Wello’s Privacy Policy

Wello is committed to the privacy, confidentiality and security of all information

Last Updated: September 9, 2021

This Privacy Policy describes how Inliv Inc., doing business as Wello (“Wello”, “we”, “us” or “our”) collects, uses and discloses personal information in the course of providing virtual and personalized care services and when you visit our website at www.wello.ca (the “Website”).

Collection and Use of Personal Information

We collect personal information (including health information) from users of our service and their dependents, in order to ensure that comprehensive medical treatment, health services, and education can be provided. This information may include name and contact information, health and medical information including provincial health numbers and demographic information.

We collect information necessary to process payments including payment card information and insurance information.

If you are an employer who retains Wello to provide services to your employee, we will collect your name, contact information and payment information, as well as information about your business. We use this information to provide the services you have requested, to administer and collect on our accounts, and to communicate with you.

We may use the personal information you provide to communicate with you regarding other Wello products, services, events, medical updates and educational information.

Wello uses the information collected to create anonymous statistics to aid service and business analysis. These statistics are created blindly and do not contain personally identifying information.

Wello uses personal information for other standard business purposes such as maintaining records, enforcing our agreements, detecting and preventing fraud, and for other purposes with your consent or as permitted or required by law.

Our Website

When you visit our Website, we automatically collect your IP address, the date and time of your visit, the pages you visit, the features you use, and the referring URL’s you came from. We use this information to improve our Website and services.

We also use cookies and similar technologies to collect information about your visit to our Website, to remember your preferences and settings when you navigate through our Website, and for security purposes.

You may be able to set your browser to block or delete cookies, or to notify you before a cookie is set. If you block cookies you may not be able to use all of the features of our Website.

For your convenience, we may offer links from our Website to other websites. We do not control, and are not responsible for, the personal information handling practices of other websites. We encourage you to consult the privacy policies for these websites before providing any personal information.

Wello disclosure of personal information

Your Employer. If you have registered for Wello through your employer, Wello may share aggregated statistics with your employer, however, your personal information cannot be identified from these aggregate statistics.

Your Healthcare Providers. With your explicit consent, we will forward information to your family physician or another third-party service provider to ensure appropriate ongoing monitoring and long-term follow up.

Service Providers. We may use service providers (including affiliates acting in this capacity) to provide certain services on our behalf such as data hosting and processing, analytics, marketing and advertising, communications and other services. Some of these service providers may be located outside of Canada, including in the United States.

Business transactions. Personal information may be used and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Our assignees or successors may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

Legal. We and our service providers may disclose personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies) or as otherwise required or permitted by law.

Disclosures In Connection with Mental Health Services. Mental health counselling services include, but are not limited to, consultation and treatment using interactive audio, video, and/or data communications. When you use these services, information about your mental health will be collected by Wello and a summary of your appointment will be recorded on your medical records. While mental health records are treated as confidential, Wello or your counsellor may be required to break confidentiality in the following circumstances (for the purposes of this section, “we” refers to Wello or your counsellor):

  • You represent a harm to yourself or to another person (e.g., if you report to us that you are acutely suicidal or that you are going to take another person’s life). We are required to take action to protect you or the other person (e.g., by warning the police, your family, or the other individual).
  • You inform us of any potential, suspected or known child abuse, including physical, emotional abuse and neglect. Please be aware that we are required to report the suspicion of child abuse or neglect and the information on which it is based to child welfare. Even past abuse of a child who is now an adult must be reported if the abuser still has access to children.
  • You indicate that you have been sexually abused by a registered health care professional (e.g., physician, dentist, etc.). We must report that individual to his or her professional regulatory body.
  • There is a court order whereby we are legally required to submit the requested information or documents.

Disclosures In Connection with Occupational Health Services. When you use Occupational Health Services, Wello and Wello practitioners may collect and share information with your employer in order to establish your fitness for duty, facilitate workplace accommodations, manage income protection benefit plans and facilitate return to work assistance. The information that may be shared for these purposes includes the general nature of your medical condition and that you are under care, the amount of time that you are expected to be off work, date of disability and length of disability, and your fitness for duty including any limitations or restrictions in order to carry out work in a safe manner.

Security of Personal Information

Wello acknowledges that personal information is confidential and takes steps to maintain its records in a secure environment.

The file containing your personal information will be maintained on our servers or those of our service providers. Within Wello, access to personal information is provided on a need to know basis to staff that require the information to perform their assigned duties to ensure high quality care. Only the least amount of health information necessary to carry out the intended purpose is collected, used and disclosed. We retain personal information for as long as necessary for the purposes for which such information was provided or to otherwise meet legal requirements. Wello utilizes an online system that allows encrypted messaging between our health professionals and clients. Online credit card information is encrypted.

Despite these measures, please be advised that no security measures can offer absolute security and it is possible that your personal information may be lost or stolen or accessed without authorization.

Access and Correction

You may request access to or correction of your personal information in our custody or control by writing to us (see “Contact Us” section below).  Your right to access and correct your personal information is subject to applicable legal restrictions. We may request information from you in order to verify your identity before providing access or making corrections.

Privacy Policy Updates

This Privacy Policy is effective as of the Last Updated date written above. We may update or amend this Privacy Policy from time to time. The revised Privacy Policy will be posted on our Website. We recommend that you refer to this Privacy Policy frequently for the latest information about our personal information practices.

Canada’s Anti-Spam Law

Wello has implemented a series of practices to comply with the consent and unsubscribing provisions for Commercial Electronic Messages (CEMs) in Canada’s Anti-Spam Legislation (CASL). Where consent is required by CASL, we ensure that recipients have expressly opted-in or have given their consent to receive Wello communications.

Use of Cookies

Wello uses cookies, pixels, and other technologies (collective, “cookies”) to collect information about usage patterns. This information assists Wello in tracking traffic and site use, as well as in developing content that responds to the interests of visitors. These cookies assign a number to each visitor to capture the frequency of visits and document what pages the user is viewing. These cookies also recognize the type and version of web browser used, to ensure our site is technically accessible.

Wello uses Google Analytics to collect information on our websites. Individuals may opt out of Google Analytics by visiting the Google Analytics opt-out page.

Contact Us

If you require more information or clarification on our privacy policy, please do not hesitate to contact our Wello Privacy Officer at 403-538-8881 or via email at business@wello.ca.