Privacy Policy

Thanks for entrusting TeleVU Innovations Ltd. (“TeleVU”, “we”, “us”) with your personal health information and personal information through the use of our iSee & uSee Platform (“TeleVU”, “Service”). Holding on to your private information is a serious responsibility, and we want you to know how we’re handling it.

The Short Version

We use your PHI and personal information as this Privacy Statement describes. No matter where you are or where you live, we provide the same high standard of privacy protection to all our users worldwide.

 

Of course, the short version and the Summary below don’t tell you everything, so please read on for more details.

 

Summary

 Section What can you find there?
What information

TeleVU collects

 TeleVU collects information directly from you for your registration and user profile. We also automatically collect your usage information, cookies, and device information, subject, where necessary, to your consent. We only collect the minimum amount of personal information necessary from you unless you choose to provide more. If you choose to record a call, or take an offline photo or video using our Service, we also store that information which may or may not contain personal or health information.
How TeleVU uses your information In this section, we describe how we use your information, including providing you with the Service, communicate with you, for security and compliance purposes, and improve our Services. We also describe the legal basis upon which we process your information where legally required
How we share the information we collect We may share your information with third parties under one of the following circumstances: with your consent, with our service providers, for security purposes, to comply with our legal obligations, or when there is a change of control or sale of corporate entities or business units. We do not sell your personal information, and we do not host advertising on our services.
 

How can you access and control the information we control

  

We provide ways for you to access, alter, or delete your personal information.
 

Our use of cookies and tracking

 We only use strictly necessary cookies to provide, secure and improve our Service. We offer a page that makes this very transparent. Please see this section for more information
 

How TeleVU secures your information

 We take all measures reasonably necessary to protect the confidentiality, integrity, and availability of your personal information on TeleVU and protect our servers’ resilience.
 

How we communicate with you

  

We communicate with you via email. You can contact us to change the email address we have on file.
Resolving complaints In the unlikely event that we are unable to resolve a privacy concern quickly and thoroughly, we provide a path of dispute resolution.
Changes to our

Privacy Statement

 We notify you of material changes to this Privacy Statement

30 days before any such changes become effective via your preferred communication method.
Contacting TeleVU Please feel free to contact us if you have questions about our

Privacy Statement.

 

What information TeleVU collects

“User Personal Information” (“PI”) is any information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, email address, a real name, an Internet protocol (IP) address are examples of “PI”.

“User Personal Health Information” (“PHI”) is any health information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as diagnoses, personal or family medical histories, and health care numbers are examples of “User PHI”.

PI and PHI do not include aggregated, anonymized, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, anonymized, non-personally- identifying information for research purposes, product development, operation, analysis, improvement, and optimize our Service.

 

Information users provide directly to TeleVU

Registration information

We require some basic information at the time of account creation. When you create your username and password, we ask you for a valid email address.

Recording Calls

As part of a call, any of the RemoteVU users (iSee platform) or the GlassVU users (uSee platform) can initiate a call recording. This recording is securely stored on our servers.

Offline Captured Photos and Video

Users of our uSee application may choose to operate it offline, where they can take photos or record videos without being part of a call. This content is securely stored on our servers.

 

Information TeleVU automatically collects via iSee and uSee

Usage information

If you’re accessing our Service or Website, we automatically collect the same basic information that most services collect, subject, where necessary, to your consent. This

 

includes information about how you use the Service, such as the pages you view, the referring site, your IP address and session information, and the date and time of each request. This is the information we collect from every visitor to the Website, whether they have an Account or not. This information may include PI.

Cookies

As further described below, we automatically collect information from cookies (such as cookie ID and settings) to keep you logged in, to remember your preferences, to identify you and your device and analyze your use of our Service.

Device information

We may collect certain information about your devices, such as their IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer. This information may include PI.

If you would like to request deletion of data we process based on consent or object to our personal information processing, please email us at Privacy@TeleVU.ca

 

How TeleVU uses your information

  • We may use your information for the following purposes:
  • We use your Registration Information to create your account and to provide you with the Service.
  • We use your Personal Information, specifically your email, to identify you on iSee.
  • We use your Profile Information to fill out your Account profile and to share that profile with other users if you ask us to.
  • We use your email address to communicate with you if you’ve said that’s okay,
  • and only for the reasons you’ve said it’s okay. Please see our section on email communication for more information.
  • We use Personal Information to respond to support requests.
  • We may use Personal Information to invite you to participate in surveys, beta programs, or other research projects, subject, where necessary, to your consent.
  • We use Usage Information and Device Information to better understand how our
  • Users use iSee and uSee and improve our Website and Service.
  • We may use your Personal Information if it is necessary for security purposes or to investigate possible fraud or attempts to harm TeleVU or our Users.
  • We may use your Personal Information to comply with our legal obligations,
  • protect our intellectual property, and enforce our Terms of Service.
  • We limit our use of the user’s Personal Information and PHI to the purposes listed in this Privacy Statement. If we need to use your Personal Information or User PHI for
  • other purposes, we will ask your permission first. You can always see what information we have, how we’re using it, and what permissions you have given us in your user profile.

PI and User PHI do not include aggregated, anonymized, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, anonymized, non-personally identifying information for research purposes, product development, operation, analysis, improvement, and optimize our Service.

 

Our role in processing your information

Privacy law distinguishes between the organization that decides why and how personal information is processed (the “controller”, or under HIPAA the “covered entity”, or under PHIPA the “health information custodian”) and the organization that processes it on that organization’s behalf (the “processor”, or under HIPAA the “business associate”). TeleVU acts in both roles, depending on the information concerned.

 

Where TeleVU acts as a processor

Most information held in iSee and uSee is entered by, or generated on behalf of, the healthcare organization, employer or other customer that has licensed the Service (“Customer”). Call recordings, offline photos and videos, clinical notes and any PHI they contain are Customer content. For that content the Customer is the controller, and TeleVU processes it only on the Customer’s documented instructions, under a written agreement that sets out the subject matter, duration, nature and purpose of the processing, the types of personal information involved and the categories of data subject.

 

If you are a patient, clinician or field user whose information was entered into the Service by such an organization, please direct requests about that information to that organization in the first instance. Where we receive a request directly, we will forward it to the relevant Customer without undue delay and assist them in responding.

 

Where TeleVU acts as a controller

TeleVU is the controller for the limited information we collect for our own purposes: account registration and credentials, support correspondence, website and Service usage information, cookie and device information, and marketing communications where you have chosen to receive them. This Privacy Statement describes that processing in full.

 

Data Processing Agreement and Business Associate Agreement

TeleVU makes a standard Data Processing Agreement (DPA) available to all Customers. The DPA incorporates the terms required by Article 28 of the GDPR and, where relevant, the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum. Customers who are HIPAA covered entities may also execute TeleVU’s standard Business Associate Agreement (BAA). Both documents are published in our Site Policy repository at [televu.ca/legal – URL to be confirmed] and may be requested at any time by emailing privacy@televu.ca.

 

Our legal basis for processing information

Processing Personal Information and PHI is subject to certain local and international laws (including, but not limited to, the European Union’s General Data Protection Regulation (GDPR), PHIPA, and others). TeleVU is required to notify you about the legal basis on which we process Personal Information. TeleVU processes the user’s Personal Information and PHI on the following legal basis:

 

Contract Performance:

When you create a TeleVU Account, you provide your Registration Information.

We require this information for you to enter into the Terms of Service agreement with us, and we process that information based on performing that contract. We

also process your email address on other legal bases, as described below.

 

Consent:

We rely on your consent to use your Personal Information and PHI under the following circumstances: when you fill out the information in your user profile; when you decide to participate in a research project, beta program, or survey; and for marketing purposes, where applicable. All of this PI is entirely optional, and you have the ability to access, modify, and delete it at any time.

 

Legitimate Interests:

Generally, the remainder of the user’s Personal Information and PHI processing is necessary for our legitimate interest. For example, for legal compliance purposes, security purposes, or maintaining ongoing confidentiality, integrity, availability, and resilience of TeleVU’s systems, Website, and Service.

 

How we share the information we collect

We may share your Personal Information with third parties under one of the following circumstances:

 

With service providers

We share users’ Personal Information with a limited number of service providers who process it on our behalf to provide or improve our Service. These service providers have agreed to privacy restrictions similar to those in our Privacy Statement by signing data protection agreements or making similar commitments. Our service providers perform customer support ticketing, network data transmission, security, and other similar services. While TeleVU processes all Personal Information in Canada, our service providers may process data outside of Canada. For example, we use Amazon Web Services for computing and storage purposes located in Canada. Managed services such as authentication may, however, be located in the United States.

 

For security purposes

TeleVU may share your email, Usage Information, and Device Information associated with that portal with an owner and/or administrator of the portal. We only do this to the extent that such information is provided only to investigate or respond to a security incident that affects or compromises that particular organization’s security.

 

For legal disclosure

TeleVU strives for transparency in complying with legal processes and legal obligations. Unless prevented from doing so by law or court order or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. TeleVU may disclose the user’s PHI, Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, or similar government order. Or when we believe in good faith that disclosure is necessary to comply with our legal obligations, and protect our property or rights, or those of third parties or the public.

 

Change in control or sale

We may share users’ Personal Information if involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of PI. We will notify you on our Website or by email before any transfer of your Personal Information. Of course, the organization receiving any Personal Information will have to honour any promises we made in our Privacy Statement or Terms of Service.

 

Aggregate, non-personally-identifying information

We share certain aggregated, non-personally identifying information with others about how our users, collectively, use TeleVU. We may use this information to improve our products and services.

 

We do not sell your PI nor your PHI for monetary or other consideration.

 

International data transfers

Where your information is processed

TeleVU stores and processes personal information and PHI in Canada. Our primary computing and storage infrastructure is hosted on Amazon Web Services in the AWS Canada (Central) region. A limited number of managed services used to operate the Service, such as authentication, may process data in the United States.

 

Transfers from the European Economic Area, the United Kingdom and Switzerland

The European Commission has decided that Canada provides an adequate level of protection for personal data transferred to recipients subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) (Commission Decision 2002/2/EC of 20 December 2001). TeleVU is subject to PIPEDA. Transfers of personal data from the EEA to TeleVU in Canada therefore take place on the basis of that adequacy decision. The United Kingdom and Switzerland recognise Canada as providing adequate protection on equivalent terms.

 

Onward transfers to other countries

Where a sub-processor processes personal information in a country that is not covered by an adequacy decision, we put in place an appropriate transfer mechanism before the transfer takes place. Depending on the recipient, this is:

 

  • the European Commission’s Standard Contractual Clauses (Implementing Decision (EU) 2021/914), supplemented by the UK International Data Transfer Addendum where United Kingdom data is involved; or
  • the recipient’s certification under the EU-US Data Privacy Framework and its UK Extension, where the recipient is certified for the relevant category of data.

 

In each case we carry out a transfer impact assessment and apply supplementary measures, including encryption of data in transit and at rest, access controls and contractual restrictions on government access requests.

 

Finding out more

You may request a current list of our sub-processors, the countries in which they process data, and a copy of the safeguards we rely on for any transfer, by emailing privacy@televu.ca.

 

How you can access and control the information

If you’re already a TeleVU user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting TeleVU Support. In addition, you can control the information we collect about you by limiting what information is in your profile, keeping your information current, or contacting TeleVU Support.

 

Data portability

As a TeleVU User, you can always take your data with you. You can contact TeleVU

support to extract all the data we have for your user.

 

Data retention and deletion of data

Generally, TeleVU retains users’ Personal Information and PHI for as long as your account is active or as needed to provide you services or as defined by the data retention policies of your organization.

If you would like to cancel your account or delete your Personal Information and PHI, you must contact your organization’s contact person who administers your portal.

We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where you ask us to delete your information, we will confirm receipt and respond to your request within one month, as described under “Your rights over your personal information” above. We will then complete the deletion of your profile, and of any data we process on the basis of your consent, as quickly as we reasonably can. Where a longer period is needed, for example because the information persists in encrypted backups or archives that are cycled on a fixed schedule, completion may take up to 90 days, and we will tell you why and when it will be done. Information that we are required by law to retain is kept for as long as the law requires and is deleted once that period ends. If you reside outside of Canada, you may have the right to file a complaint with your local supervisory authority.

After an account is deleted, we will delete or de-identify your Personal Information and User PHI from our servers.

 

Your rights over your personal information

If you are in the European Economic Area, the United Kingdom or Switzerland, data protection law gives you the rights set out below. Wherever we are able to do so, TeleVU extends these rights to all of our users, regardless of where they live. Residents of Canada, of US states with comprehensive privacy laws, and of other jurisdictions may have comparable or additional rights under their local law.

  • Right of access. You can ask us to confirm whether we are processing information about you and, if so, to give you a copy of it, together with the purposes of the processing, the categories of information involved, who we share it with, how long we keep it and where we obtained it (GDPR Article 15).
  • Right to rectification. You can ask us to correct information about you that is inaccurate, and to complete information that is incomplete (Article 16).
  • Right to erasure. You can ask us to delete information about you where it is no longer needed for the purpose we collected it, where you withdraw the consent we relied on, where you object and we have no overriding legitimate grounds, or where it has been processed unlawfully (Article 17).
  • Right to restriction of processing. You can ask us to pause our use of your information while we check its accuracy, consider an objection you have raised, or where you need it preserved for a legal claim (Article 18).
  • Right to data portability. Where we process your information by automated means on the basis of your consent or of a contract with you, you can ask us for a copy in a structured, commonly used, machine-readable format, and to transmit it to another organization where technically feasible (Article 20).
  • Right to object. You can object at any time to processing we carry out on the basis of our legitimate interests, and we will stop unless we can demonstrate compelling legitimate grounds that override your interests, or we need the information for legal claims. You can object to direct marketing at any time and we will stop without exception (Article 21).
  • Right to withdraw consent. Where we rely on your consent, you can withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it (Article 7(3)).
  • Rights relating to automated decision-making. You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you. TeleVU does not make decisions of this kind about users of the Service (Article 22).
  • Right to complain and to a remedy. You can lodge a complaint with a data protection supervisory authority and you have the right to an effective judicial remedy (Articles 77 to 79).

 

How to exercise your rights

Email privacy@televu.ca with the subject line “Data Subject Request”, telling us which right you wish to exercise. You can also write to our Data Protection Officer at the address given under “Resolving complaints” below.

We do not charge a fee for handling a request, unless it is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or refuse to act, and we will explain why. Where we have reasonable doubts about who is making a request, we will ask for information sufficient to confirm your identity before we act, and we will use that information for no other purpose.

We respond to requests without undue delay and within one month of receiving them. Where a request is complex, or where you have made a number of requests, we may extend that period by up to two further months; if we do, we will tell you within one month of receiving your request and explain why. If we decide not to act on your request, we will tell you why within one month and explain how to complain to a supervisory authority and seek a judicial remedy.

 

Requests about information held on behalf of an organization

Where the information you are asking about was entered into the Service by a healthcare organization, employer or other Customer, that organization is the controller and is responsible for answering your request. Please contact them directly. If you contact us instead, we will pass your request on to them without undue delay, tell you that we have done so, and support them in responding as our agreement with them requires.

 

Complaining to a supervisory authority

If you are in the EEA, you may complain to the data protection authority of the country where you live or work or where the issue arose; a list is published by the European Data Protection Board at edpb.europa.eu. If you are in the United Kingdom, you may complain to the Information Commissioner’s Office at ico.org.uk. If you are in Canada, you may complain to the Office of the Privacy Commissioner of Canada or to your provincial privacy commissioner. We would ask you to raise the matter with us first so that we have the chance to put it right, but you are not required to do so.

 

Children’s personal data

TeleVU does not offer any product, feature or service that is directed to children. iSee and uSee are general-purpose communication and collaboration tools, licensed to organizations. We have no paediatric-specific functionality, we do not market to children, we do not profile children, and we do not use any child’s information for any purpose of our own.

 

Enrolment is decided by our Customers

Our Customers decide who is given access to the Service, who is enrolled, what is captured and in what settings the Service is used. TeleVU does not make those decisions and does not independently verify the age of the individuals a Customer chooses to enrol. A Customer may therefore enrol, or capture personal or health information about, a person who is under the age of majority, and TeleVU may hold that information as a result.

 

Who is responsible for a child’s information

Where a Customer enrols a person under the age of majority, or captures personal or health information about such a person, that information is Customer content. TeleVU processes it solely as a processor, on the Customer’s documented instructions, and never for any purpose of our own. The Customer is the controller of that information and is responsible for:

  • determining whether the Service may lawfully be used in that setting;
  • establishing a lawful basis for the processing, including any additional condition required for health or other special-category data;
  • obtaining any consent or authorization required from a parent or legal guardian, and assessing the capacity of the individual to consent for themselves where local law allows it;
  • carrying out any data protection impact assessment or equivalent risk assessment required; and
  • setting the retention and deletion rules that apply to the information.

 

Requests concerning a child’s information should be directed to the Customer that enrolled them. Where we receive such a request directly, we will forward it to that Customer without undue delay, tell you that we have done so, and assist them in responding as our agreement with them requires.

 

Limits we apply regardless of instructions

Whatever a Customer instructs, TeleVU will not use a child’s information for marketing, profiling, product development or any other purpose of its own. If, in our view, an instruction a Customer has given us would infringe applicable data protection law, we will tell them so.

 

If a child has given us information

If you believe that a child has provided personal information to TeleVU directly, or that we hold information about a child without the consent of a parent or legal guardian where that consent is required, please email privacy@televu.ca. We will investigate, refer the matter to the relevant Customer where the information is Customer content, and where we confirm that we have collected information without an appropriate lawful basis, delete it promptly.

 

Our use of cookies and tracking Cookies

TeleVU only uses strictly necessary cookies. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors.

We use cookies solely to provide, secure, and improve our Service. For example, we use them to keep you logged in, remember your preferences, identify your device for security purposes, analyze your use of our Service, compile statistical reports, and provide information for the future development of TeleVU.

By using our Service, you agree that we can place these cookies on your computer or device. If you disable your browser or device’s ability to accept these cookies, you will not be able to log in or use our Service.

 

How TeleVU secures your information

TeleVU takes all reasonably necessary measures to protect users’ Personal Information and PHI from unauthorized access, alteration, or destruction.

Also, to maintain data accuracy and help ensure the appropriate use of users’ Personal Information and PHI.

The Chief Technology Officer is ultimately accountable for compliance with privacy policies at TeleVU.

TeleVU enforces a written security information program. Our program:

  1. aligns with industry recognized frameworks;
  2. includes security safeguards reasonably designed to protect the confidentiality, integrity, availability, and resilience of our Users’ data;
  3. is appropriate to the nature, size, and complexity of TeleVU’s business operations;
  4. includes incident response and data breach notification processes; and
  5. complies with applicable information security-related laws and regulations in the geographic regions where TeleVU does business.

If a data breach affects your Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.

Transmission of data on TeleVU is encrypted using SSH, HTTPS (TLS), WebSocket, WebRTC and all data is encrypted at rest. No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

 

How we communicate with you

We use your email address to communicate with you if you’ve said that’s okay, and only for the reasons you’ve said it’s okay. For example, if you contact our Support team with a request, we respond to you via email.

Depending on your email settings, TeleVU may occasionally send notifications about new features, requests for feedback, significant policy changes, or offer customer support. We also send marketing emails based on your choices and in accordance with applicable laws and regulations. An “unsubscribe” link is located at the bottom of each marketing email we send you. Please note that you cannot opt-out of receiving essential communications from us, such as emails from our Support team or system emails. Still, you can configure your notifications settings in your profile to opt out of other communications.

 

Our emails may contain a pixel tag, a small, clear image that can tell us whether or not you have opened an email and your IP address. We use this pixel tag to make our email more effective for you and ensure we’re not sending you unwanted emails.

 

Resolving complaints

If you have concerns about how TeleVU handles your Personal Information, please let us know immediately. We want to help. You may email us directly at privacy@televu.ca with the subject line “Privacy Concerns.” We will respond promptly — within 30 days at the latest. If you request access to your data, we will provide you with access within 30 days of your request. If your request requires us to conduct a lengthy search, we may request an extension for another 30 days.

You may also contact our Data Protection Officer directly.

TeleVU Data Protection Officer

9131 Keele Street, Suite A4

Vaughan, ON, L5K 0G7, Canada privacy@televu.ca

 

Dispute resolution process

In the unlikely event that a dispute arises between you and TeleVU regarding our handling of your PI or User PHI, we will do our best to resolve it. If you are a Canadian resident, you may contact the Office of the Privacy Commissioner of Canada or your local, provincial Privacy Commissioner.

Changes to our Privacy Statement

Although most changes are likely to be minor, TeleVU may change our Privacy Statement from time to time. We will notify users of material changes to this Privacy Statement through our Website at least 30 days before the change takes effect by posting a notice on our home page or sending an email to the primary email address specified in your TeleVU account. For other changes to this Privacy Statement, we encourage Users to frequently check our Site Policy repository.

 

Contacting TeleVU

Questions regarding TeleVU’s Privacy Statement or information practices should be directed to privacy@televu.ca.