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Privacy on WELL Clinics  

Updated: April 2025

WELL Health Clinic Network Inc. and our parent company WELL Health Technologies Corp. (“WELL”, collectively “we”) are proud to offer you the WELL Health Clinics website (the “Website”) and the associated medical clinics (the “Clinic”). WELL is committed to protecting your personal information and complying with applicable data protection and privacy laws.  This “Privacy Policy” tells you how we do so.

We will update this Privacy Policy as necessary. Please check it regularly.

 

  1. What information do we collect?

Website

Cookies

Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Website, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings, language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online interactions.

These Cookies helps us understand how you use the Website and the content of the Website in order to make improvements. We also may use these Cookies to promote our services through marketing and advertising. These Cookies may be accessed or disclosed to third-parties, such as Google Analytics and Facebook Pixel, for the purpose of analyzing site usage and better serving you relevant advertisements. 

You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of the Website’s features, and may prevent us from providing you with the information and services you have requested.

Website Forms

When you submit a form on the Website, we will collect some personal information about you, like your name, e-mail, phone number, address, and health card number (and if you are a health professional, your billing or regulatory college number). This information will be used to create a profile with WELL, verify your identity, respond to your inquiry, or to allow us to follow-up with you directly.

If you are a physician and submit an inquiry into the Healthcare Provider Portal, we will collect your name, practice location, e-mail, billing number and regulatory college number. This information will be used to either verify your identity, or to create and administer your Healthcare Provider Portal account.

Direct Marketing

If you sign up to receive direct marketing or promotional communications from WELL, we will collect your name and e-mail to inform you about the requested products and services from WELL and its affiliates.

Opportunities for physicians

If you are a Canadian Physician and fill out the online form to obtain information on either joining one of WELL’s  clinics or to obtain information on working as a locum in one of our clinics, your name, e-mail, phone number and other relevent information will be collected to allow the appropriate WELL representative to reach out to you to discuss the possibility of you joining the WELL team.

Clinics

At WELL Clinics, we will collect some personal information about you, like your name, e-mail, phone number, address, and your health card number. This information will be used to create a profile with WELL, verify your identity, communicate with you, and bill the relevant insurers for the healthcare services provided to you. WELL will also collect, either directly from you and potentially from other health service professionals or resources, personal health information about you. This information can include presenting problems, health history, health conditions and treatments provided.  Only the personal health information necessary to provide you with the requested health services will be collected.

 

  1. Why do we use personal information?

We use your personal information to:

  • provide you medical services,
  • review the diagnoses, and evaluate the treatment and services provided to you,
  • determine suitability for clinical research programs and trails which may be available;
  • manage our relationship with you and provide you with the information you request,
  • conduct research on our Website and at our Clinics including analyzing testing data to improve our services,
  • communicate with you regarding inquiries for information, service requests, employment opportunities, or appointment reminders,
  • detect, prevent or investigate security breaches,
  • process insurance information or other payment information,
  • protect our business against error, fraud, theft and damage,
  • maintain appropriate records for internal administrative purposes or as required by law,
  • conduct appropriate consultation and follow-up, and
  • book appointments at hospitals and other health services as appropriate as per the order of the consulting physician.

WELL reserves the right to aggregate and anonymize personal information collected and to use such aggregated information as it sees fit.

 

  1. Who do we share the personal information with?

We may share some of your personal information, including personal health information, with third-party service providers to provide you with the services you request. We only use service providers that ensure a comparable level of protection for your information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information only for the services requested.

Exceptionally, we may collect, use or disclose personal information without your consent in the following limited circumstances:

  • when the collection, use or disclosure of personal information is permitted or required by law or by regulatory proceedings,
  • in an emergency that threatens an individual’s life, health, or personal security,
  • when we require legal advice from a lawyer,
  • to protect ourselves from fraud,
  • to a collection agency to collect our unpaid accounts; or
  • to investigate an anticipated breach of an agreement or a contravention of law.

If we merge with another business, we will inform you of any impact on your personal information. 

Website

We only share your personal information with service providers to operate the Website. This includes potentially sharing your personal information for:

  • providing requested services or information,
  • operating and optimizing the Website, or
  • customer service.

Clinics

We may share your personal information, including your personal health information, with service providers in the course of administering health services to you. This includes potentially sharing your personal information to:

  • refer you to a specialist or another health professional,
  • determining your suitability for available clinical trials and programs,
  • process payments or to bill the relevant insurance providers, or
  • provide you access to requested information or reports via a service provider.

 

  1. How long do we keep personal information?

We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with applicable legal and regulatory requirements.

All personal health information collected at the Clinics will be retained for the minimum length of time as required by the relevant provincial Colleges of Physician and Surgeons. The retention periods are as follows:

  • British Columbia: 16 years (or 16 years from when the patient reaches the age of majority);
  • Alberta: 10 years (or 2 years from when the patient reaches the age of majority);
  • Manitoba: 10 years (or 10 years from when the patient reaches the ages of majority);
  • Ontario: 10 years (or 10 years from when the patient reaches the age of majority); and
  • Quebec: 5 years.

 

  1. How do we keep personal information accurate?

We take reasonable steps to ensure that any personal information in our custody is accurate and up to date but we mostly rely on you to notify us of any changes to personal information you provided us.

 

  1. How do we protect your personal information?

We use reasonable and appropriate physical, administrative and technical measures designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate purpose for accessing the personal information collected by us are authorized to do so. Security and data protection training is also provided to all WELL staff. Unauthorized use of personal information by anyone affiliated with WELL is prohibited and constitutes grounds for disciplinary action.

All of our contracts with our third-party service providers, including our EMR providers, contain clauses specifically to address confidentiality and data management, and covenants ensuring compliance with privacy law and the protection of personal health information. 

Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee no breach will ever occur. 

 

  1. Where do we store personal information?

Website

All personal information we collect on our Website is collected via secured connections and stored on secure servers in Canada; however, personal information processed by our third-party service providers may be done outside of Canada.  While outside of Canada, personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.

For more information on our service providers or where we store personal information, contact us at privacy@well.company.

Clinic

All personal health information we collect at the Clinic is stored within electronic medical records (EMR). Our agreements with our EMR vendors, and all other third-party service providers used in the operations of the Clinic, ensure that all personal health information remains in Canada and that our vendors comply with all relevant privacy laws and adhere to certain data protection standards.

For more information on our Clinic’s third-party service providers and how your personal health information is protected, contact us at privacy@well.company.

 

  1. Links to third-party sites

Our Website may lead you to third-party websites, including websites advertising other products or services.  Those organizations are separate and distinct from WELL and have their own separate privacy policies.  We are not responsible in any way for how any third-party collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies of these websites before providing your personal information to them.

 

  1. Direct marketing

You may sign up to receive marketing or promotional communications from WELL.  Where you have expressly consented, we may use your personal information to inform you about us and products and services offered by WELL and its affiliates and subsidiaries, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

  • using the unsubscribe feature found in our emails and other electronic communications, or
  • contacting us via email at marketing@well.company.

We remove your contact information from our marketing lists within 72 hours as soon as you unsubscribe.

 

  1. Use of Technology including Artificial Intelligence

WELL Health Clinics use digital tools including traditional software and artificial intelligence to enhance patient care, streamline administrative processes, and optimize experiences for patients and healthcare providers.

These tools include:

  • Electronic Medical Record (EMR) Software – EMR’s are secure, digital systems that store, organize, and manage patient health information, replacing traditional paper records. This software enables healthcare providers to efficiently document, access, and update patient charts in real time. Key benefits include:
    • Centralized Patient Data – Consolidates medical histories, prescriptions, lab results, imaging reports, and treatment plans in one secure system, ensuring accurate and comprehensive records.
    • Security – Designed to meet healthcare privacy laws and data protection standards, ensuring that patient information remains confidential and securely stored.
    • Improved Care Coordination – Allows multiple healthcare providers within the clinic to access up-to-date patient information, reducing errors and enhancing collaboration
    • Streamlined Documentation – Provides structured templates and automated features to support accurate and efficient note-taking, reducing administrative workload for physicians
    • Decision Support Tools – Integrates alerts, reminders, and evidence-based guidelines to assist healthcare providers in diagnosing conditions, managing chronic diseases, and preventing medication interactions.
    • Secure Communication & Data Sharing – Enables encrypted messaging and secure exchange of medical records with authorized specialists, laboratories, and pharmacies, ensuring continuity of care.
  • Online Booking System – A secure, user-friendly platform that allows patients to schedule, modify, or cancel appointments conveniently from their computer or mobile device, without needing to call the clinic. This system improves accessibility, reduces administrative burden, and enhances the overall patient experience. Key benefits include:
    • 24/7 Access to Scheduling – Patients can book appointments at their convenience, anytime and anywhere, without being restricted by clinic hours
    • Real-Time Availability – Displays up-to-date appointment slots, allowing patients to choose a time that best fits their schedule while helping clinics optimize provider availability.
    • Automated Reminders & Notifications – Sends reminders to patients before their appointment, reducing the likelihood of missed visits and no-shows.
    • Seamless Integration with EMR Systems – Syncs directly with the clinic’s Electronic Medical Record (EMR) software, ensuring that scheduled appointments are accurately recorded and that providers have access to relevant patient information.
    • Self-Check-In & Pre-Visit Forms – Allows patients to complete certain forms before their visit, streamlining the check-in process.
    • Secure & Compliant – Designed with encryption and authentication measures to protect patient information and comply with healthcare privacy regulations.
  • Automated Fax Triage – Intelligent software that sorts, categorizes, and prioritizes incoming medical documents, such as lab results and referrals, ensuring that critical information reaches the appropriate healthcare providers in a timely manner. This reduces administrative delays and enhances patient care coordination.
  • Ambient Scribe Software– Transcription software that observes and processes patient-provider interactions in real time, using artificial intelligence to generate comprehensive SOAP (Subjective, Objective, Assessment, and Plan) notes which are reviewed by the healthcare provider and saved as part of their ongoing records of your visit. This tool reduces the administrative burden on physicians by automating documentation while ensuring compliance with medical record-keeping standards set by the College of Physicians and Surgeons of British Columbia (CPSBC). By minimizing time spent on manual notetaking, providers can dedicate more attention to patient care, leading to a more engaging and efficient clinical experience, which can lead to better health outcomes.
  • Clinical Decision Support Software– This physician-directed tool harnesses clinical data and machine learning algorithms to assist in the early identification of chronic and rare diseases. By analyzing a patient’s medical history, test results, and other health data, the software can screen for over 100 conditions and highlight potential health risks. Physicians can use this tool to:
    • Identify patterns and risk factors for chronic diseases such as diabetes, cardiovascular conditions, and autoimmune disorders.
    • Detect early warning signs of rare diseases by comparing patient data against a curated panel of high-risk conditions.
    • Support diagnostic decision-making with evidence-based insights, allowing providers to take proactive steps such as ordering specialized tests or making timely referrals to specialists.
    • Enhance patient outcomes by facilitating earlier diagnoses, improving treatment planning, and reducing delays in care.
    • This technology empowers healthcare providers with data-driven insights, helping them make informed clinical decisions while optimizing patient care and early intervention strategies.
  • Additional Tools – As we continue to adopt innovative technologies, we will update this notice to reflect new tools that enhance patient care, streamline workflows, and improve service delivery at our clinics.

 

For more information on the use of technology at WELL Clinics, please contact privacy@well.company.

 

  • Consent

Patients

We will obtain the patient’s consent to collect, use or disclose personal information (except where we are authorized to do so without consent). Consent can be provided orally, in writing, electronically, through an authorized representative, or it can be implied when the purpose for collecting, using or disclosing the personal information would be considered obvious, and the patient or physician voluntarily provides personal information for that purpose.

Physicians

Where we collect, use or disclose a Physician’s personal information in order to provide services, we will obtain the physician’s consent.

 

  • Your rights

Based on the applicable laws of the province where you live and receive health care, you may have the following rights over your person health information:

  • updating or withdrawing your consent to the use or disclosure of personal information,
  • requesting access your personal information, including your personal health information,
  • requesting restrictions on our use or disclosure of your personal information,
  • objecting to or making a complaint to our use or disclosure of your personal information,
  • requesting that we edit or correct, but not remove, certain information (like an e-mail address),
  • requesting that we transfer to another organization the personal information you have provided us, and
  • requesting deletion of the personal information we hold about you, where permitted.

Contact us at privacy@well.company to exercise any of these rights. If you request access to your personal health information, we may refer your request to the relevant healthcare provider to comply with your request. We will respond within 30 days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons. 

We will address all requests with equal attention.

  • Contacting us

Accountability with respect to your personal information is important to WELL and WELL. In the event that you have any questions (including how personal information is managed by WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company.

If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.