Last Updated: Jan 10, 2022.
Effective Date: Jan 10, 2022.
Virtual Hallway Consults Inc. (“Virtual Hallway”, “Us”,
“We”, or “Our”) operates the www.virtualhallway.ca Website (the “Website”), in which users may sign up for or subscribe to Our
proprietary software as a service platform designed to virtually connect Primary Care Providers and
users of the Platform (“You” or “Your”) of Our policies regarding the collection,
use, and disclosure of personally identifiable information and personal health information when You use the
Platform and the choices You have associated with the data You submitted to Us. We use Your data to provide
and improve the Platform.
Unless otherwise stated herein, defined terms in this Policy have the same meaning
as set forth in Our End User License Agreement (“EULA”).
By using the Platform, You agree to the collection and use of information under this
- Policy Scope
- This Policy describes:
- How We collect, use, disclose, and protect any personally
identifiable information and personal health information submitted by You through the Platform.
- Describes the types of information We may collect from You
or that You may provide when You visit the Platform.
- Our practices for collecting, using, maintaining,
protecting, and disclosing that information.
- This Policy applies to information We collect, use, or disclose
- On the Platform.
- In email, text, and other electronic messages between You
and Virtual Hallway in relation to the Platform.
- This Policy DOES NOT include any policies regarding Our
collection, use, and disclosure of personal information or any information through Your
interaction with non-Platform part of the Website, which is governed by Our General Privacy
Policy, available at (www.virtualhallway.ca/privacy-policy). Your communication with Us regarding the non-Platform part of the Website is also covered
Policy, this Policy must prevail.
- This policy DOES NOT apply to information that You provide to or is
collected by any third party, through any application or content (including advertising) that may link
to or be accessible from or on the Platform.
- We will only use Your personal information in accordance with this
Policy unless otherwise required by applicable law. We take steps to ensure that the personal
information that We collect from You is adequate, relevant, not excessive, and used for limited
purposes. Privacy laws in Canada generally define “personal information” as any information
about an identifiable individual, which includes information that can be used on its own or with other
information to identify, contact, or locate a single person. For this Policy, personal information also includes “personal health information”/"health information", which has the same meaning under the Nova Scotia Personal Health Information Act (PHIA), the Ontario Personal Health Information Protection Act (PHIPA) and the Alberta Health Information Act (HIA) as amended from time to time., as amended from time
- Please read this policy carefully to understand Our policies and
practices for collecting, processing, and storing Your information. If You do not agree with Our
policies and practices, Your choice is not to use Our Platform. By accessing or
using this Platform, You indicate that You understand, accept, and consent to the practices described in
make changes indicates that You accept and consent to those changes, so please check the policy
periodically for updates.
- Information Collection and Use
We collect several different types of information for various purposes to provide
and improve Our Platform to You.
Types of Information Collected
- Personal Data
- While using Our Platform, We may ask You to provide Us with
certain personally identifiable information. Personal Data may include but is not limited to:
- Data be used to contact or identify You, such as Email
address, First name and last name, Your device’s Internet Protocol address, phone number, and Your
address and postal code; and
- For identity verification and fraud prevention, We may ask
You to provide Us with Your government-issued identification, proof of insurance and liability coverage,
and other relevant information from time to time.
- We may collect additional Personal Data when You use the
Platform as You may supply Us with personally identifiable information and personal health information,
- Your Patient’s information, including their personal
health information, such as name, diagnosis, health card number, date of birth, MSI/Health Society
- Names of Primary Care Provider and Specialist; and
- Other relevant information such as start and end time of the
In any case, We will only collect and maintain Patient personal health
information that You provide to Us in relation to the services of the Platform.
- Business and Professional Practice Data
- We may also collect Business and Professional Practice Data
from You for Your registration for or subscription to the Platform and for verifying Your professional
- Data we collected includes Your business phone number,
province of practice, Your practitioner type, professional society membership number, and Your address
- We may also collect necessary billing information from Your
practice, such as Your business’ bank account information, name of financial institution, and Your
business address, so that We can act as Your agent in collecting the bill payments from MSI.
- If You subscribe to the Platform, We may also collect Your
credit card information for facilitate Your subscription fees to Us, including (Last 4 digits) of Your
credit card number, credit card type, billing address and postal code.
- Usage Data
We may also collect information relating to how You access and use the Platform
(“Usage Data”). This Usage Data may include information such as browser type, browser version,
the pages of Our Platform that You visit, the time and date of Your visit, the time spent on those pages,
unique device identifiers and other diagnostic data.
- Tracking & Cookies Data
Platform and hold certain information. Cookies are files with small amount of data which may include an
anonymous unique identifier. Cookies are sent to Your browser from a website and stored on Your device.
Tracking technologies also used are web beacons, tags, and scripts to collect and track information and to
improve and analyze the Platform. You can instruct Your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if You do not accept cookies, You may not be able to use some portions of Our
Platform. Examples of Cookies We use:
- Session Cookies. We use Session
Cookies to operate Our Platform.
- Preference Cookies. We use
Preference Cookies to remember Your preferences and various settings.
- Security Cookies. We use
Security Cookies for security purposes.
- How We Collect Information About You
We use different methods to collect Your information, including through:
- Direct interactions with You when You provide it to us, for
example, by filling in forms or corresponding with Us by phone, email, or otherwise.
- Automated technologies or interactions, as You navigate through the
Platform. Information collected automatically may include usage details, IP addresses, and information
collected through cookies, web beacons, and other tracking technologies.
- Third parties or publicly available sources, for example, Our
business or advertising partners.
- Information You Provide to Us
The information We collect directly from You on or through Our Platform may
- Information that You provide by filling in forms on Our
Platform, interacting with the Platform’s functionalities, using Our Platform to facilitate
consultation with a Specialist or a Primary Care Provider, uploading to the Platform, posting any
material, making payments to Our Platform services, or requesting further services. We may also ask You
for information when You enter a conference or promotion sponsored by us, and when You report a problem
to Us in relation to the Platform.
- Records and copies of Your correspondence (including email
addresses), if You contact Us.
- Use of Your Information
- Virtual Hallway uses the collected data for various purposes:
- To provide Our medical consultation management services on
the Platform and maintain the Platform;
- To notify You about changes to the Platform;
- To allow You to participate in interactive features of Our
Platform when You choose to do so;
- To provide customer care and support;
- To process payments and medical bills on behalf of Your
- To receive payments from you;
- To provide analysis or valuable information so that We can
improve the Platform;
- To monitor the usage of the Platform;
- To detect, prevent and address technical issues; and
- For any other purpose with Your consent.
We may also use Your information to contact You about Our own and third-parties'
goods and services that may be of interest to You, as permitted by law. If You do not want Us to use Your
information in this way, please e-mail Us at [email protected]. For more information, see Your Choices
We will only share personal health information to a third-party entity and any other
person in accordance with applicable privacy and security laws and with the terms and conditions of the
We may use the information We have collected from You to enable Us to display
advertisements to Our advertisers' target audiences. Even though We do not disclose Your personal
information for these purposes without Your consent, if You click on or otherwise interact with an
advertisement on the Website, the advertiser may collect information about You, in which We do not have
control. For example, the advertiser may identify You as their targeted audience.
- Data Processing and Transfer
Please note that We store and process Your personal information, including all
Personal Data, in Canada. If You are located outside Canada and choose to provide information to us, Your
consent to this Policy followed by Your submission of such information represents Your agreement to that
We may transfer personal information that We collect or that You provide as described
in this policy to contractors, Our Service Providers (defined hereafter), and other third parties We use to
support Our business (such as analytics and search engine providers that assist Us with Website improvement
and optimization) 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.
- Disclosure of Your Information
- Virtual Hallway may disclose aggregated information about Our users,
and information that does not identify any individual, without restriction.
- Virtual Hallway may disclose personally identifiable information
that We collect or You provide in the good faith belief that such action is necessary:
- To comply with Our legal obligations, including to respond
to any government or regulatory request, in accordance with applicable law;
- To provide services of this Platform in accordance with the
EULA, such as facilitating the consultation between the Primary Care Provider and the Specialist and
facilitating medical billing between You and Billing Agent;
- To fulfill the purpose for which You provide it;
- To enforce or apply Our terms and conditions and other
agreements, including for billing and collection purposes.
- In accordance with applicable law, to a buyer or other
successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other
sale or transfer of some or all of Virtual Hallway’s assets, whether as a going concern or as part
of bankruptcy, liquidation, or similar proceeding, in which personal information held by Virtual Hallway
is among the assets transferred;
- To protect and defend the rights or property of Virtual
- To prevent or investigate possible wrongdoing in connection
with Our services;
- To protect the personal safety of users of the Platform or
the public; and
- To protect against Our legal liability.
- Security of Data
- The security of your personal information is very important to us.
We use commercially acceptable means and industrial standard measures designed to secure your personal
information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store
all information you provide to us behind firewalls on secure servers hosted by our Service Provider. Any
payment transactions and personal information You provided on or through the Platform will be encrypted
using SSL technology.
- The safety and security of your information also depends on you.
Where we have given you (or where you have chosen) a password for access to certain parts of our
Platform, you are responsible for keeping this password confidential. We ask you not to share your
password with anyone.
- Unfortunately, the transmission of information via the Internet or
method of electronic storage is not completely secure. Although we do our best to protect your personal
information, we cannot guarantee the security of your personal information transmitted to our Website.
Any transmission of personal information is at your own risk. We are not responsible for circumvention
of any privacy settings or security measures contained on the Website.
- Retention of Data
- Except as otherwise permitted or required by applicable law or
regulation, We will only retain Your personal information and Patient personal health information for as
long as necessary to fulfill the purposes We collected it for, including for the purposes of satisfying
any legal, accounting, or reporting requirements. Under some circumstances We may anonymize Your
personal information so that it can no longer be associated with You. We reserve the right to use such
anonymous and de-identified data for any legitimate business purpose without further notice to You or
- Please refer to Our EULA as it sets forth specific rules with regard
to the retention of Patient personal health information.
- Your Choices
We strive to provide You with choices regarding the personal information You provide
to Us. We have created mechanisms to provide You with the following control over Your information:
- Tracking Technologies and Advertising. You can set Your browser to refuse all or some browser cookies, or to alert You when
may not be accessible or may not function properly.
- Promotional Offers from Us. If You have
opted in to receive certain emails from Us but no longer wish to have Your contact information
used by the Company to promote Our own or third parties' products or services, You can opt-out by
sending Us an email stating Your request to [email protected]. If we have
sent You a promotional email, You may unsubscribe by clicking the unsubscribe link we have included in
the email or change Your preferences in Your account profile.
- Third Party and Internet-based Advertising. We will not provide Your personal information to third parties, except for the purpose
to provide Our services to You and otherwise states in the EULA or herein. However, we cannot control
third parties' collection or use of Your information to serve interest-based advertising. However,
these third parties may provide You with ways to choose not to have Your information collected or used
in this way. 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.
- Accessing and Correcting Your Personal Information
- By law You have the right to request access to and to correct the
personal information that we hold about you. You may review and change some of the personal information
by logging into the Platform through the Website and visiting Your account profile page. Please keep Us
informed if Your personal information changes. For any personal information that You cannot change by
visiting Your account profile page, You may send Us an email at [email protected] to request access to, correct, or delete any personal information that You have
provided to Us.
- Subject to applicable privacy law, a Patient may request access to
their personal information and personal health information hosted by Us by sending Us an email at
[email protected] to request access to, correct, or delete any personal
information that You have provided to Us.
- For either situation in paragraph (a) or (b) above, We may not
accommodate a request to change information if We believe the change would violate any law or legal
requirement or cause the information to be incorrect.
- In certain circumstances We may need to delete Your account to
delete Your personal information. In such cases, You consent to Us deleting Your account for this
- We may request specific information from the person requesting
access to their personal information to help Us confirm their identity and their right to access, and to
provide You with the personal information that We hold about them (or their Patient) or make their
requested changes. If We cannot provide You with access to the personal information, We will inform them
of the reasons why, subject to any legal or regulatory restrictions. We will provide access to their
personal information, subject to exceptions set out in applicable privacy legislation.
- If any person is concerned about Our response or would like to
correct the information provided, the person may contact Our Privacy Officer at [email protected].
- Withdraw Consent
Where a person has provided consent to the collection, use, and transfer of the
person’s personal information, the person may have the legal right to withdraw consent under certain
circumstances. To withdraw consent, if applicable, contact Us at [email protected]. Please
note that if the person withdraws consent, We may not be able to provide the person with a particular
product or service. We will explain the impact to the person at the time to help You with Your
- Third Party Providers
- From time to time, We may engage with or employ third-party entities
and individuals (“Service Providers”) for maintaining functionalities of and making changes
to the Platform, to host information and data of the Platform, to process payment on behalf of You, or
to collect your payment of subscription fees of the Platform.
- Service Providers have access to personal information submitted by
You or collected by Us only to perform these tasks on Our behalf and are obligated under contractual
arrangements not to disclose or use it for any other purpose and to process the personal information
with the same standards set out in this Policy.
- You acknowledge that while Virtual Hallway strives to protect
privacy and security of personal information You submit or We collect, We cannot guarantee our Service
Providers will adhere to the same level of protection and security.
- You further acknowledge that, from time to time, Service
Providers may also access or process de-identified Personal Information to assist Us in analyzing how
Our Website is used.
- Links to Other Sites
The Platform may include plug-ins, services, social networks, applications, or links
to third-party websites. Clicking on those links or enabling those connections may allow the third party to
collect or share data about You. If You follow a link to a third-party website or engage a third-party
plug-in, please note that these third parties have their own privacy policies, and We do not accept any
responsibility or liability for the practices of third-party websites or their policies. We do not control
or application You visit.
- Children’s Privacy
- You represent and warrant that You are over the majority age of your
jurisdiction or age of 19 (whichever is higher) when You access or use the Platform. Our Platform does
not address or intend to address any User under the age of the majority of Your jurisdiction; or any
User under 19. We do not knowingly collect personal information from such user.
- We collect personal information, including personal health
information, of a child Patient under age of 13, only if the child’s parent(s) or legal
guardian(s) have provided informed consent to the Primary Care Provider for the child’s personal
information to be stored, processed, or transferred through the Platform. If We learn We have collected
or received personal information from a Patient who is a child under the age of 13 without verification
of an informed parental consent, we will delete that information. If You believe We might have any
information from or about a child under the age of 13, please contact Virtual Hallway at [email protected].
- Changes to This Policy
We may update Our Policy from time to time. We will notify You of any changes by
posting the new Policy on this page. We will let You know via email and/or a prominent notice on Our
Platform, prior to the change becoming effective and update the “Effective Date” at the top of
- Contact Us
email: [email protected].