This privacy statement (“Policy”) describes the current policies of Medipense Inc., (“Medipense” or “we” or “our”) with regard to personal information collected by us from you. Your privacy is important to Medipense. We developed this Policy so you know how we collect, use, disclose, transfer and store your information. Please read through this Policy to familiarize yourself with our privacy practices. If you have any questions, please let us know by emailing us or by sending a letter to the address set forth at the end of this Policy.
Table of Contents
- What information do we collect?
- What do we use your information for?
- Do we disclose any information to outside parties?
- What security measures have we implemented?
- Childrens Online Privacy Protection Act Compliance
- Personal Information Protection and Electronic Documents Act (PIPEDA)
- Québec P-39.1
- Health Insurance Portability and Accountability Act (HIPAA)
- FDA 21 CFR Part 11 Compliance
- General Data Protection Regulation (GDPR) (EU)
- California Privacy (CCPA)
- Your Consent
- How to update or delete your data
- Contacting Us
- Face-to-face, phone, email, chat, video conference, mail or other business interactions with our customers, vendors or other businesses interested in our products and services.
What information do we collect?
We collect information from you when you register on our site, use our products or services, place an order, subscribe to our newsletter, respond to a survey or fill out a form.
When ordering, inquiring or registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address, phone number, business or other information as necessary to operate our site, software or products.
We may record the following information:
- Email address and password (Registration Information),
- Name, billing address, shipping address (Billing Information),
- IP Address (Location Information),
- Birth date, gender, height, weight, affiliation (Profile Information),
- Data sharing permissions with other accounts (Permissions Information),
- Health data such as prescription information, medical conditions, allergies, caregivers and health care providers. Body metrics such as cardiac activity, breathing activity, movement activity, manual annotations, and others, and information and statistics based on these measurements (Activity Information).
All personally identifiable information and associated medical information is subject to PIPEDA, HIPAA and GDPR as described below.
What do we use your information for?
Any of the information we collect from you may be used in one of the following ways:
- To improve our website
We continually strive to improve our website offerings based on the information and feedback we receive from you
- To improve customer service
Your information helps us to more effectively respond to your customer service requests and support needs
- To process transactions
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
- To administer a contest, promotion, survey or other site feature
- To send periodic emails
The email address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.
Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
- To assist in your care or treatment
Share information with your health care provider, family, close friends, or others involved in your care.
- To operate our software and products
The information you provide or allow us to access on your behalf, may contain information such as medications, dosage, medical conditions, schedules, timing and other personal health data which is required to properly program and dispense your medications at the specified time.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable information may be provided to other parties for marketing, advertising, or other uses.
What Security Measures Have We Implemented?
We take serious measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. All web access, our web site, APIs and web portal all use Secure Sockets Layer (SSL) software, which encrypts information you input, to protect information you submit via our Services. In addition, all data and images stored online via the RxPense are encrypted at rest. Medipense’s products use biometric, RFID and password authentication schemes to better protect and limit access to only those authorized. More details on what measures Medipense takes to secure Protected Health Information can be downloaded here.
Our security measures are only as good as you are in ensuring privacy. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.
Childrens Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
Personal Information Protection and Electronic Documents Act (PIPEDA or the PIPED Act)
We are in compliance with the law concerning privacy of your information. In Canada, we are governed by PIPEDA, an overview of which and how we are establishing company policy and compliance can be downloaded here.
The law gives individuals the right to
- know why an organization collects, uses or discloses their personal information;
- expect an organization to collect, use or disclose their personal information reasonably and appropriately, and not use the information for any purpose other than that to which they have consented;
- know who in the organization is responsible for protecting their personal information;
- expect an organization to protect their personal information by taking appropriate security measures;
- expect the personal information an organization holds about them to be accurate, complete and up-to-date;
- obtain access to their personal information and ask for corrections if necessary; and
- complain about how an organization handles their personal information if they feel their privacy rights have not been respected.
The law requires organizations to
- obtain consent when they collect, use or disclose their personal information;
- supply an individual with a product or a service even if they refuse consent for the collection, use or disclosure of your personal information unless that information is essential to the transaction;
- collect information by fair and lawful means; and
- have personal information policies that are clear, understandable and readily available.
Québec P-39.1 – Act respecting the protection of personal information in the private sector
The object of this Act is to establish, for the exercise of the rights conferred by articles 35 to 40 of the Civil Code concerning the protection of personal information, particular rules with respect to personal information relating to other persons which a person collects, holds, uses or communicates to third persons in the course of carrying on an enterprise within the meaning of article 1525 of the Civil Code. For full details, download the Act.
Health Insurance Portability and Accountability Act (HIPAA)
In the USA, Medipense is compliant with HIPAA and takes all measures available to protect your data. To download a copy of our HIPAA policy: Medipense-HIPAA-Compliance-Notice-2018.
FDA 21 CFR Part 11 Compliance
21 CFR Part 11 regulations set forth the criteria under which the FDA considers electronic records, electronic signatures, and handwritten signatures executed to electronic records to be trustworthy, reliable, and generally equivalent to paper records and handwritten signatures executed on paper. This part applies to records in electronic form that are created, modified, maintained, archived, retrieved, or transmitted, under any records requirements set forth in agency regulations. This part also applies to electronic records submitted to the agency under requirements of the Federal Food, Drug, and Cosmetic Act and the Public Health Service Act, even if such records are not specifically identified in agency regulations. However, this part does not apply to paper records that are, or have been, transmitted by electronic means.
The software development methodology and quality system that is in place at Medipense along with the functionalities of the cloud-based software have been reviewed for ability to comply with FDA 21 CFR part 11. The conclusion is that the software is part 11 ready and if configured properly by the client will meet 21 CFR part 11 expectations for compliance.
General Data Protection Regulation (“GDPR”) (EU)
The General Data Protection Regulation (GDPR) is the toughest privacy and security law in the world. Though it was drafted and passed by the European Union (EU), it imposes obligations onto organizations anywhere, so long as they target or collect data related to people in the EU. The regulation was put into effect on May 25, 2018.
California Privacy (CCPA)
The California Consumer Privacy Act (“CCPA”) provides consumers, in California, with specific rights regarding their Personal Information. Principally, The CCPA will provide consumers, in California, with new rights, including a right to transparency about data collection, a right to be forgotten, and a right to opt out of having their data sold.
While the CCPA does not apply to information already subject to other USA federal regulations, such as HIPAA for example, it does apply to entities covered by these laws to the extent they collect and process other personal information about consumers.
While much of the CCPA is a subset of the GDPR, there are several unique differences.The CCPA requires that we disclose for the previous 12 months:
- Types of personal information that Medipense has collected
- Types of personal information that Medipense has sold
- Types of personal information that Medipense has shared for commercial reasons
Since we do not sell your data, there is no need to opt-out. However, if you have concerns about the use of the data we do collect as you browse this web site or purchase a product, you may request that we delete any personally identifiable data by submitting our Request to Erase Your Data form, or by following the instructions provided on that form. You should also exit our web site and delete any cookies or history stored in your browser. The simplest approach to perform this action is to search for “how to delete cookies” in your favorite search engine.
How to update or delete your data
You can ask us to correct health information about you that you think is incorrect or incomplete. You can always update or delete any medical information yourself by logging into your account. Ask us how to do this.
You may ask us to delete your medical and personal information, including your account. Requests should be submitted with the Request to Erase Your Data form, or by following the instructions provided on that form.
We will comply with the understanding that you may no longer be able to use our products or services. Due to legal or government requirements, we may have to maintain an archived copy of your data along with any transaction records for a fixed period of time.
Policy revised: 21 Mar 2020