SPINEgroup® Privacy Policy

This Privacy Policy describes the collection, use and disclosure of Your Information in connection with Your Interaction with Dr. Connie D’Astolfo Chiropractic Professional Corporation trading as SPINEgroup® (“SPINEgroup®” or “We” or “Us”) in the course of providing Healthcare Services.

When engaging in any Interaction whether or not You have requested or received any of the Healthcare Services offered by Us, You consent to the collection, transfer, manipulation, storage, disclosure and other uses of Information as described in this Privacy Policy. We seek to minimize our collection and use of Information to what is needed for providing Healthcare Services.

Please note that this Privacy Policy does not apply to the collection, use, management, disclosure and destruction of Your Information by Permitted Healthcare Personnel. Please note that Permitted Healthcare Personnel are subject to separate privacy legislation and professional and/or regulatory requirements in Ontario that govern the collection, use and management of Your Information in the course of providing Healthcare Services to You. Please contact the respective Permitted Healthcare Professional directly if You have any questions or concerns about their specific collection, use or management of Your Information in relation to the course of Your Healthcare Services.

This Privacy Policy is in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the federal privacy law for private-sector organizations. We will seek to ensure compliance with PIPEDA, as amended by the Digital Privacy Act (“DPA”), as may be applicable, as well as with the Personal Health Information Protection Act (“PHIPA”), where applicable. We are committed to complying with this Privacy Policy.

Definitions:

“Dependent” means any individual for whom You have the legal authority to make decisions regarding Healthcare.

“Healthcare” means any services or virtual services relating to the maintenance or improvement of an individual’s health to prevent, diagnose, treat, recover or cure such individual’s disease, illness, injury, and other physical and mental impairments.

“Healthcare Services” means the Healthcare services provided by Us via the Patient Platform, in-person, virtually or otherwise.

“Information” shall mean Personal Information and may include PHI as the circumstances may require.

“Interaction” means any contact between You and us (unless excluded herein) whether transmitted via the Patient Platform, facsimile, electronic correspondence, email, texts, verbally and/or in-person patient encounter.

“Personal Health Information” or “PHI” means identifying information, recorded in any form, about You, if the information relates to: (a) Your physical or mental health (including health history), (b) the provision of Healthcare to You (including the identification of a person as Your provider of Healthcare), (c) Your payments, eligibility or coverage for Healthcare, and/or (d) Your health number.

“Permitted Healthcare Personnel” means, in the Province of Ontario, (a) authorized physicians licensed to practice medicine in the Province of Ontario, (b) authorized regulated healthcare professionals licensed in the Province of Ontario to provide Healthcare Services, and/or (c) healthcare administrator staff employed or working for Us.

“Personal Information” means information, recorded in any form, about an identifiable individual which is not PHI being collected, created, compiled, used, disclosed by means of the Patient Platform, entered by Us or uploaded by You.

“Patient Platform” means, inter alia, the hardware, applications, websites including www.spinegroup.ca, portal and services owned and/or operated by Us but not third-party sites or software.

“You” or “Your” also refers to you on behalf of your Dependent(s), where applicable.

Collection of Personal Information

a) Any Interaction may result in our collection of Personal Information. We collect Personal Information directly from You, or indirectly from third party sources as otherwise permitted by applicable law.a) Log Data: Our servers may record certain information (“Log Data”) related to Your actions on the Patient Platform. Log Data may include information such as Your IP address, browser type, ISP, date/time stamps, the referring domain, and pages visited. Log Data may also be recorded by third parties.

b) Cookies: We may use “cookie” technology to collect any additional Patient Platform usage data and to improve our Healthcare Services. A cookie is a small data file that is transferred to Your computer’s hard disk. Most Internet browsers automatically accept cookies. You can instruct Your browser, by editing its options, to stop accepting cookies.

c) Submissions: Any information such as remarks, suggestions, questions, correspondence, comments, creative ideas, photos, graphics, or other information communicated to Us (collectively, called the “Submission”) shall be treated as non-confidential. You agree that You will not upload or transmit any Submission that infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party in the world. Your Submission becomes the property of SPINEgroup and We shall be free to use the Submission on an unrestricted basis for any purpose whatsoever.

d) Third-party Services: We may use a variety of services hosted by third parties to help provide our Healthcare Services. These third-party services may collect information sent by Your browser as part of a web page request, such as cookies.

e) Links: The Patient Platform may contain links to third party websites. These links are not intended as an endorsement of or referral to the linked websites. Please review all third-party privacy policies for any site you browse or visit.

Permitted Healthcare Personnel may, create, compile or print Information such as treatment plans, prescriptions, and clinical notes in relation to any Interaction with You (collectively the “Patient Notes”) as necessary to provide Healthcare Services and to comply with applicable laws. While providing You with Healthcare Services, Permitted Healthcare Personnel may also collect additional Personal Information about You. Subject to Your withholding rights as noted below, Permitted Healthcare Personnel will have access to the Personal Information. Such Personal Information may include but is not limited to: details You provided, documents, Patient Notes created by others, and emergency contact information (please note that You are responsible for notifying Your emergency contact that You are providing their information to Us and for obtaining their consent).

Use of Your Information

When requesting Healthcare Services, You may be asked to provide Information regarding the Healthcare Services, Your medical history and applicable symptoms. Upon patient intake completion, We may disclose the identity of the Permitted Healthcare Professional to You. Afterwards, unless You have chosen to withhold access to any of Your Information to Us stored in the Patient Platform, the Permitted Healthcare Personnel assigned to You will be able to view such Information in order to provide Healthcare Services. Please note that in some circumstances, the withholding of Information may severely limit the Permitted Healthcare Personnel’s ability to provide You with Healthcare Services.

In addition to some of the specific uses of Personal Information we describe in this Privacy Policy, we may use or share such Personal Information to: (a) confirm Your eligibility to use the Patient Platform, or authenticate You when You log onto the Patient Platform, (b) if applicable, determine Your eligibility for Healthcare Services, (c) connect You to the appropriate Permitted Healthcare Professional, (d) establish, maintain and manage patient relations with You in order to provide Healthcare Services, (e) provide ongoing customer service to You, (f) facilitate payments for Healthcare Services, and (g) comply with meet any legal and regulatory requirements.

Information Sharing and Disclosure

Our use of Information is limited to the purposes described in this Privacy Policy, and We do not otherwise sell, rent, trade, barter, exchange or disclose for consideration any Information that we have obtained.

a) With Your Consent: We may share or disclose Your Information with Your consent. Consent can be either express (verbally, in writing or electronically) or implied, where permitted under applicable law. When You provide Your Information voluntarily or to a Permitted Healthcare Professional, You imply that You have consented to the collection, use and disclosure of such Information. You may change or withdraw Your/their consent at any time, subject to legal or contractual restrictions, if any, and reasonable notice, by contacting us at admin@spinegroup.ca. Please note that in some circumstances, a change in or withdrawal of consent may severely limit or prevent our ability to provide Healthcare Services.

b) Without Consent: Please note that there are circumstances where the use and/or disclosure of Your Information may be justified or permitted or where we are obliged to disclose information WITHOUT consent. Such circumstances may include, but are not limited to the following: (a) if we believe that it is reasonably necessary to comply with a law, regulation or legal request, (b) to protect the safety of any person; (c) to address fraud, security or technical issues; or (d) to protect our rights or property.

c) Other Service Providers: We share Information with Permitted Healthcare Personnel, Your emergency contacts, our employees, and contractors and business partners, to the extent required for them to provide the Healthcare Services to You or for the purposes in this Privacy Policy. We engage certain trusted third parties to perform functions and provide services to us such as website hosting companies, payment processing companies and other third-party service providers. We may share Personal Information with these third parties, but only to the extent necessary.

d) Corporate Transfers: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, Your Information may be disclosed or transferred as part of that transaction. The promises and exceptions in this Privacy Policy will apply to Your Personal Information as transferred to the new entity.

e) Government: We may share Personal Information with government agencies and law enforcement officials, when required to do so to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.

 Protection of Information and Disclaimer

We endeavor to maintain appropriate physical, procedural and technical security with respect to our offices and Information storage and recovery facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Information. We further protect Your Information and any financial or payment information by restricting its access to those employees and contractors who need to have knowledge of that Information in order for us to provide our Healthcare Services. While we endeavour to protect Your Information, no data transmission over the Internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any Information You transmit to us via email or via the Patient Platform or otherwise; any transmission to Us is at Your own risk.

By this Privacy Policy, We shall hereby notify patients of the potential risks, including privacy-related risks, associated with the Patient Platform, and to obtain Your express consent to receiving Healthcare Services, You are hereby notified that: (a) certain Healthcare Services may be made available through third-party platforms, (b) use of the Patient Platform or using unencrypted SPINEgroup email from You or to You or others on your behalf, may increase the risk of Your Information being unintentionally disclosed or intercepted by third parties, (c) while We will make reasonable efforts to protect the privacy and security of Your Information, it is not possible to completely secure electronic correspondence or email to third parties including Your legal representative(s) and therefore the security and confidentiality of Information and Healthcare Services cannot be guaranteed, (d) You agree to take steps to protect Your privacy when receiving Healthcare Services including confirming Your identity with Permitted Healthcare Personnel, (e) using Healthcare Services only from a private location, on Your own computer or device, and on a password-protected Wi-Fi network, (f) not recording the Healthcare Services, or any part thereof, (g) You agree that We may collect location data through the use of GPS technology and Your IP address where applicable, (h) You agree that Information may be used or disclosed as permitted or required by law including any risk of harm to an individual or a child is in need of protection under the Child, Youth and Family Services Act, 2017).

Privacy Policy Changes

We may revise this Privacy Policy from time to time. The most current version of this Privacy Policy will govern the use of Information unless we notify You otherwise. Please check this page periodically for any updates. By continuing to access or use the Healthcare Services after those changes become effective, You agree to be bound by any revised Privacy Policy.

Contact Us

If You have any questions, concerns, or requests regarding Your Information or our Privacy Policy, please contact us at: 1-905-850-7746