12700921 Canada Inc., d.b.a. Topology Health (“Topology Health” “we”, “us”, “our” and terms of similar meaning) takes your privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use, protect and disclose:

1. your personal information and/or your personally identifiable information (collectively referred to together in this Privacy Policy as “Information”); and
2. data we obtain from your activity on our website (the “Site”) or through the Services (as defined below) (“Data”) as part of providing the EHR Auth Gateway software (the “Software”), which will offer you the opportunity to connect to Electronic Health Records systems (EHRs), and associated services (collectively with the Site and Software, the “Services”).

We encourage you to read and understand our Terms of Service “Terms” and this privacy policy (“Privacy Policy”) before using the Services. By accepting the Terms or Privacy Policy and/or accessing or using the Services, you expressly consent to our collection, use and disclosure of your Information and Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms.

All capitalized terms or terms that were otherwise defined in the Terms that are not otherwise defined herein obtain their meaning from the Terms, including, without limitation, the definition of “you” and “your” used in the Terms.

What Information and Data Do We Collect?

1. General.

   Our primary purpose in collecting information and data from you voluntarily is to provide you with a safe, smooth, efficient, and customized experience when using the Services. We will only ask for and collect Information and Data that we consider necessary for achieving this purpose.

2. Information you provide.
   1. You can access the Site without having to register, but in order to use the remaining Services, you must sign up and register for a User Account on the Software. When registering for a User Account, you must provide Information as requested or where indicated on the Software. Where possible, we indicate which fields are required and which fields are optional. In addition, as you use the Services, you may be required or requested, from time to time, to provide further Information through the Services. The Information you may be required or requested to provide may include, without limitation, name, address, phone number, e-mail address, username and/or password.
   2. You represent that you have the right and authority or have obtained all necessary consents and approvals to provide any Information, including any Information of another individual or entity, that is provided by you to Topology Health or otherwise to or through the Services.
3. Data Collected Automatically

   As you navigate through and interact with the Services, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

   1. Details of your visits to the Site and/or the Software, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site and/or the Software.
   2. Information about your computer and internet connection, including your IP address, operating system, and browser type.
   3. The information we collect automatically is statistical data and does not include Information, and we may maintain it or associate it with Information we collect in other ways, including Information that you provide to us, or we receive from third parties. It helps us to improve the Site and/or the Software and to deliver a better and more personalized service, including by enabling us to:
      • Estimate our audience size and usage patterns.
      • Recognize you when you return to the Site and/or the Software.

How Do We Use Your Information and Data?

We use your Information and Data to help us provide, operate, improve, understand, customize, support, and market the Services; to determine your eligibility to have a User Account and be a Client and/or User; to provide you with access to and use of the Services; to provide you the license to use the Services; to communicate with you, either directly or through one of our partners, including for marketing and promotional purposes; to improve our marketing and promotional efforts; to advise you of Services related updates; to resolve service disputes; to troubleshoot problems; to inform you about online and offline products, services and updates; to analyze usage of the Services; to improve our Services and product offerings; to detect and protect us against error, fraud and other criminal activity; to enforce the Terms; to provide you with system or administrative messages; and/or as otherwise described to you at the time of collection.

Our Disclosure of Information and Data

1. General Disclosure.

   We may share your Information and Data with third parties only in the ways that are described in this Privacy Policy and in accordance with your consent. We will not share, sell or rent your Information or Data to third parties without your explicit written consent.

2. Anonymized Aggregated Data.

   We may aggregate and anonymize Data and use and disclose it for a variety of purposes, including analytics. However, in these situations, we do not disclose any Information.

3. Laws and Jurisdictions.

   Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose Information and Data if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or any other person’s or entity’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your Information and Data.

4. Sale of Business.

   We may disclose Information and Data to the acquiror or its agents in the course of the sale of our business, in accordance with applicable law. If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.

5. Storing and Processing Information and Data.

   In some cases, Information and Data that we collect may be stored or processed outside of Canada. When that occurs, we continue to protect the Information and Data with appropriate safeguards and data export requirements, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.

6. Subsidiaries, Affiliates and Service Providers.

   We may use the services of affiliates, subsidiaries and/or unrelated third-party service providers (collectively, “Third Parties”) in connection with our provision of the Services, including, without limitation, off-premise data hosting and communication services. We may disclose your Information and Data to the Third Parties in the course of our use of their services. We take care to use Third Parties that we believe are reputable and capable of performing the services we require of them, including, without limitation, the handling of confidential information and Information and Data and the compliance with all applicable laws.

Your Information and Data Rights

In accordance with the applicable privacy laws, you may have the following rights with respect to your Information and Data:

1. Right of Access and Portability.

   You may ask for an overview or copy of your Information and/or Data to be provided to you; and/or transferred to another organization.

2. Right to Rectification.

   You may review your Information and delete and/or update it through your User Account or by contacting us, to ensure it is accurate and complete on the Services.

3. Right to Erasure and Restriction.

   You may ask us to remove and/or restrict our processing of your Information and/or Data in certain circumstances (e.g. if you believe we have processed your Information and/or Data unlawfully), if you believe that your Information and/or Data is no longer necessary for the purposes in which it was collected or processed, you withdraw your consent (as discussed below). Notwithstanding the foregoing, despite such request, subject to all applicable laws and the terms and conditions of this Privacy Policy, we may still retain your Information and Data for legitimate business interests, to collect any fees owed (if and as applicable), resolve disputes, troubleshoot problems, analyze usage of the Services, assist with any investigations, prevent fraud, enforce our Terms and/or take other actions as required or permitted by law.

4. Right to Withdraw Consent.

   Where we have asked for your consent to use and/or process your Information and Data, you can withdraw this consent at any time. We will do our best to accommodate your request, subject to applicable laws and the terms and conditions of this Privacy Policy.

Please contact us. if you would like to exercise any of the above rights.

Communication Preferences

You can always unsubscribe from our commercial and promotional emails, but we may still send you communications relating to your status as a Client and your Users and your use of the Services in accordance with applicable anti-spam legislation.

Information and Data Retention

1. General Retention Policy.

   We keep Information and Data for as long as it is required for the purposes for which it was collected, which is determined in our sole discretion, in accordance with the applicable laws. Notwithstanding the foregoing, we may periodically de-identify (a) Information from collected Data in unused User Accounts; and (b) unnecessary Information from Data collected elsewhere on and/or through the Service. Subject to the terms and conditions of this Privacy Policy and applicable law, with the exception of aggregated Data, we may delete unused User Accounts and the Information and Data associated with them within a time period as required by applicable law.

2. Termination of User Account.

   If your User Account is terminated, we may deactivate it, but we may retain your Information and Data for a certain period of time and disclose it in a manner consistent with our practices under this Privacy Policy.

Security

Each User Account is protected by a password for your privacy and security. You must prevent unauthorized access to your User Account by selecting and protecting your password appropriately and limiting access to your device. We strive to protect your Information and Data by putting in place a range of technical and organizational measures to safeguard and secure the Information and Data we receive from you, including without limitation, security technologies, encryption, passwords and physical security measures and managerial procedures. Information you provide to us is stored on our secure servers or on secure servers used by our service providers. We are continuously utilizing security measures to protect your Information and Data from unauthorized access or against loss, misuse or alteration. Despite our efforts, we cannot guarantee the security of any Information and Data. Unauthorized entry or use, hardware or service failure and other factors, may compromise the security of Information and Data at any time. We reserve the right, without any limitation, to investigate any suspected breaches of the Services security or information technology or other systems or networks.

Changes to This Privacy Policy

Topology Health may amend this Privacy Policy from time to time. The use of Information and Data we collect is subject to the Privacy Policy and the Terms in effect at the time the Information and Data is used. If we make any material changes in the way we use Information and Data you provide to us, we will notify you by:

1. posting a notice on the Software or your User Account page
2. sending you an email at the address registered on the applicable User Account; and/or
3. otherwise notifying you pursuant to the notice or modification provisions in the Terms. You are bound by any changes to the Privacy Policy and the Terms when you access, use or purchase the Services after such changes have been first posted, subject to the terms and conditions of the Terms.

Get in touch

It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please contact us.