Privacy Policy

Introduction

The purpose of this Privacy Policy is to inform you about the types of personal information Red Leaf Wellness (as follows, “Red Leaf Wellness” “we” or “us”) collects, uses and discloses. redleafwellness.ca, redleafapothecary.com, and restoreplusnetwork.com (collectively the “Website”) are websites owned by Red Leaf Wellness, with a registered address of 10623 129 Street NW, Edmonton, AB T5N1X2, Canada. This Privacy Policy sets out how we obtain and use the personal information which you provide us.  As the legal environment, technology, and operations change, it may become necessary for us to make changes to this Privacy Policy and all such changes will be posted on the Website.

Our Privacy Commitment

At Red Leaf Wellness, we protect your privacy by:

  • Collecting only the personal information required to provide medical and wellness related services to you.
  • Advising you how your information might be disclosed and obtaining your consent.
  • Safeguarding your personal information.
  • Sharing your personal information only for the purposes stated and agreed to in a signed consent form or otherwise permitted by law.
  • Ensuring any contractors we hire who may have access to your information also protect the privacy of your information.
  • Training staff and adapting the office space to ensure maximum protection of your privacy.
  • Ensuring personal information is current, complete and accurate.
  • Providing you access to your personal information and a mechanism for requesting corrections.
  • Having our privacy officer available to answer your questions.
  • Periodically reviewing our privacy policy to ensure it provides adequate protection for your personal information.

Consent

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be expressed (e.g., orally, electronically or on a form you may submit, or implied (e.g., when you provide information necessary for a service you have requested, or in some circumstances where notice has been provided to you about our intentions with respect to your personal information you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided). Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or as otherwise described at the time of collection. You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice, however, please note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services.

We do not collect, use or disclose your personal information other than as described in this Privacy Policy without your consent, unless permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example in response to a court order or subpoena, to comply with local or federal regulations, or to collect a debt owed to us.

How We Gather Information

We may gather personal information in several different ways:

  • Through our Website and/or electronic health record sign-up/registration process;
  • Through the provision of medical or wellness services to you;
  • Through your orders of products and/or services;
  • Through providing support to our registered account holders and/or customers and/or potential customers; and
  • Through your payment to third-party payment processors which we use.

Information Collected

  • The personal information collected is required to provide you with medical and wellness services and facilitate payment for services rendered.
    • Contact information: your name, phone number, address, email address and an emergency contact person.
    • Health information: your health history, treatment received, names of other health-care providers, family medical history, your subjective complaints, objective findings, diagnoses, reason for discharge, and discharge plan.
    • Financial information: your insurance benefit coverage information, credit card information, employer’s name, and other information to facilitate payment for services provided.
  • Other Information – we also gather other information (“Other Information”), which cannot identify you unless it is used in conjunction with actual personal information. For example, we may collect your computer’s Internet Protocol address (i.e. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may receive and store certain information whenever you visit the Website. We may use your IP address to help diagnose problems with our server and to administer the Website, and to help identify you. Your IP address may also be used to gather broad demographic information, and for other purposes. Such Other Information cannot generally be used by us to identify you, and as such is not considered Personal Information.

What Do We Use Your Information For?

  • We use contact information to open and update your patient file, invoice for services, remind you of appointments and/or the need for further treatment, and to provide informational materials about our clinic.  We may also contact you to notify you of changes to our services, allow you to participate in interactive features of our services when you choose to do so, and to provide customer support. We may also provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information
  • We use health information to assess, diagnose, provide, and evaluate medical and wellness treatments.
  • We use financial information to arrange payment for services rendered.
  • We use Other Information to:
    • To provide and maintain our Website and to provide you with our goods and/or services.
    • To gather analysis or valuable information so that we can improve our services
    • To monitor the usage of our Website and to track our customer’s ordering of products or services
    • To detect, prevent and address technical issues.
    • We reserve the right to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Website and to inform advertisers of such information as well as the number of users that have been exposed to or clicked on their advertising banners.

How Do We Protect Your Personal Information?

  • We are a paperless clinic. We store all electronic records on secured hardware, use antivirus software and passwords on all computers and take care to protect screen monitors from public viewing.
  • We transfer digital records outside our office by secure methods and are made anonymous wherever possible.
  • We conduct telephone discussions with sensitivity to ensure that your personal information is not inadvertently disclosed.
  • We do not share your personal information outside our office for any marketing, promotional, publicity, educational, or research purposes without your consent.
  • We train staff to handle your information only through the protected measures outlined in our privacy procedures. If consultants or contractors are hired, we take steps to ensure the consultant or contractor also protects your privacy

With Whom Do We Share Your Information?

  • Contact information – may be disclosed to third-party health benefit providers/insurers when reimbursement claims for all or part of the treatment cost have been submitted.
  • Health information – may be disclosed to:
    • Third-party health benefit providers and insurance companies when a claim is submitted for reimbursement or payment of all or part of the cost of treatment or we have been asked to submit a claim on your behalf.
    • The WCB or your employer if you made a WCB claim.
    • Other health-care professionals also providing you with treatment.
    • Your lawyer, if you were injured in an accident.
    • Research teams in an anonymous form to facilitate outcome research.
  • Financial information – may be disclosed to your insurer or credit card company as required to facilitate payment.
  • Service Providers – we may employ third party companies and individuals to facilitate our Website and business (“Service Providers”), to provide services on our behalf, to perform services or to assist us in analyzing how our Website is used. We also may employ agents to fulfill functions on our behalf, such as providing marketing assistance, analyzing data, preparing and maintaining site content, processing credit card payments and providing customer service. These agents have access to user and customer information as required in order to help them perform their functions on our behalf, but they are not allowed to use that information for any other purpose.

Note: Personal information can also be disclosed without your consent if we are required to do so by law. We may also release such information if we feel it is necessary in order to protect our rights or the rights of our customers, affiliates, partners, or any other party, and for purposes of protection from fraud and credit risk. We may disclose your personal information in the good faith belief that such action is necessary to:

    • To comply with a legal obligation
    • To protect and defend our rights or property
    • To prevent or investigate possible wrongdoing in connection with our service
    • To protect the personal safety of users of our service or the public
    • To protect against legal liability

Information Stored Outside Of Alberta

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. Our operational preference is always to contract with sovereign Canadian providers whenever possible. Although rare, your personal information, may be transferred to and maintained on computers located outside of your province, country or other governmental jurisdiction where the data protection laws may differ than those from our jurisdiction. For example, we contract with companies outside of Canada to provide marketing and advertising services on our behalf, however they do not ever have access to health information. For further information regarding our storage of information outside of Canada or regarding the Red Leaf Wellness policies and practices regarding storage of information outside of Canada, please contact our privacy officer, whose contact information is listed at the end of this Privacy Statement.

If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it here. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Accessing And Correcting Your Personal Information

You can get access to view your personal information by asking a staff member who may refer you to our privacy officer. We will attempt to help you understand the reasons we collect, store and use the information in your records. You may request a change to your personal information if it is inaccurate, incomplete, no longer current, or if you believe there is a factual mistake. You can also request a copy of your patient record. Requested copies will be provided in a reasonable period. If there is a charge for the cost of producing a copy, we will advise you of the cost in advance.

How Long Is Information Kept?

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We are required by legislation to keep all health records containing personal information for 10 years from the last date of service. Or in the case of a minor, 10 years past the minor’s eighteenth birthday. After that time, we destroy the records. When discarding hardware, we ensure the hard drive is destroyed.

We may also retain Other Information for internal analysis purposes. Other Information is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.

Marketing And Advertising Specific Considerations

  • Advertising – We may use third-party Service Providers to show advertisements to you to help support and maintain our service, such as Google, who as a third party vendor, uses cookies to serve ads on our Website. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Website or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: https://www.google.com/ads/preferences/.
  • Personal Information for Marketing – We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. If you do not wish to receive notification of special offers or news and/or updates to our Website, please email us at info@redleafwellness.ca.
  • Behavioral Remarketing – We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors may use cookies to inform, optimize and serve ads based on your past visits to our Service. Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
  • Facebook – We may use Facebook’s remarketing service which is provided by Facebook Inc.
  • Our Use of Cookies and Web Beacons – You should be aware that non-personal information and data may be automatically collected through the standard operation of our Website’s internet servers or through the use of “cookies”. We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we may use:
    • Session Cookies.We use Session Cookies to operate our Website.
    • Preference Cookies.We use Preference Cookies to remember your preferences and various settings.
    • Security Cookies.We use Security Cookies for security purposes.
    • Advertising Cookies.Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
  • Log Files – As with most other websites, We collect and use the data contained in log files. The information in the log files may include your IP address, your ISP, the browser you used to visit Our Website, the time you visited our Website and which pages you visited throughout our Website.
  • Analytics – We may use third-party Service Providers to monitor and analyze the use of our Website, such as Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Website This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
  • External Links – The Website may contain links or references to other websites to which this Privacy Policy does not apply. These sites are not owned or controlled by us and We are not responsible for the collection, use and disclosure of personal information or the privacy practices of other organizations or other websites to which our site may refer visitors or provide links for. When submitting Personal Information on such other websites, we encourage you to read the privacy policy of those sites.
  • Children’s Privacy – Our Website does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers

Users Must be Age of Majority

Persons under the age of majority in their jurisdiction must ask their parents or legal guardians for permission before sending any information about themselves to us, or via the Website or to Website payment processors.

Transfer of Customer Information

Customer information is a valuable business asset. If for any reason we transfer or divest ourselves of our business assets, our customer information may be transferred as one of these business assets. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

“Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. Although we take standard precautions to safeguard your personal information, when you voluntarily disclose personally identifiable information (e.g., name, e-mail address, telephone number, etc.) on our Website or through other digital channels (e.g. text message, web chat, etc.), which do not encrypt or otherwise secure that information other than by standard web server technology, along with any substantive information disclosed in your communication, this personal information may be subject to unauthorized collection by third parties and that unauthorized activity is beyond our control.

In the event you transmit personal information to us over a non-secure channel, to protect your personal information, we may require subsequent responses to be conducted over a secure messaging service.  We will provide you with details on how to do so at that time.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the “effective date” at the bottom of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

More information

If you have a concern about your personal information, please feel free to ask the clinician treating you or another staff member. If your question/concern is not resolved, please address it in writing to our privacy officer: Daniel Lalonde, Red Leaf Wellness info@redleafwellness.ca.

The foregoing policies are effective as of 2021-02-05. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.

Last updated: 2022-12-17