The agreement between Sabe and physicians providing services through the Sabe Platform and the Terms and Conditions for the Sabe Platform explain the services that Sabe provides to Authorized Physicians and to Users respectively. The agreement between Sabe and Non-Physician Providers providing services through the Sabe Platform explain the services that Sabe provides to Authorized Non-Physician Providers.
Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Physicians or Authorized Non-Physician Providers. Authorized Physicians and Authorized Non-Physician Providers are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use and retain in the course of providing services through the Sabe Platform. Please feel free to ask any Authorized Physician or Authorized Non-Physician Provider to whom you are referred if you have questions about how he or she will treat your Information.
Collecting and Using Information
Sabe collects and uses Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes. For example, we do not record the audio or video portions of interactions between Users and Authorized Physicians and between Users and Authorized Non-Physician Providers through the Sabe Platform. Access to information is restricted to Authorized Physicians and their administrative staff, and Authorized Non-Physician Providers and their administrative staff.
As mentioned, Authorized Physicians and Authorized Non-Physician Providers are responsible for their collection, use, disclosure, retention, destruction and protection of Information. As a result, the following description is an overview only of the use generally made of Information for the purpose of providing services through the Sabe Platform. A particular Authorized Physician or Authorized Non-Physician Providers may or may not chose to collect or use Information as described below in connection with a particular interaction with a User.
Authorized Physicians and Authorized Non-Physician Providers may collect Information about you or any Registered Dependent (as defined below) when you provide it during a Healthcare Services consultation (e.g., verbally or in texts), by viewing the Information that you have entered or uploaded to the Sabe Platform and/or by creating or compiling Information in the Sabe Platform. Information that will be available to Authorized Physicians and Authorized Non-Physician Providers includes: the details that you provide in your consultation request; information you’ve entered or uploaded to profiles and medical records; information created during earlier interactions through the Sabe Platform with other Authorized Physicians and/or Authorized Non-Physician Providers; the name, email address, phone number, gender and date of birth and province/territory that you provided when you registered; and your emergency contact’s name and contact information. Authorized Physicians and Authorized Non-Physician Providers use Information to provide you with Healthcare Services and/or Informational Services and, as with any healthcare provider, must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Physicians and Authorized Non-Physician Providers may create Information such as prescriptions, sick notes and other notes about your interaction with them through the Sabe Platform. They may export or print copies of your Information that they collect. Authorized Physicians and Authorized Non-Physician Providers may, but are not required to email or text your emergency contact if they believe that you are dealing with a medical emergency during a consultation. You are responsible for advising your emergency contact that you are providing their name and contact information to Sabe and Authorized Physicians and Authorized Non-Physician Providers, and for obtaining any necessary consent from them for the provision and use of their information in connection with the Sabe Platform.
Authorized Physicians and Authorized Non-Physician Providers collect and use Information that you provide in the course of obtaining Informational Services, by viewing the information that you have entered or uploaded to the Sabe Platform and by creating or compiling Information in the Sabe Platform. The Information that they collect and use includes: the details that you provide in your request for Informational Services and information that you provided to register to use the Sabe Platform (name, gender, date of birth and place of residence) to confirm your eligibility to receive Informational Services. Authorized Physicians and Authorized Non-Physician Providers are bound to comply with privacy legislation applicable to providers of Informational Services.
Provision of the Sabe Platform
We collect and use your Information to register you, create your User Account, authenticate you when you log in and personalize your experience while using the Sabe Platform. We confirm your eligibility to use the Sabe Platform for Healthcare Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.
We collect your provincial health card number in order to bill provincial health plans for those services that are eligible for coverage by provincial health plans.
You may choose to enter or upload and store your Information in the Sabe Platform such as your medical records, and the name and contact information for your emergency contact.
When seeking Healthcare Services, you may also choose to enter or upload and store Information about individuals for whom you have the legal authority to make decisions regarding their healthcare and for whom you have created a profile by providing their first and last name, gender and date of birth (each a “Registered Dependent”). We use their date of birth where applicable and your assertion of their relationship with you to confirm your eligibility to obtain Healthcare Services for them, and their eligibility to receive Healthcare Services.
We use Information that you enter, or upload, or which is created as part of an interaction with an Authorized Physician or Authorized Non-Physician Provider to make it available to you when you access your User Account.
We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.
We may use Information to help us create, develop, operate, deliver, support and improve the Sabe Platform, its content and advertising provided to you through it (Sabe’s and third parties’) unless you have decided not to receive such advertising.
Users eligible for Healthcare Services:
- To request Healthcare Services, you select any applicable symptoms relevant to your request. You may also specify whether you’re seeking to renew a prescription or obtain a sick note. We facilitate your disclosure to the Authorized Physician or Authorized Non-Physician Provider of that information, along with age and gender to determine whether your request is eligible. We do not identify you, or, if applicable, the Registered Dependent for whom you’re seeking the Healthcare Services. Once the Authorized Physician or Authorized Non-Physician Provider confirms that your request is eligible, we identify the Authorized Physician or Authorized Non-Physician Provider to you. The Sabe Platform presents to the Authorized Physician or Authorized Non-Physician Provider the Information you provided in your consultation request, your name and, if applicable, the name of the Registered Dependent for whom you’re seeking the consultation. Unless you have elected to withhold access to information held in the Sabe Platform about you or any Registered Dependent, the Authorized Physician or Authorized Non-Physician Provider will be able to view it too.
- We use Information that you enter to provide you with services that you request us to perform on your behalf, e.g., securely faxing your prescription to your chosen pharmacy.
- We use your Information to text or email you to notify you about services that you request. For example, we notify you about the status of your consultations and other requests, such as prescription orders.
- We may collect location data through the use of GPS technology and your IP address where applicable to services you have requested, e.g., ensuring you are connected to an Authorized Physician or Authorized Non-Physician Provider or pharmacy that is licensed or authorized to provide such services in the jurisdiction where you are located. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.
Users eligible for Informational Services:
- When you request Informational Services, you select any topics for which you are seeking education. On your behalf, we present the information that you provide to an Authorized Physician or Authorized Non-Physician Provider to determine whether your request is eligible for Informational Services. We do not identify you. Once the Authorized Physician or Authorized Non-Physician Provider confirms that your request is eligible, we identify the Authorized Physician or Authorized Non-Physician Provider to you. The Sabe Platform presents to the Authorized Physician or Authorized Non-Physician Providers the Information you provided in your request for Informational Services and your name.
- We use your Information to text or email you to notify you about services that you request, for example, about the status of your request for Informational Services.
- We may collect location data through the use of GPS technology and your IP address to support you in receiving services, e.g., ensuring you are connected to an Authorized Physician or Authorized Non-Physician Provider who is authorized to provide such services in the jurisdiction where you are located. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.
Communicating With You
Medical emergencies associated with requests for Healthcare Services. Should you submit Information about a medical issue, which is deemed an emergency by an Authorized Physician or an Authorized Non-Physician Provider prior to their acceptance of your request for Healthcare Services, Sabe reserves the right to contact you at any time using any of the contact information you have provided. This contact is strictly for the purpose of informing you that an Authorized Physician or Authorized Non-Physician Provider has viewed your anonymized request and has declined the request based on their belief that your symptoms may represent a medical emergency.
Updates and marketing. From time to time, we may send you service announcements, including policy updates and updates to our Terms and Conditions and software and keep you posted on our latest products and any upcoming events that may be of interest to you or apply to you. You may opt-out of receiving non-essential communications by logging in to your User Account and updating your preferences. For clarity, service announcements including updates to our policies and Terms and Conditions and software are not considered non-essential communications.
Customer support. If you email, fax, write to us or complete a ‘contact us’ form on the Sabe Platform, we will collect the name and contact information that you provide to us and will use it to respond to you.
We only permit our Personnel to access Information to the extent necessary to perform their designated functions. We require them to protect the Information and maintain its confidentiality by complying with our policies, procedures and applicable law.
We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Physicians or Authorized Non-Physician Providers, emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Sabe’s legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person. We may use or disclose your email address, but never PHI, information to market a product or service, either directly, or through a service provider or partner that performs services on our behalf.
We may disclose Information for the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.
Retaining and disposing of Information
Unless we otherwise give you notice, we will retain your Information on the Sabe Platform on your behalf until such times as you or we terminate your User Account. On termination, you will have an opportunity to print or make copies of your Information subject to the following. To ensure that Authorized Physicians and Authorized Non-Physician Providers may exercise any authority they have to withhold Information they compile in connection with Healthcare Services from patients under the law, you will be required to request any access you would like to notes made by an Authorized Physician or an Authorized Non-Physician Provider about your consultation from the Authorized Physician or Authorized Non-Physician Provider. With the exception of residents of Prince Edward Island receiving Healthcare Services in Prince Edward Island, Sabe is not the custodian of Information held on the Sabe Platform; rather it holds Information on behalf of Users or Authorized Physicians and Authorized Non-Physician Providers. For residents of Prince Edward Island receiving Healthcare Services in Prince Edward Island, Sabe is a custodian, as defined by the PEI Health Information Act. On termination of your User Account, once you have been given the opportunity to print or make copies of your Information, we will delete the Information associated with your User Account, except Information that an Authorized Physician or Authorized Non-Physician Provider advises us he or she requires in connection with a consultation or Informational Services the Authorized Physician or Authorized Non-Physician Provider provided. In such circumstances, Sabe will destroy the Information when the Authorized Physician or Authorized Non-Physician Provider has obtained a copy or terminates his/her account with Sabe.
You can access your Information or that of your Registered Dependents to check that it is accurate, complete, and up to date by logging in to your User Account at www.sabewellness.ca/login.
You may update and edit any of your Information except Information an Authorized Physician or Authorized Non-Physician Provider has viewed or created Information during a Healthcare Services consultation when you log in to your User Account. Contact the Authorized Physician or Authorized Non-Physician Provider who provided the Healthcare Services to access or request the correction of Information in their notes on the Sabe Platform or that they hold in their medical records.
You can access Information you provided in your request(s) for Informational Services by logging in to your User Account at www.sabewellness.ca/login.
The Sabe Platform offers you functionality and choices for protecting your privacy which include:
- You may enable two-factor authentication on your account to help ensure that only you can access your account. If you do, in addition to entering your password to log in to your account to access the Sabe Platform, we will send a code to your mobile number, which you will need to enter. This added security prevents anyone else from accessing your Sabe account unless they have access to your log in information and your mobile phone.
- You may choose whether to use audio, chat, or video for interactions with Authorized Physicians and Authorized Non-Physician Providers.
- When seeking Healthcare Services, you may withhold Information, e.g., consultation information and medical records from Authorized Physicians and/or Authorized Non-Physician Providers. Please be aware that Authorized Physicians and Authorized Non-Physician Providers may be unable to provide you with Healthcare Services as a result. They will advise you of the implications of your choice.
- When seeking Informational Services, any previous Information collected e.g., consultation information and records, will not be accessible by the Authorized Physician or Authorized Non-Physician Provider providing the services unless you specifically elect to provide access.
- You may choose whether to receive communications by email or SMS.
- You can check your log-in history when you access the Sabe Platform.
Please contact us directly at sabewellness.ca/login for assistance with using the privacy functionality or with any questions about using the Sabe Platform. Additionally, you may contact us at any time to: stop receiving e-mails or other correspondence from us, seek assistance with viewing and correcting Information, and close your User Account. To protect privacy, we may request information to verify your identity when you contact us.
Sabe takes the security of your information seriously. We store your information in electronic format using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Sabe Personnel are obligated to protect Information by adhering to our policies, practices and applicable laws.
You also play an important role in protecting your privacy and the confidentiality of your Information. For example:
- Create a strong and unique password for your User Account, using Sabe’s password strength estimator, and update it periodically.
- Do not share your User 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 contact us if you receive such a request.
- Log out of your User Account once you are finished using it, especially if you share your Device with anyone else.
- Have a strong and unique password on your Device, too.
- Choose a quiet, private location from which to receive services from Authorized Physicians and Authorized Non-Physician Providers.
Collecting, Using and Sharing Data
Sabe de-identifies Information on behalf of Authorized Physicians and Authorized Non-Physician Providers. Under their agreement with Sabe, Authorized Physicians and Authorized Non-Physician Providers permit Sabe to collect and use the resulting de-identified data for purposes that include: quality control activities designed to ensure use of the Sabe Platform in compliance with the Sabe Physician Services Agreement, Authorized Non-Physician Provider Agreements such as the Sabe Therapists Agreement, and the Terms and Conditions; improving the Sabe Platform and more generally, the use of patient-initiated telemedicine services (through an understanding of usage and utilization patterns by Users and Authorized Physicians and Authorized Non-Physician Providers); conducting academic research and designing surveys (to be posted and completed at the discretion of Users). We will not use Data to re-identify individuals.
Cookies and Similar Technologies
Links and Third Party Websites and Applications
The Sabe Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.
We publish the current version of our Policy at www.sabewellness.ca/privacy. We reserve the right to amend our Policy at any time. Check back often to ensure you are aware of our current practices for collecting, using, disclosing, retaining, destroying and protecting Information.
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’d like us to respond to you.
Sabe Wellness Medical Clinic Inc.
ATTN: Chief Compliance Officer
101-395 Stafford Street
Winnipeg, Manitoba, R3M 2X4
“Authorized Physician” means physician who are are independent, regulated health professionals. Each Authorized Physician is responsible for their own license and registration authorizing the practice of medicine in a Province or Territory of Canada. Sabe is not a healthcare provider. Authorized Physicians alone are responsible for the Healthcare Services and Informational Services they provide through the Sabe Platform.
“Authorized Non-Physician Provider” is an independent, regulated health professional (such as psychotherapists or nurses). Each Authorized Non-Physician is responsible for their own license and registration authorized by their regulating body in a Province or Territory of Canada. Sabe is not a healthcare provider. Authorized Non-Physician Providers alone are responsible for the Healthcare Services and Informational Services they provide through the Sabe Platform.
“Data” means information collected or compiled through the Sabe Platform which has been de-identified.
“De-identify” in relation to PHI, means to remove information that identifies the individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify the individual.
“Device” means a mobile or desktop device owned or controlled by a User and used to access Sabe Physician Services.
“Health Care” means any observation, examination, assessment, care, service or procedure that is provided by a physician or a non-physician healthcare provider to an individual to diagnose, treat, or maintain the individual’s physical or mental condition, to prevent disease or injury to the individual, or to promote the individual’s health.
“Healthcare Services” means the provision of Health Care by an Authorized Physician or an Authorized Non-Physician Provider through the Sabe Platform.
“Informational Services” means the provision of general information about a disease or condition, rather than patient specific medical information, for educational purposes only and for clarity, not including a diagnosis, treatment or advice based on observation, examination or assessment of a particular patient.
“Sabe Platform” means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Physicians and Authorized Non-Physician Providers to provide Healthcare Services and Informational Services to Authorized Users.
“Personal Information” means information about an identifiable individual which is not PHI and which is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Sabe Platform.
“Personnel” in relation to Sabe, means its employees and agents including independent contractors and sub-contractors, for whom Sabe is responsible at law.
“PHI” or “personal health information” means information about an individual’s health or healthcare that is subject to Privacy Law and that is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Sabe Platform.
“Privacy Law” means the applicable legislation governing the collection, use, disclosure, and/or protection of PHI in the Province or Territory in which a User resides.
“User” means an individual who has registered and created a Sabe User Account in accordance with our Terms and Conditions and is thereby eligible to receive Healthcare Services and/or Informational Services through the Sabe Platform.