Web and Mobile Privacy Policy

WEB AND MOBILE PRIVACY POLICY

Last updated on October 25, 2021

Teladoc Health Canada, Inc., on its own behalf and its affiliates and/or wholly owned subsidiaries (collectively referred to as "Teladoc", "we", "us", or "our"), makes certain telehealth related information available to you and/or facilitates your access to telemedicine, chronic condition management, and expert medical services ("Teladoc Services").

This Privacy Policy applies to visitors of www.teladochealth.com/en-CA/ and its publicly available associated domains and mobile applications owned and operated by Teladoc (collectively, the "Websites"). For the purposes of this Disclaimer, "you" and "your" means you as the visitor of the Websites.

This Privacy Policy describes the types of Personal Information we collect from visitors of our public Websites and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us.

This Privacy Policy does not apply to information collected from visitors who register and log-in ("Members") to the password-protected and secure portions of our sites ("Secure Platforms"). The Secure Platforms allow eligible Members to use Teladoc Services. All information collected and stored by Teladoc or added by our Members into such Secure Platforms is considered Protected Health Information ("PHI") and/or medical information and is governed by applicable laws that apply to that information. How Teladoc uses and discloses such PHI is in accordance with the applicable Canadian Notice of Privacy Practices for Teladoc Services. For example, if you have consented to importing data from HealthKit into the Secure Platform, you should review our Notice of Privacy Practices to understand how we use and disclose such PHI.

When using our Websites, you may choose to interact with features from third parties that operate independently from Teladoc, such as social media widgets and links to third-party websites. Teladoc has no control over and is not responsible for the privacy practices of such third parties. This Privacy Policy does not apply to the extent Teladoc does not own or control any linked websites or features you visit or use. We recommend that you familiarize yourself with the privacy practices of those third parties.

This Privacy Policy is not a contract and does not create any contractual rights or obligations.

TYPES OF PERSONAL INFORMATION WE COLLECT

While using our Websites, you might provide us with certain information about you. We or our advertising partners may automatically collect information through the use of cookies and other tracking technologies (see below).

Personal Information that we collect through your use of the Websites may include IP Address, Device ID, and online identifier. We may use that Personal Information and link it to Internet or other electronic network activity information, and we may draw inferences about you from the information we collect. During you use of the Websites, we may collect your name, title, contact information (e.g., business, address, phone number, email address), or date of birth, but only if you proactively provide it to us when registering or on a web form.

HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information using the following methods:

Directly from you when you provide it to us (such as information you enter into web forms, inquiries, responses, activity on the Websites, and during registration to use a Security Platform).
From third parties, such as analytics and email marketing service providers.
Automatically through tracking technologies (cookies, web beacons, log files), including over time and across third-party websites or other online services.

"Cookies" are small files that a website stores on a user's computer or device. The Websites may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Websites and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (see below). In accordance with applicable law, we may obtain your consent separately before collecting information by automated means using cookies or similar devices.

Our Websites may use Google Analytics, a vendor's service that uses cookies, web beacons, web pixels and/or similar technology to collect and store anonymous information about you. You can learn more about Google Analytics' privacy policy and ways to opt out from Google Analytics tracking by visiting Google Analytics' website.

Our Websites may use Adobe's analytics and on-site personalization services, which use cookies, web beacons, web pixels and/or similar technology to collect and store information about you or your device or browser. You can learn more about how Adobe may handle information collected through our use of its services, and your options for controlling this activity, by visiting Adobe's website.

For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see below.

HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following purposes:

Operate, maintain, supervise, administer, and enhance the Websites, including monitoring and analyzing the effectiveness of content on the Websites, aggregate site usage data, and other usage of the Websites such as checking your eligibility and assisting you in completing the registration process.
Provide you with a tailored and user-friendly experience as you navigate our Websites.
Promote and market our Websites to you.
To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information, request a demo, or request an RFP.
Conduct research on users' demographics, interests, and behavior based upon information provided during use of our Websites.
Anonymize and aggregate information for analytics and reporting.
Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Websites and safety of users.
Develop, test, improve, and demonstrate the Websites.
Any other purpose with your consent.

We only use and disclose your Personal Information for the purposes for which it was collected, except as authorized by law.

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:

For business purposes. We may share your Personal Information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms. We may disclose your name, email address, date of birth, phone number, and address if you provided it to us via a form on the website or during an incomplete or failed registration to Service Providers.
With your direction or consent. We may share your Personal Information with third parties if you request or direct us to do so. This includes your use of social media widgets on our Websites.
With affiliates within our corporate group. We may share your Personal Information with any subsidiaries within our corporate group.
Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
In the context of a transaction. We may share your Personal Information connection with an asset sale, merger, bankruptcy, or other business transaction.
For other business reasons. We may share your Personal Information to enforce any applicable Terms of Service or Legal Disclaimer, and to ensure the safety and security of the Websites and/or our users.

We also may disclose deidentified information. Note that if you make any Personal Information publicly available on the Websites, anyone may see and use such information.

Certain features of the Websites permit you to initiate interactions between the Websites and third-party services or platforms, such as social networks ("Social Features"). Social Features include features that allow you to click and access Teladoc's pages on certain third-party platforms, such as Facebook, Twitter and LinkedIn as applicable, and from there to "like" or "share" our content on those platforms. Use of Social Features may entail a third party's collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both Teladoc and the third party may have access to information about you and your use of both the Websites and the third-party service.

THIRD PARTY WEBSITES AND LINKS

Our Websites may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook, LinkedIn or Twitter) may also be viewable by other users of the Websites and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Websites. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

COOKIES AND INFORMATION USED FOR ADVERTISING

As discussed above, on our Websites, we may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Policy provides details and explains how to exercise your choices. You may see certain ads on other Websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to Websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies visit the appropriate link below.

Microsoft Internet Explorer

You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our Websites may not work properly.

Your browser settings also may allow you to transmit a "Do Not Track" signal when you visit various websites. Some of the Websites may not be configured to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit here.

If you have further questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

CHILDREN'S PRIVACY

Our Websites are not intended for children under 16 years of age, and we do not knowingly collect or sell Personal Information from children under 16. If you are under 16, do not use or provide any information on these Websites or through any of its features. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 16 years of age whom you believe might have provided us with their Personal Information, you may contact us using the below information to request that it be deleted.

SECURITY OF PERSONAL INFORMATION

We take steps to secure Personal Information through administrative, technical, and physical safeguards designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

RETENTION OF PERSONAL INFORMATION

We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements. Because we maintain our Websites to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.

CROSS BORDER TRANSFER OF PERSONAL INFORMATION

Personal Information Teladoc collects through your use of the Websites is stored in Canada.

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

Right to Access Personal Information. You have the right to obtain a copy of the Personal Information that Teladoc collected from your use of the Websites. To access a copy of your Personal Information, you must submit your request in writing to Teladoc. Teladoc may impose a fee for the costs of copying, mailing, labor and supplies associated with your request. Teladoc may deny your request to inspect and/or copy your Personal Information in certain limited circumstances. If that occurs, Teladoc will inform you of the reason for the denial, and you may request a review of the denial.

Right to Correct Personal Information. You have a right to request that Teladoc amend your Personal Information if you believe it is incorrect or incomplete. You must submit your request in writing to Teladoc and provide a reason to support the requested amendment. Teladoc may, under certain circumstances, deny your request by sending you a written notice of denial. If Teladoc denies your request, will inform you of the reason for the denial, and you may request a review of the denial.

Right to Withdraw Consent. If you do not want Teladoc to collect your Personal Information, you must stop using the Websites. You may, at any time, withdraw your consent for us to collect, use, and disclose your Personal Information as outlined in this Privacy Policy, however, withdrawal of consent is subject to legal or contractual restrictions and reasonable notice. At your request, we will delete your Personal Information unless we are required to retain it to meet our legal or regulatory obligations including provincial retention guidelines for health care providers.

Right to ask questions or file a complaint. If you have any questions, wish to make a complaint about this Privacy Policy, or wish to request any of the rights listed above, contact us at privacy@teladochealth.com or

Privacy Officer
Teladoc Health
2 Heritage Drive, 5th Floor, Suite 5A
North Quincy, MA 02171
(855) 213-6709 (toll free)

If you contact us to exercise any of the rights above, we will respond to your request within a reasonable time and at no cost to you.

UPDATING THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.