Clever Consult Services Corporation (“Clever Consult”, “we”, “us”, “our”) is proud to offer you our website (available at www.cleverconsult.ai) (the “Website”) and associated services including via our website (“Services”). This Privacy Policy describes how we collect, store, use and distribute information about the healthcare practitioners (“you”) who use our Services and their patients. Clever Consult’s customers are healthcare practitioners who are utilizing the Services. If you are a patient or guardian of a healthcare practitioner who uses Clever Consult and do not wish for your personal information to be collected, used, disclosed or otherwise processed in the manner described in this Privacy Policy, you must inform the healthcare practitioner that you do not consent to the use of your personal information by Clever Consult.
What is personal information?
Personal information means any information about an identifiable individual, including information that can be used to identify you. This may include your name, address, telephone number, email address, payment information as well as PHI (defined below) contained patient records you may share with us.
What personal information do we collect?
Account information: When you register for Clever Consult, we will collect the information
you provide such as your name, phone number, email address, fax number, your
professional designation, billing information and any other information you may include.
Patient Documentation: Clever Consult only collects patients’ personal health information
(PHI) which is provided to Clever Consult by the patients’ healthcare practitioners.
Generally, PHI means information about an identifiable individual that relates to their
health or to the provision of health care to them.
We may also collect personal information from you when you request information from us, provide us feedback or otherwise interact or communicate with us, including via the phone, on social media, or when you email us.
How we use personal information.
We may use personal information for the purposes:
To establish and manage our relationship with you and provide you with the
information or Services requested;
To identify and authenticate you;
To communicate with you regarding inquiries for information or customer service
request or employment opportunities;
For administrative purposes (including managing our day-to-day operations, recordkeeping, quality control, safety, and research purposes);
To detect, prevent or investigate security breaches;
For marketing and advertising purposes;
To promote our services, products and events including via social media;
To process credit card or other payment information;
To process and respond to any complaints made by you; and
To protect our business and to carry out our obligations and enforce our rights arising from any agreements that we may have with you, including for billing and collection or to comply with legal requirements.
Patient Documentation: Clever Consult uses machine learning algorithms and other artificial
intelligence technologies which are needed to analyze the patient documentation to provide the
Services and improve performance. Without the ability to process the patient documentation,
Clever Consult would not work as intended.
Aggregated and Anonymized Data: We use aggregated or anonymized data for research and development of new products or tools, to refine our algorithms and machine learning applications, to improve the Services we provide, to develop statistical information, and to manage our business and operations. We may disclose such aggregated or anonymized information publicly and to third parties, for example, in public reports about health, to partners under agreement with us, or in benchmarking information we provide to the medical community. At no time will such information personally identify, or be used to identify, any individual.
Job applications: If you submit a job application to us, we will use the information relating to that application (such as your employment history) to assess your suitability to any of our job postings. We may also collect information from third parties about you, such as references you list, for the same purpose.
How we share personal information
We may share your personal information with our service providers such as our AI, cloud,
analytics, support and payment providers to operate the Website and provide our Services. This
includes sharing your personal information for:
Fraud prevention,
Payment processing and notifications,
Providing requested Services or information,
Operating the Website, and
Customer service.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any
government or regulatory request, in accordance with applicable law;
To enforce or apply our terms of use and other agreements, including for billing and
collection purposes;
If we believe disclosure is necessary or appropriate to protect our rights, property, or the safety of our users or others; or
In connection with a corporate re-organization, amalgamation, or sale of the business (or potential sale of our business).
How Clever Consult uses artificial intelligence
Clever Consult uses third-party artificial intelligence service providers (the “AI Service
Providers") to help provide the Services, process the patient information included in patient
documentation, and return a summary of the patient documentation as per the Services
Agreement for the healthcare practitioner to review (the “Summarized Note"). Our contracts
with our AI Service Providers ensure that they do not collect, use or disclose any information
provided to them, except to provide the services we specifically request. Additionally, we enforce a zero-retention policy with our AI Service Providers and have business associate agreements in place with them as well.
Consent
We only collect information by lawful means. As part of using our services or interacting with us,
we may collect and process some details about you. When we do so, we will collect, use or
share your personal information with your consent for the purposes identified or as otherwise
permitted or required by law. In compliance with our privacy obligations, we may obtain your
permission based on implied consent (including through this privacy policy) or through other
means (such as express consent). However, in some situations, the law allows us to collect, use
or disclose personal information without your consent.
You can withdraw your consent to the collection, use or disclosure of your information at any
time. However, in some cases withdrawing consent will mean that we can no longer provide you
with certain services or perform certain tasks where the information is required to do so.
You may withdraw your consent to the collection, use or disclosure of your or your child’s
personal information at any time by contacting us using the information outlined below and,
subject to any legal constraints, we will comply with your request.
Patient Consent: Clever Consult relies on the healthcare practitioners to obtain consent
for the collection and use of patient's personal information, including PHI, to be used by
Clever Consult for the provision of its Services. If a healthcare practitioner does not have a
patient's consent for their personal information to be used in this manner, the healthcare
practitioner must not use the Services in relation to that patient.
Security
We take reasonable steps to ensure your personal information is protected from misuse and
loss and from unauthorized access, modification, or disclosure.
Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
Accordingly, any personal information or other information which you transmit to us online is
transmitted at your own risk. We endeavour to take all reasonable steps to protect the personal
information you may transmit to us or from our online products and services. Once we do
receive your transmission, we will also make our best efforts to ensure its security on our
systems.
Retention
We retain personal information for as long as required to provide the services for which it was
collected, otherwise, in accordance with applicable legal and regulatory requirements.
Healthcare practitioners using Clever Consult are required to comply with different statutory and regulatory requirements and store personal health information for a minimum length of time. This includes any Summarized Notes they elect to save within their own electronic medical record system. We encourage patients to speak with healthcare practitioners directly on how long they are required to store your personal information.
Transfers of personal information
We may transfer personal information that we collect or that you provide as described in this
Privacy Policy to contractors, service providers, and other third parties we use to support our
business (such as our AI Service Providers) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them,
and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country and
out of your province, with different privacy laws that may or may not be as comprehensive as
Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory
agencies of that country may be able to obtain access to your personal information through the
laws of the foreign country. Whenever we engage a service provider, we require that its privacy
and security standards adhere to this policy and applicable Canadian privacy legislation.
For more information on our service providers or where we store personal information, contact
us using the information outlined below.
Direct marketing communications
We may send you direct marketing communications and information about our services that we
consider may be of interest to you. These communications may be sent in various forms,
including mail, SMS, fax, and email, in accordance with applicable marketing laws, such as
Canada’s Anti-Spam Legislation (CASL). If you indicate a preference for a method of
communication, we will endeavour to use that method whenever practical to do so. In addition,
at any time you may opt-out of receiving marketing communications from us by contacting us
(see ‘Contacting Information’ below) or by using the unsubscribe mechanisms provided in our
marketing communications.
We do not provide your personal information to other organizations for the purposes of direct
marketing.
Automatic Data Collection Technologies
We may also use these technologies to collect information about your online activities over time
and across third-party websites or other online services (behavioral tracking). To learn more or
to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool
for information on how you can opt out of behavioral tracking on this website and how we
respond to web browser signals and other mechanisms that enable consumers to exercise
choice about behavioral tracking.
The information we collect automatically [is statistical data and does not include personal
information] [is statistical information and may include personal information] [is statistical
information that includes personal information], and we [may] maintain it or associate it with
personal information we collect in other ways[, that you provide to us,] or receive from third parties. It helps us to improve our website and to deliver a better and more personalized
service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our website
according to your individual interests.
Speed up your searches.
Recognize you when you return to our website.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your
computer. You may refuse to accept browser cookies by activating the appropriate
setting on your browser. However, if you select this setting you may be unable to access
certain parts of our website. Unless you have adjusted your browser setting so that it will
refuse cookies, our system will issue cookies when you direct your browser to our
website.
Flash Cookies. Certain features of our website may use local stored objects (or Flash
cookies) to collect and store information about your preferences and navigation to, from,
and on our website. Flash cookies are not managed by the same browser settings that
are used for browser cookies. For information about managing your privacy and security
settings for Flash cookies, visit the Flash player settings page on Adobe’s website.
Web Beacons. Pages of our website [and our e-mails] may contain small electronic files
known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)
that permit Exposoft, for example, to count users who have visited those pages or
[opened an email] and for other related statistics (for example, recording the popularity of
certain content and verifying system and server integrity).
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using [an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they are used. If you have
any questions about an advertisement or other targeted content, you should contact the
responsible provider directly.
How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by
contacting us using the information outlined below. Where we hold information that you are
entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). Before providing access to any information, we will first verify your identity, and you consent to our collection and use of your personal information for verification purposes.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete, or inaccurate, then you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it, together with your requested amendment.
If we correct your personal information, we will, so far as is reasonably practicable, inform every
other person to whom we have disclosed that information of the correction.
If you are a patient, please contact your healthcare professional directly to discuss your data subject rights and requirements.
Contacting us
Accountability with respect to your personal information is important to Clever Consult. If you
have any questions, requests, complaints or concerns about this Privacy Policy, please contact
us at:
Email: privacy@cleverconsult.ai
If after contacting us you are still not satisfied, you have the right to file a complaint with your
local privacy authority.
Changes to this Privacy Policy
We may modify this Privacy Policy from time to time and will post the most current version
online.
