Hoom Corporation Privacy Policy

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Introduction

Marathon Naturel Inc. (“Hoom”, “we”, “us”) offers Naturopathy Services. When you register with Hoom as a User, you become eligible to use our Naturopathy Services. You also become eligible to sign up separately for one or more of our Services, should you wish to.

Please read this Privacy Policy carefully. It describes how Hoom will collect, use, store, disclose and protect your information in relation to our Naturopathy Services.


Definitions

The following provides the meaning of certain terms used in this Policy. If not defined below, the capitalized words and phrases in this Policy have the same meaning as in Hoom’s Terms of Use.

“Hoom Platform” means, collectively, the hardware, software, applications, websites, Content, products and services owned and/or operated by us to enable the provision of remote Naturopathy Services to Users, among other purposes.

“Information” means, collectively, “Personal Information” (information about an identifiable User as further defined in Applicable Law) and “Personal Health Information” or “PHI” (information about an identifiable User’s health or Naturopathy as further defined in Applicable Law).

A “User” is an individual registered to use the Hoom Platform, including, unless otherwise specified, as part of a customized program provided by a third party. A “PCH User” is a User also registered to use Loblaw’s PC Health application. Unless we make a distinction, “Users” means all Users.

Naturopath (“Authorized Providers”) are registered to use the Hoom Platform to provide “Naturopathy Services” within their scope of practice to Users. An Authorized Provider provides Naturopathy Services through a “Consultation”
“Applicable Law,” in relation to Hoom, Authorized Providers, or Users, means the laws and regulations, including privacy laws and regulations, to which each is subject.

“Content” means general information about health-related topics posted on the Hoom Platform, access to which is not the delivery of Naturopathy Services and does not replace and cannot be relied upon as Naturopathy Services.

Your Agreement with Hoom

If you are a User, the arrangement between you and Hoom – your rights and obligations and those of Hoom – is set out in the Terms of Use and, where applicable, supplementary Terms. The Terms of Use for PCH Users may differ from those for other Users to take into account supplementary Terms for use of the PC Health application.

Application of this Policy

This Policy describes Hoom’s management of Information, including the purposes for which we collect, use and disclose Information and the safeguards we use to protect Information.
The Hoom Platform and How Hoom Collects and Uses Information
The following is an overview of how the Hoom Platform generally functions and how Hoom collects and uses Information. The details of how the Hoom Platform functions may vary by Consultation and Authorized Provider.

Naturopathy Services

Authorized Providers collect Information about you that you provide before or during a Consultation. They may collect this Information in different ways, including through discussions with you during the Consultation, via text messages with you before the Consultation, or when you enter or upload Information to the Hoom Platform before the Consultation. Authorized Providers also have access to other Information about you through the Hoom Platform. This includes Information that you provide in your consultation request; Information you’ve entered or uploaded to profiles; Information created during your earlier interactions through the Hoom Platform with other Authorized Providers; the name, email address, phone number, gender identity, date of birth and province/territory that you provided when you registered with Hoom; and your emergency contact’s name and contact information (if you have chosen to add an emergency contact to your account). Authorized Providers use this Information to provide you with Naturopathy Services. As noted above, they must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Providers may create Information in the Hoom Platform, such as prescriptions, sick notes and notes about your Consultation. They may export or print copies of your Information.
Authorized Providers may, but are not required to, email or text your emergency contact if they believe that you are presenting with a Naturopathy emergency. You are responsible for advising your emergency contact that you are providing their name and contact information to Hoom and Authorized Providers, and for obtaining any necessary consent from your emergency contact for the provision and use of that information in connection with the Hoom Platform.

Other Services

Hoom provides services that support the provision of Naturopathy Services. These services may include receiving, reviewing, and scanning or otherwise uploading laboratory test results to the Hoom Platform; faxing prescriptions to pharmacies; obtaining referrals for consultations with specialists; and collecting Information required for scheduled appointments (such as health card numbers or information from referral letters). Hoom provides some of these services to Authorized Providers (for example, the receipt and preliminary review of laboratory results) and some to Users (for example, faxing prescriptions and arranging referral to specialists). These services require the use of Information.
Hoom may also provide services through the Hoom Platform that are Naturopathy-related but not Naturopathy Services (such as navigational services to assist you to access Naturopathy Services on the Hoom Platform). Unless otherwise advised, Hoom Personnel will deliver these services. Hoom Personnel receive privacy and security training and commit to complying with Hoom’s obligations in connection with Information, as described below in the section on Safeguarding Information.

Other Collections and Uses of Information

Hoom uses Information to the extent necessary to develop, evaluate, improve, provide, and support the Hoom Platform and its various services. We may also use Information for loss prevention, to prevent fraud, and to comply with legal requirements. We do not collect or use Information if non-identifying information will suffice. We do not record the audio or video portions of Consultations.
For more information about how Hoom collects and Uses Information when you create your Hoom account, use our Naturopathy Services, please see the section of this policy entitled ** .

Third party service providers

Hoom uses third-party software and service providers for a variety of services, such technical, operational, and marketing services. For example, our scheduling functionality is provided through a third party service provider. We require our third party service providers to limit their use of Information to what is necessary for their services. We also require them to have security measures in place that are appropriate for the protection of Information. Some of our service providers operate from outside of Canada, which means that Information they use to provide their services to us will be subject to the laws of other jurisdictions and may be available to foreign government authorities under lawful orders and laws applicable in those jurisdictions.
For additional details about Hoom's third party service providers, please contact jose@naturesante.ca

Hoom’s disclosure of Information

Emergency contacts. We may disclose Information to emergency contacts as described above.

Third parties, on consent. We may disclose Information to third parties with User consent.

Compliance, Fraud Prevention. We disclose Information to the extent required to comply with Applicable Law, including to respond to a subpoena, order, or similar obligation to produce information; and to establish or exercise Hoom’s legal rights, including to defend against legal claims and to detect, investigate, suppress, prevent or take action regarding illegal or prohibited activities, such as suspected fraud and threats to the reputation or safety of any person.

Business transactions. We may disclose Information for the purposes of conducting required due diligence or the completion of a business transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including agreements and notice requirements that apply to the disclosure of Information for such transactions.

Hoom’s retention/deletion of Information

Unless we notify you otherwise, we will retain your Information on the Hoom Platform until you (or Hoom) close your Account. On termination, for a limited time, you will be able to print or copy your Information held in the Hoom Platform, except for any private notes of Authorized Providers. Any request for access to an Authorized Provider’s notes should be made directly to the Authorized Provider outside of the Hoom Platform. If you are having trouble finding the provider you consulted with, our Customer Support team may be able to help. Please contact us directly at jose@naturesante.ca .

After the time period during which you may print or copy your Information has ended, we will securely delete the Information associated with your Account, except for any Information that Hoom is required to retain under Applicable Law or Information required by an Authorized Provider in connection with Naturopathy Services. Hoom will delete the latter once the Authorized Provider makes a copy of the Information or terminates their account with Hoom. When Information is deleted, it is removed from our active database. Any Information that remains in our backup is securely stored and isolated from any further processing until deletion is possible.

Accessing and correcting Information

You can access your Information or that of your Registered Dependents by logging in to your Account at https://naturesante.ca/account/login.
You may update or otherwise correct your Information at any time, except Information that an Authorized Provider has viewed or created. Any request to update or correct Information that an Authorized Provider has viewed or created should be made directly to the Authorized Provider outside of the Hoom Platform.

Privacy Settings

The Hoom Platform enables you to make choices to enhance the protection of your privacy. For example:

  • When requesting a Consultation, you may choose to withhold Information, for example Information contained in your Naturopathy records, from the Authorized Provider. Please be aware that Authorized Providers may be unable to provide you with Naturopathy Services as a result. They will advise you of the implications of your choice.
  • You may choose whether to receive communications from Hoom by email or SMS.
  • You can check your login history when you access the Hoom Platform.

Please contact us directly at jose@naturesante.ca if you require assistance with these options or more generally have questions about how to use the Hoom Platform. To protect your privacy, we may request information to verify your identity when you contact us.

Safeguarding Information

We permit Hoom personnel (“Personnel,” which includes our employees, contractors and subcontractors) to access Information only to the extent necessary to perform their designated functions. We require Personnel to complete privacy and security training and to commit to protecting Information by complying with our policies, procedures and Applicable Law.

We store your information in electronic format within Canada, using computer systems with restricted access and that are housed in facilities using physical security measures.

More generally, we have in place appropriate physical, technological, and organizational safeguards, including access controls, to protect Information against loss, theft, and unauthorized access, use and disclosure. Notwithstanding the safeguards we employ and our commitment to protecting Information, we cannot guarantee the security or error-free transmission or storage of Information. There are risks inherent in the use of electronic means to transmit and hold information in electronic format. These risks can be minimized but not eliminated by the use of appropriate security measures, such as the measures Hoom employs. These risks include interception, loss, corruption, unauthorized access to, use and disclosure of Information, and delay in the availability of Information.

You play an important role in protecting and the privacy of your Information. We ask you to do the following.

  • Create a strong and unique password for your Account using Hoom’s password strength estimator and update your password periodically.
  • Do not share your Account or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please do not provide it and contact us if you receive such a request.
  • Log out of your Account as soon as you finish using it, especially if you share the device you use to access the Hoom Platform with anyone else.
  • Password-protect your device with a strong and unique password.
  • Choose a quiet, private location from which to receive Naturopathy Services.


Hoom’s collection and use of non-identifiable Data

  • Hoom obtains the authorization of Authorized Providers to collect and use non-identifiable data about their use of the Hoom Platform (“Data”). This may include, for example, non-identifiable information about the number of consults carried out by Authorized Providers on the Hoom Platform or the symptoms most commonly treated by Authorized Providers using the Hoom Platform. Hoom may use Data to monitor the compliance of Users and Authorized Providers with the Hoom Platform terms of use, to make the use of the Hoom Platform more accessible and enhance the Hoom Platform experience for Users and Authorized Providers, and to design optional surveys for Users. We may also use or disclose Data for internal product development purposes or for duly approved research projects. We will not use Data to re-identify Users or for any other purpose prohibited by Applicable Law.


Amendments to this Policy

Hoom last updated this Privacy Policy (“Policy”) on July 16th, 2024. We post the current version of the Policy at www.naturesante.ca/privacy. We reserve the right to amend the Policy at any time to account for changes in Applicable Law, our practices and the Hoom Platform. Please check to see if we have amended the Policy since you last used the Hoom Platform to ensure you are aware of (and agree to) our current privacy practices.

Contact Us

If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance Officer. Please include your name and contact information if you would like us to respond to you.

Marathon Naturel Inc.
ATTN: Jose M. Azares — Chief of Staff
jose@naturesante.ca
(416) 779- 0607
5006 Queen Mary Street
Montreal, Quebec
H3W 1X2