HWARP Privacy Policy


HWARP Inc. (the “HWARP”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information, including through our HWarp Platform (“Platform”) that allows health care providers and physicians (“Care Providers”) and health organizations (“Organizations”) to communicate with patients, (“Customers”) or in the case of minors or dependent patients, the parents or caregivers of patients (“Caregivers”), and provide digital care before and after a surgery, procedure or medical intervention (the “Services”).

The privacy of our users is of significant importance to our organization. By visiting our website located at https://www.hwarp.com/ (the “Website”) or using the HWarp Platform or related Services in any manner (as those terms are defined in our Terms of Use), you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals or information that is linked to an identifiable individual (“Personal Information”). This Privacy Policy does not apply to the practices of companies that we do not own or control, including those of Care Providers who subscribe to the Services.

Care Providers and Organizations are responsible for their own privacy practices when using the Platform, including getting consent to collect, use and disclose patient Personal Information and/or personal health information as may be required by law.

COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA

2.1.     Care Providers, Organization Managers, and Health Administrators                                              

In order to use the HWarp Platform, Care Providers, Organization Managers and Health Administrator users must have a valid HWarp account to log into HWarp (“Account”). When a user registers for HWarp Platform, HWARP collects:

  • first and last names, birthday, phone number, address and email address;
  • medical practice information, Care Provider’s practice specialties; and
  • billing information, including credit card details and billing address.

HWARP uses the Personal Information to uniquely identify you as a user, authenticate your Account access, and provide access to the HWarp Platform and Services, including access to the Organization’s account. HWARP uses the billing information to process payments for subscription fees in respect of any paid subscriptions to the Services.

HWARP administers a workflow engine that sends tasks known as activity objects to patients that provide information, instruction and/or actions from Care Providers, Organization Managers and Health Administrators in order to improve HWarp Platform user experience.

2.2       Customer Information

Customers must have a valid account in order to use the Services (“Customer Account”). HWARP collects Customers’ names, email addresses, phone numbers from their Care Provider to allow the Care Provider to invite the Customers to use HWarp Platform. When a Customer creates a Customer Account, HWARP collects the following Personal Information:

  • contact and demographic information, including first and last names, birthday, phone number, gender, address and email address;
  • Procedure and medical information, including name of procedure, date and time of procedure, location of procedure, date of any related appointments, physicians performing procedure, specialty procedure belongs to; and
  • Digital care action plans and Care Provider advice, activities to perform (ex. stretching, removing gauze, etc.), and when to do them, instructions on pre-hab, re-hab and wellness care, appointments with their dates, times, and locations.

The Personal Information above is collected from the Care Provider or Customer directly. If the Customer is a “dependent patient” user, HWarp may also collect Personal Information from that Customer’s Caregiver. If a Customer invites a Caregiver to be linked to the Customer’s Account, the Caregiver will have access to all of the Customer’s Personal Information, including medical information, in the Customer Account.

It is stored on behalf of the Customers so Care Providers can maintain compliant records. Information related to the Customer’s medical and procedure history is collected from the Care Provider and/or Customer to allow Care Providers and Customers to utilize the Services.

HWARP administers tasks and collects completed actions from Customers in order to improve Customer experience and the HWarp Platform and Services.

2.3      Caregivers

HWARP collects Personal Information from caregivers of Customers who create an Account to access the Services on behalf of a Customer (“Caregivers”).  When a Caregiver creates an Account, HWARP collects the following Personal Information:

  • contact and demographic information, including first and last names, birthday, phone number, gender, address and email address;

Personal Information of Caregivers is used to provide the Services to Caregivers on behalf of Customers.

2.4 HWarp Platform Usage Data

The HWarp Platform tracks certain information about usage of the software Platform, including the entry of Customer information, Platform usage (i.e. time spent on platform, frequency of logins, etc.)

(“Usage Data”).  HWARP uses Usage Data in order to diagnose technical issues with the Platform, monitor and improve Platform efficiency, and inform product development and Platform improvement.

2.5       Website Data

HWARP may also collect certain information from users of the Website through web forms that collect your first name, last name, email address, phone number, and may also collect Internet addresses, time spent logged into the website, and other usage data (“Website Data”). This information is logged to respond to user queries, provide ongoing email updates, and to constantly improve the quality of the Services.

The Website uses technologies such as cookies, beacons, scripts, and tags. These technologies may be used for analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. Various browsers may offer their own management tools for removing these types of tracking technologies.

In particular, the Platform utilizes session cookies to save browser sessions for automatic log in.

STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

HWARP stores its Platform data, including Personal Information, using cloud services on servers located in Canada. By submitting Personal Information, you agree to this transfer, storing or processing of your Personal Information in Canada and USA by our service providers including those listed on our platform endpoint process page. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those countries under lawful access regimes or court order.

DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

4.1.     Service Providers and Business Partners

We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the HWarp Platform and related Services. In particular, HWARP uses cloud services provided by the end-point service listed on our endpoint process page, service providers may be replaced or supplemented by HWARP from time to time. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of software licensing, maintenance services, database management, Web analytics and general improvement of the HWarp Platform and related Services.

4.2.     Business Transfers

If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

4.3.     With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.

RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

ACCESS, CORRECTION AND ACCURACY

You have the right to access and download the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. 

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.

ADDITIONAL INFORMATION

Questions regarding this Privacy Policy or HWARP’s privacy practices should be directed to:


Attn: Privacy Team
HWARP Inc.
1155 Lola Street, Suite 200
Ottawa, ON
Email: privacy@hwarp.com   

Last Updated: Dec 1, 2019