Last updated: October 2021
ELNA Medical Group Inc. (“ELNA Medical”, “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy informs visitors and regular users of https://elnamedical.com (the “Website”) about the purposes for which we collect, use and disclose personal information, including personal health information, and how it is protected. By using the Website, you accept the privacy practices presented in this policy. We encourage you to read this policy carefully to understand our privacy practices before using the Website or submitting any personal information. By accessing or using the Website or by otherwise giving us your personal information, you indicate that you understand, accept, and consent to the privacy practices described in this policy.
This policy applies only to the Website and the services provided on the Website. ELNA Medical and its affiliates and subsidiaries may have separate websites, sub-domains, and services through other web, mobile, or cloud platforms that are not subject to this policy. Additionally, ELNA Medical business partners, ad networks, and other third parties have their own websites and services with separate privacy practices. We encourage you to read the privacy policies of all websites, portals, and applications that you visit to understand their privacy practices.
- Information We Collect About You
- How We Use Your Information
- Sharing of Your Information
- Accessing and Securing Your Personal Information
- Links to Other Websites
- Withdrawing your Consent
- Questions or Concerns
Throughout this policy, we use the term “personal information” to refer to any information accessed, collected, or used by ELNA Medical that identifies an individual, or can reasonably be used to identify an individual, directly or indirectly. “Personal health information” refers to any information about an individual which relates to: physical or mental health of the individual, including family health history and the provision of health care to the individual, including, the identification of an individual as a provider of health care to another individual, payments or eligibility for health care in respect of the individual, donation by the individual of any body part or bodily substance or which is derived from the testing or examination of any such body part or bodily substance, the individual’s health number, or identification of an individual’s substitute decision-maker. Personal health information includes other identifying information that is contained in a record which contains personal health information.
Unless an exception to consent applies, ELNA Medical only collects, uses or discloses your personal information and personal health information with your consent, which may be express or implied as required by applicable law. You may withdraw your consent at any time, subject to legal and contractual constraints.
This policy applies to information we collect, use, or disclose about our visitors and Website users as follows:
- On the Website, including when you interact with us through opt-in or booking forms, and newsletter sign-up forms
- Through virtual care services such as those listed under the “Services” tab on the Website
- On the Patient Portal
- In email, text and other electronic messages between you and us
When you choose to participate in activities related to the Website, such as message boards, surveys, subscribing to our newsletter and marketing or promotional materials, you understand that you are under no obligation to provide us with personal information; however, that may limit your ability to use certain functions or request certain services or information from us.
When you use our Website, we may collect personal information about you either directly from you or through an authorized representative with your prior consent, where required by law. This information includes, but is not limited to:
- Your name and initials
- Your email address
- Your date of birth
- Your contact information
- Some personal health information, such as your medical records, personal and family health history, health card information, payment information, health insurance information, records of your visits to ELNA Medical and the care that you received
- If you choose to apply for a position at ELNA Medical, we will collect the information contained in your resume and cover letter as well as any information you decide to share with us as part of the application process
Additionally, we obtain certain information about you automatically when you use our Website through automated technologies and interactions. This information includes, but is not limited to:
- Some user behavioral information such as the services you choose and your preferences
- Some technical information such as login information, usage details of our Website, the hardware and software you use to interact with our Website, the device identifier, your mobile network information, the settings you use on our Website, your network location, and your IP address and location
The information we collect automatically is statistical information and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service. Some web browsers have a “Do Not Track” feature. This feature allows you to tell websites you visit that you do not want to have your online activity tracked over time and across websites. These features are not yet uniform across browsers. The Website is not currently set up to respond to those signals.
We may use your personal information and personal health information to communicate with you, deliver virtual care and administrative services, receive payment for your treatment and virtual care, research, meet legal requirements, and fulfill other purposes permitted or required by law. Your personal health information may be disclosed to physicians, health care professionals, and staff directly involved in your health care with your consent.
ELNA Medical may use personal information and personal health information to generate de-identified or aggregated information so that it does not contain any personal information that could identify and individual. ELNA Medical may use and disclose such de-identified or aggregated information for research purposes, activities to improve the quality of care, or to evaluate our services.
Under certain circumstances, ELNA Medical will disclose your personal information or personal health information:
- When you have expressly consented to the disclosure
- Where your consent was implied, including the disclosure to another health information custodian for the purpose of providing health care to you
- Where necessary to establish and collect payment
- To detect, prevent or otherwise address fraud, security or technical issues
- To engage in a merger, acquisition, reorganization or sale of all or portion or ELNA Medical assets
- As required or authorized by law to do so without your consent
We may engage certain third-party service providers or agents to provide administrative support services to us, including information technology services. To the extent that these service providers have access to your personal information, they are obligated by us to protect your personal information to a level of security similar to that which we provide.
ELNA Medical does not give, rent or sell personal information to any organization or individual.
We have established appropriate safeguards to ensure that the personal information and personal health information that we collect is protected. Our internal policies and procedures govern the manner in which all our employees access and manage patient information. Our employees are required to sign a confidentiality agreement and our physicians are bound by the rules and guidelines of the applicable provincial medical regulators with respect to privacy and confidentiality.
We have also established appropriate physical, technical, and administrative safeguards to protect the personal information we collect from or about our users, such as facility access control and workstation security. In addition, our patient information system uses passwords and firewalls to protect from inappropriate access and our Patient Portal accounts are password-protected and sensitive information is secured through encryption technologies.
We caution that no method of transmission over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you understand that any information that you transfer to ELNA Medical is done at your own risk.
You have the right to access and correct your personal information that is under our control. Please contact us at our coordinates below to request access to or change your personal information or preferences. If you have any questions about security or have reason to believe your interaction with us is no longer secure, we encourage you to notify us immediately at our coordinates below. We will collect or delete ay personal information we have about you, unless we are required to keep it by law.
We will retain your personal information and personal health information to meet our contractual obligations to you, and for as long any account you activate on or through the Website is active and is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We retain personal health information for at least the minimum retention period required by applicable provincial medical regulators. Where personal information is no longer needed, it will be securely destroyed, permanently anonymized or de-identified.
Where you have provided your consent to us processing your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at our coordinates below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
ATTN: PRIVACY OFFICER
ELNA Medical Group Inc.
5990 Ch. de la Côte-des-Neiges
Montréal, QC H3S 1Z6
For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Or your provincial office of the Information and Privacy Commissioner for more information.