HeadWay Clinic Incorporated.(“HeadWay”, “we”, “us”) is committed to protecting personal information and safeguarding the privacy of all users of the HeadWay website, www.headwayclinic.ca (the “Site” ). This privacy policy (the “Policy”) applies to information collected by HeadWay Clinic through the website.  It does not apply to information or data collected through other sites, products, or services.

By using the Website, you consent to the collection and use by us and our agents of your Personal Information as described in this Policy.

Definitions

“Account” means the account used by Users to sign into and use the Site.

 “Identifying Information” means personally identifiable information that identifies an individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify an individual. This includes information such as your name, address, e-mail address and date of birth.

“Non-Personal Information” is information of an anonymous nature, such as an Internet Protocol Address (IP Address), the domain used to access the site, and the type and version of browser or operating system being used. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, average time spent on the Site, and information volunteered by the user, such as survey information, is also considered Non-Personal Information.

 “Personal Health Information” means identifying information about an individual, if the information (a) relates to the physical or mental health of the individual, including information that consists of the health history of the individual’s family, (b) relates to the provision of health care services to the individual, including the identification of a person as a provider of healthcare to the individual, (c) relates to payments or eligibility for health care, or eligibility for coverage for health care, in respect of the individual, or (d) is the individual’s health number.

“Personal Information” in the context of this Policy, means both Identifying Information and Personal Health Information.

Collection of Personal Information

Personal Information is collected from Users’ account setup and includes without limitation the User’s name, e-mail address.

Through Cookies.  HeadWay  uses cookies within Users’ web browsers to facilitate the sign in process and to facilitate making appointments. The cookie is a small data file that a website places on your computer’s hard disk. HeadWay uses cookies to help it compile aggregate statistics about usage of the Site, such as how many users visit the Site, how long users spend viewing the Site, and what pages are viewed most often. This is a temporary or session cookie that uniquely identifies the User as they move from page to page on the Site. We need this information in order to operate, but it does not collect Personal Information.

Use of Personal Information

We do not now (and do not intend to) sell or otherwise market Personal Information to third parties. We limit the collection, use, retention and disclosure of Personal Information to that which is reasonably necessary for the purposes outlined below. Personal Information will not be used without your consent for any purpose other than those mentioned in this Policy.

 

Online Appointment Booking
Users can book and manage appointments online with their Health Care Provider. This information is stored in an third party-software (Acuity Scheduling) and the providers’ Exchange Accounts.

Law and Compliance

Other Uses
HeadWay may hire other companies to provide services on its behalf (the “Agent”).  Headway gives Agents only the Personal Information they need to deliver the service. HeadWay requires Agents to maintain the confidentiality of the Personal Information and prohibits them from using such information for any other purpose.

HeadWay and Agents may use your Personal Information for the following purposes:

·       to provide Users with information about the Site, including updates and notifications;

·       to send Site e-mail communication;

·       to invoice applicable service fees, if any;

·       to maintain and administer Accounts;

·       for support services; and

·       to generate statistics and aggregate reports to improve the Portal.

Security

Our servers are located in Canada.  HeadWay uses commercially reasonable efforts to ensure that your Personal Information is stored and maintained in a secure environment. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Third Party Websites

Through the Site you may be introduced to a variety of third parties and websites. The privacy policies of these third parties are not under the control of HeadWay and may differ from this Policy. The use of any information that you may provide to any third party, or the use of “cookie” technology by any third party, will be governed by the privacy policy of the operator of the website that you are visiting. If you have any doubts about the privacy of the information you are providing on another website, we recommend that you contact that website directly for more information and review its privacy policy.

Access to Personal Health Information

Users can access the Personal Health Information we hold about them by sending us an e-mail at privacy@headwayclinic.ca. We will advise you in advance of any charges for copies of your file. We may be unable to provide you with some information in certain circumstances, such as if the information also refers to other individuals, is subject to legal privilege, contains confidential information, cannot be retrieved using your name or account number, or as otherwise permitted or restricted by law. If you wish to notify us of any changes to your Personal Health Information, or if you believe that any information we hold about you is inaccurate or incomplete, please send us an e-mail with the corrections to the e-mail address noted above.

Changes to This Policy

HeadWay may amend and update this Policy at any time, which will be reflected by the “last modified” date below. It is highly recommended that you read over this Policy occasionally to keep informed of our commitment to the protection of your private information and any changes to this Policy.  By continuing to use the Site, you agree to this Policy and any changes thereto.

Contact information

Should you have any questions or concerns about this Policy, please send your correspondence to:

Chief Privacy Officer
HeadWay Clinic Inc.
907 Lorne St.
Sudbury, Ontario
P3C4R6
privacy@headwayclinic.ca

All communications relating to privacy will be considered confidential and treated as such.

Last Updated: April 1, 2018