Arlo Privacy Policy

The Arlo Healthcare Company Inc. (“Arlo”, “we”, “our” or “us”) recognizes the importance of privacy. The purpose of this Privacy Statement is to inform you about our privacy practices, including how we collect, use, and disclose your personal information in connection with your use of our website and our software application (collectively, the “Platform”).

What This Privacy Statement Covers

This Privacy Statement covers the following topics:

Personal Information We Collect

How We Use Your Personal Information

How We Share Your Personal Information

Your Consent

Children’s Personal Information

Our Use of Cookies

Opting Out of Marketing Communications

Retention and Storage of Personal Information

Information Security

Accessing and Updating Your Personal Information

Third-Party Websites and Services

Changes to this Privacy Statement

How to Contact Us

Personal Information We Collect

“Personal information” means information about an identifiable individual as described under Canadian privacy laws.

Personal information generally does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.

We may collect, use, and disclose different types of personal information, depending on our relationship with you. Generally, we collect the following types of personal information (not all of which may apply to you): 

identity information, such as your name, username or similar identifier, marital status, title, date of birth, and sex assigned at birth;

contact information, such as your billing address, e-mail address, and telephone numbers;

personal health information, such as the name of your healthcare provider, information about your health history, records of treatment and clinical notes from patient encounters, diagnoses and diagnostic test results, and any other information about you that is collected in the course of providing you with health services (“Medical Records”);

financial information, such as your bank account number and payment card details used to purchase products or services;

account information, such as your username and login credentials;

technical and usage information when you use our Platform, such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Platform;

information you provide to us, such as inquiries, feedback and reviews; and

marketing and communications information, such as your preferences for receiving communications from us.

We may also create, use, and share anonymized data for any purpose. Anonymized data is generally not considered personal information because it cannot be used to identify you.

How We Use Your Personal Information

We generally use your personal information for the following purposes:

to determine your eligibility for our Platform and other services in accordance with applicable laws and our policies;

to provide you or your registered dependents with telehealth services through the Platform;

to administer your use of our Platform, including by creating and setting up your account and user profile and receiving payment for services provided to you;

to respond to your inquiries, complaints or requests;

to communicate with you through our newsletter or other communications;

to manage our business and our arrangements with our users and customers, including to detect and prevent errors and fraud;

to improve the quality, effectiveness and efficiency of our Platform, operations, and services;

to investigate legal claims and protect our rights, operations or property;

for such other purposes as you may consent to from time to time; and

as otherwise required or permitted by law.

How We Share Your Personal Information

We generally identify to whom, and for what purposes, we will disclose your personal information (and we obtain your consent to such disclosure) at the time we collect your personal information.

If you receive telehealth services through our Platform, we may disclose your Medical Records to other healthcare providers to facilitate the provision of your healthcare. This helps to coordinate care and ensure that everyone involved in your healthcare has the right information to meet your healthcare needs

We may also disclose your personal information when we believe such disclosure is required or permitted by law. In addition, we may disclose your personal information to a third party in the event of any significant business transaction, such as a merger or reorganization.

We may rely on service providers to perform a variety of services on our behalf, such as payment card processors, technical support providers, and data storage and processing service providers. If we transfer your personal information to service providers, we require that those service providers maintain the confidentiality of your personal information and keep it secure.  

Your Consent

We may collect, use, and disclose your personal information with your consent. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question. Generally, we will seek your consent at the time we collect your personal information, either orally, electronically, or in writing.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their information as described in this Privacy Statement.

If you wish to withdraw your consent to our collection, use or disclosure of your personal information, or place conditions on your consent, please contact us using the contact information below. We will accommodate your request to withdraw or place conditions on your consent, subject to legal or contractual restrictions. Withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services.

In certain circumstances, we may collect, use, and disclose your personal information without your consent to the extent permitted or required by law.

Children’s Personal Information

Individuals under the age of 16 may not create an account through our Platform. Parents or legal guardians may create user profiles for children for whom they have the right to make healthcare decisions, in which case we will collect personal information about children from their parent or legal guardian as described in this Policy.

Our Use of Cookies   

A “cookie” is a small text file that contains information and is stored on your computer. We generally use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our Platform and your interaction with our emails. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage.

We may use this information to facilitate the use of our Platform, for our business or analytical purposes (including to asses website traffic and track search criteria), and to personalize web pages according to your choices and interests.

We may also use this information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our Platform, and across third-party websites or service offerings when you leave our Platform. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests. For example, we may use Google Ads to provide you with advertising based on your browsing history and search requests.

If you do not wish to accept cookies, you can adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. Some areas or features of our Platform rely on cookies and may not work if you delete or decline cookies. For more information about cookies please visit www.allaboutcookies.org.

Opting Out of Marketing Communications

If you no longer want to receive marketing-related e-mails from us, you may opt out by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information below.

If you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our Platform or services, or other matters.

Retention and Storage of Personal Information

We, and our service providers, will store your personal information in Canada.  

We generally will retain your personal information for as long as necessary to fulfill the purposes for which we collected it. We retain Medical Records for the period of time required by law.

Information Security

We have implemented physical, organizational, contractual, and technological security measures in an effort to protect your personal information from loss or theft, unauthorized access, use, or disclosure. Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in risks such as phishing and identity theft. We will address such breaches as required by law.

We may also require that you assist us in safeguarding your personal information. For example, if you create an account through our Platform, you should use a unique and strong password and not share your password with others.

If you have reason to believe that your personal information is no longer secure, please contact us immediately using the contact information below.

Accessing and Updating Your Personal Information

We expect you to supply us with updates to your personal information, when required.

If you have an account through our Platform, all personal information in your account, including your Medical Records, is accessible by you. You can make changes to certain personal information that we have collected about you, such as your contact information, by editing the information in your account. 

You may also contact us to make a request to review any personal information about you that we have collected, used, or disclosed, and information about those uses and disclosures, and we will provide you with any such personal information to the extent required by applicable laws.

You may also challenge the accuracy or completeness of your personal information in our records. If you demonstrate that your personal information in our records is inaccurate or incomplete, we will amend or delete your personal information as required. We may transmit the amended information to third parties to whom we have disclosed your personal information.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. We will not charge you any fees to access your personal information in our records, including your Medical Records, without first providing you with an estimate of the approximate fees, if any.

Third-Party Websites and Services

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy statements and policies of the respective third party. This Privacy Statement does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.

Changes to this Privacy Statement

The Privacy Statement was last revised as of the date that appears at the top of this page. From time to time, we may make changes to this Privacy Statement. When changes are made, they will become immediately effective when published in a revised Privacy Statement posted on our website, unless otherwise noted. We may also communicate the changes to this Privacy Statement by other means.

How to Contact Us

All comments, questions, concerns, or requests regarding your personal information or our privacy practices should be forwarded to our Privacy Officer at privacy@arlohealth.ca