Note about Minors: The Services may be used by patients and users of all ages. Please note that parental or legal guardian’ consent may be required in connection with the use of the Services and provision of Personal Information by minors who are below the age of 13 and/or are not capable of making independent decisions about their health and use of the technology.
2. COLLECTION OF PERSONAL INFORMATION
2.1 Institutional Users’ Information
In order to provide the Services to Healthcare Institutions and their permitted users which may include administrators and healthcare providers (“Institutional Users”) , we require access to certain Personal Information. In particular, administrative users are required to submit this Personal Information to create an account on the Hero AI Platform and in order to use the Services. In particular, Hero AI may collect the following Personal Information from Institutional Users or administrator):
- First and last name
- Email address
- Phone number
- Role/position and department in the organization (e.g. hospital)
- List of patients under an Institutional User’s care
In the course of providing the Services such as the App, we collect Personal Information regarding the individual patients who are using the Services (“Patients”). In order to create accounts for Patients we require the following minimum information:
- Patient Name
- Parent/Legal Guardian Name
- Patient date-of-birth
- Patient Gender
- Patient MRN (this is used to link your account with an institution electronic health record system)
- Patient Postal Code
Based on the Services requested by our Customers (i.e. healthcare institutions), electronic health record information and Personal Information may be shared that includes but is not limited to the following:
- Patient Ward Location/Room
- Patient/Parent Phone Number
- Patient/Parent Email
- Patient Postal Code
- Patient Chief Complaint (i.e. reason for presenting to the to emergency department/hospital)
- Patient Language Preference
- Patient Address
- Patient Triage Vital Signs
- Patient Most Recent Vital Signs
- Patient Free Text Triage Nursing Note
- Patient Free Text Clinical Encounter Note
- Patient Lab Orders and Corresponding Results
- Patient Imaging Orders and Corresponding Results
- Name of Nurse(s) Assigned to Patient
- Name of Physician(s) Assigned to Patient
- Patient Time of Arrival
- Patient Mode of Arrival
- Patient Institutional User Initial Assessment Time
- Patient Length of Stay Time
- Patient IP Address
Please note that in addition to Personal Information which Patients make available through the Service, other users such as Healthcare Institutions and Institutional Users. In such cases, the Healthcare Institution is typically the “health information custodian” under applicable laws related to the protection of personal health information.
2.3 Personal Information automatically collected through the use of the Software and App
Hero AI collects certain Personal Information that is uploaded to the Software or App, or that is generated from a Patient’s or Institutional User’s usage. For example:
- Institutional User input into the App (messages sent to Patients)
- Patient input into the App (messages sent to Institutional User)
- App utilization metrics, such as time of usage, number of messages
2.4 Device Information
When you visit the Website or access the App or Software, we may collect certain information about your device, including information about your device ID web browser, IP address and general location/time zone. This information is used for the purpose of maintaining security, threat detection, and troubleshooting software issues.
3. USE OF YOUR PERSONAL INFORMATION
3.1 End Users
Our primary purpose for using your Personal Information is to provide the Services, including:
- Allowing you to access and use the Software, App and Services, and in particular providing the following Services to healthcare organizations:
- Facilitate on-demand virtual care between patients and healthcare Institutional Users including video calls, messaging, and interactive beacons (pain scales, oral hydration assessments etc.);
- To facilitate the utilization of algorithms, machine learning models, and artificial intelligence to make predictions for the purposes of clinical automation and improving healthcare delivery;
- To generate metrics to be displayed on dashboards and in the mobile App;
- To generate reporting metrics for our clients related to technology utilization by patients; and
- To facilitate research and development of future models and software innovations.
- Providing you with assistance (including technical assistance) in relation to your use of the Services;
- Personalizing and optimizing your experience of the Services and providing you with software updates; and
- Ensuring compliance with the terms of our agreement with your organization.
We may also use your Personal Information for other purposes if we have a legal basis for doing so, including:
- Ensuring compliance with our own obligations under applicable law and regulations;
- Complying with court orders and other lawful access processes; and
- Using your Personal Information to help us to establish, exercise or defend legal claims.
3.2 Updates and News about Hero AI
We may use Personal Information of users in order to let you know about, and invite you to participate in, our products and service offerings. We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in in accordance with applicable laws. You can opt out of receiving marketing communications at any time.
4. DISCLOSURE OF PERSONAL INFORMATION
Where appropriate and in accordance with applicable laws, we may share your Personal Information in the following ways:
- Organizations who procure/administer the Services: When Institutional Users use the Services on behalf of Healthcare Providers, Personal Information and usage data of Patients and Institutional Users may be made available to the organization that holds the Hero AI license.
5. SAFEGUARDING PERSONAL INFORMATION
We are committed to taking all reasonable and appropriate steps to protect the Personal Information that we hold from misuse, loss, destruction or unauthorized access. We do this by having in place a range of appropriate technical and organizational measures.
6. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Hero AI may process and store data collected by Hero AI, including Personal Information, on cloud servers located in Canada. Hero AI takes steps reasonably necessary to ensure that the data is subject to appropriate safeguards, such as where applicable, relying on contractual commitments from our service providers.
Personal Information may be accessible to law enforcement and governmental agencies in Canada, and other jurisdictions in which your Personal Information is stored (if applicable) under lawful access regimes or court order.
7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
When we are no longer permitted under our agreement with your organization or it is otherwise no longer necessary to retain your Personal Information, we will delete the Personal Information that we hold about you from our systems. While we will endeavour to permanently erase your Personal Information once it reaches the end of its retention period, some of your Personal Information may still exist within our systems, for example if it is waiting to be overwritten.
8. HOW CAN YOU ACCESS OR CORRECT PERSONAL INFORMATION THAT WE HOLD ABOUT YOU?
You have the right to access 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. Upon receipt of your written request to the contact information below, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavour to deal with all requests for access and modifications in a timely manner.
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.
10. ADDITIONAL INFORMATION
Attention: Privacy Officer
Last Updated: March 16, 2022