we may delegate our authority for Processing of
your Personal Information to third-party individuals and organizations who
assist us with providing our Services and administering our business, and for
such other purposes as set forth below, including:
practitioners for the purpose of providing or assisting in the provision of
healthcare to you. We may also disclose your Personal Information to third
parties such as other health professionals, specialists, pharmacists,
pharmacies and laboratories for the purpose of providing or assisting in the
provision of healthcare to you, including for the purpose of providing referrals,
prescriptions, or lab and imaging requisitions to you. Information will only be
shared with your family doctor, hospital, lab or specialist with your consent unless
we are required to do so under applicable laws.
Health or benefits providers for the purpose of requesting benefits coverage,
payment or reimbursement for our Services.
agents, contractors and affiliates, including companies we use for storage,
processing, and delivery of our Services.
and technical support, including cloud storage providers, IT support, and data
in connection with proposed or actual financing, insuring, sale,
securitization, assignment or other disposal of all or part of our business or
do not store your payment information for online payments made with debit /
credit cards. This is shared directly with our third-party payment providers
including financial institutions and payment processors.
Name of Third Party
Telus Health Solutions
OnCall Health Inc.
We may also disclose
Personal Information in situations where we are legally required or permitted
to do so. These situations may include criminal investigations, government tax
reporting requirements, court orders, or instances where we believe the rights
and safety of others may be at risk.
If you believe that a third-party has inappropriately disclosed your
Personal Information to us, please contact that third-party directly. If the
third-party does not sufficiently respond to your inquiries, please let us know
The PrEP Clinic
takes care to ensure that Personal Information you provide to us is accessed
internally only by individuals that require access to perform their tasks and
duties, and externally only by service providers with a legitimate purpose for
accessing it. We will not use or disclose any collected Personal Information
outside of the purposes described in this Policy unless you have otherwise
consented or it is required or permitted by law.
We do not sell,
trade, rent or otherwise share for marketing purposes the Personal Information
that we collect with third parties, unless you consent or authorize us to do
so. We limit the Personal Information provided to the aforementioned affiliate
and third-party service providers to the extent necessary for them to provide
the Services. We do not allow these third-party service providers to use your Personal
Information for their own purposes and only permit them to access and process
your Personal Information for specified purposes and in accordance with our
instructions. Such service providers are required by contract to safeguard any
Personal Information disclosed or transferred by us.
The PrEP Clinic
takes all reasonable steps to keep your Personal Information as accurate,
complete and up-to-date as necessary to fulfill the purpose for which your
Personal Information has been collected. If desired, you may verify the
accuracy and completeness of your Personal Information in our records with our
Despite our efforts, errors
sometimes do occur. Should you identify any incorrect or out-of-date Personal
Information in your file, we will remedy any such errors on a timely basis. You
may request correction of the Personal Information we hold about you, though we
may need to verify the accuracy of the new information you provide to us. If
inaccurate Personal Information is mistakenly sent to a third-party, we will
communicate relevant changes to the third-party where appropriate.
You can review and change
Personal Information that is displayed in your profile on the Platform, and can
close your account at any time. If you wish to have us delete all data about
you held on our servers or otherwise, contact us and we can assist with this.
Contact information can be found at the end of this Policy document.
The PrEP Clinic
will store your Personal Information only for as long as is reasonably
necessary to fulfill the purpose for which the Personal Information was
collected, including for the purposes of satisfying any legal, accounting, or
reporting requirements. Once your Personal Information is no longer needed, we
will securely and effectively dispose of it.
To determine the appropriate retention period for Personal
Information, we consider the amount, nature, and sensitivity of the Personal
Information, the potential risk of harm from unauthorized use or disclosure of
your Personal Information, the purposes for which we process your Personal
Information and whether we can achieve those purposes through other means, and
the applicable legal requirements.
In some circumstances we may
anonymize your Personal Information (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this
anonymized information indefinitely without further notice to you.
You may request access to your Personal Information, which enables you to
receive a copy of the Personal Information we have collected from you and
information about how we are Processing it. We may need to request
specific information from you to help us confirm your identity and right to
access your Personal Information. This is a security measure to ensure that
Personal Information is not disclosed to any person who has no right to receive
it. The PrEP Clinic may not always be
able to comply with your request for access to Personal Information for specific
reasons which you will be notified of, if applicable, at the time of your
In some circumstances you have
the right to request that we delete or remove your Personal Information where
there is no good reason for us to continue Processing it. You may also ask us
to delete or remove your Personal Information where you have successfully
exercised your right to object to Processing, where we may have processed your
information unlawfully or where we are required by law to erase your Personal
Information. We may not always be able to comply with your request for deletion
of Personal Information for specific legal reasons which you will be notified of,
in writing, within thirty (30) days of the time of your request.
You may request the transfer of
your Personal Information to a third-party. The PrEP Clinic will provide your Personal Information to the third-party
you have chosen in a structured, commonly used, machine-readable format. This
request may only apply to automated information which you initially provided
consent for us to use or where we used the Personal Information to perform a
contract with you.
The PrEP Clinic uses
industry standard measures, including administrative, organizational,
technical, and physical safeguards, to help protect Personal Information from
loss, theft, misuse, and unauthorized access, disclosure, alteration, and
destruction. We implement measures and processes to help us keep your Personal
Information secure and to maintain its quality. We regularly review our
security and related policies to adapt the technology as new threats evolve and
monitor our systems to help ensure the highest level of availability. If you
have any questions about the security of our Platform, you can reach out to our
Access to private, sensitive and
confidential information, including Personal Information, is restricted to
authorized healthcare practitioners, employees or contractors with legitimate
business reasons. The PrEP Clinic’s healthcare
practitioners, employees and contactors understand the importance of keeping
your Personal Information private. All healthcare practitioners, employees and
contractors are expected to maintain the confidentiality of Personal
Despite the foregoing security measures and significant steps
The PrEP Clinic has taken to protect
your Personal Information, no company can fully eliminate all security
risks associated with the Processing of Personal Information. With that in
mind, we cannot guarantee the security of any Personal Information provided to
or received by us. We encourage you to keep watch for communications that are
suspicious, and report any suspicious activity to us as soon as possible.
In the event there has been a
breach of our security safeguards which involve your Personal Information, including
the unauthorized access, use or disclosure of your Personal Information, loss
of your Personal Information, or other breach, and where there is a risk that
significant harm will come to you as a result of that breach, The PrEP Clinic will notify you of the breach
and report the breach to the Privacy Commissioner.
Our Platform and Services are
governed by the provisions and practices stated in this Policy. Our Platform
may contain links to third-party sites or applications that are not governed by
this Policy. Although we endeavour to only link to sites or applications that
share our commitment to your privacy, please be aware that this Policy will no
longer apply once you leave our Platform and that we are not responsible for
the privacy practices of third-party sites or applications. We therefore
suggest that you closely examine the respective privacy policies of third-party
sites and applications to learn how they collect, use and disclose your
This Policy and all related
matters shall be interpreted and construed in accordance with the laws of the
Province of Ontario and the applicable federal laws of
Personal Information, including your medical records for consultations
conducted through our Platform or physical clinics, is stored in Canada and
cannot be accessed from outside Canada.
Your privacy is very important to us. We are happy to provide
you with a copy of this Policy and to discuss any of its contents with you.
The PrEP Clinic’
Privacy Officer is responsible for the implementation of this Policy and
monitoring our adherence to its terms and all applicable laws. The Privacy
Officer also handles questions and concerns about our Policy, as well as
Personal Information access requests and complaints. You may also seek advice
from the Office of the Privacy Commissioner of Canada and, if appropriate, file
a written complaint with the Commissioner's office.
The PrEP Clinic’s
Privacy Officer may be contacted at:
803-180 Bloor St W Toronto, ON M5S 2V6