This Privacy Policy governs how Brainbot Inc. (“Brainbot” “us” “we” or “our”) collects, stores, uses, discloses, and otherwise manages your Personal Information and your Personal Health Information (collectively “Information”) through the Brainbot Platform. The Brainbot Platform includes our website, our Authorized Healthcare Professional Services, our mobile app, and integrations with third-party systems.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE BRAINBOT PLATFORM YOU CONSENT TO THE COLLECTION, STORAGE, USE, AND DISCLOSURE OF YOUR INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Brainbot collects and uses Information through the Brainbot Platform, which includes our mobile app, third-party tools, and services provided by authorized healthcare professionals, to provide and facilitate healthcare services.
For the purposes of this Privacy Policy, “Personal Information” means information about an identifiable individual, including your name, phone number, email address, sex and gender, birth date, payment card information, and internet protocol (IP) address used to connect your computer to the internet but excluding Personal Health Information; “Personal Health Information” means information about an identifiable individual’s health or healthcare, including information that is collected or created by the Brainbot Platform in the course of providing healthcare services to you, information concerning your physical or mental health history, health status, symptoms, diagnosis, laboratory testing results, and diagnostic images, healthcare-related personal identification numbers, information concerning any healthcare service and advice provided to you, including referrals, recommended follow-up or next steps, and other health-related information. Personal Information and Personal Health Information do not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.
Use of Third-Party Systems in the Brainbot Platform: As part of the Brainbot Platform, certain services, such as the provision of website hosting, basic scheduling, processing payments, telehealth and secure messaging services, data storage, the collection of wearable device data, and conducting certain analysis and generating certain clinical insights using AI-based tools, may be facilitated through third-party tools. These third-party systems are carefully selected to ensure compliance with all applicable privacy and data protection regulations, and Brainbot ensures that Personal Health Information shared through these platforms is handled in accordance with PHIPA and other relevant standards.
How Brainbot Incorporates Artificial Intelligence: The Brainbot Platform uses various artificial intelligence tools to conduct data analysis and provide insights to assist in clinical decision making, as well as streamline administrative tasks. In addition, de-identified information is used to improve the Brainbot Platform and to train artificial intelligence models. Moreover, Brainbot uses aggregate-level de-identified data from your information combined with data from other Brainbot Platform users for analytics. This analysis aids in marketing efforts, further development of the Brainbot Platform, and may be shared with healthcare providers and public authorities when appropriate.
Limits for Collecting Personal Health Information: Brainbot collects personal information about you, which you enter into our mobile app or other approved Third-Party Systems. Brainbot only collects that Information from you necessary to provide you with the services and features available through the Brainbot Platform. This information may include:
Registration on the Brainbot Platform: You do not have to register to browse our Website. However, in order to use the mobile app and receive Authorized Healthcare Professional Services, you will need to register for an account with us, which may include utilizing a third party system, and provide your name and email address. You will also need to disclose information about your current health condition and health history to our healthcare team in order to enable them to provide you with appropriate services.
Quality of Care: If you receive Authorized Healthcare Professional Services, only authorized members of the Brainbot team who are directly involved in your care or in evaluating and improving the quality of services or the Brainbot Platform may access your Personal Information and Personal Health Information. All such team members receive appropriate training on privacy, security, and handling of Personal Health Information in compliance with applicable privacy laws, including PHIPA. Access is limited to the extent necessary to fulfill these purposes.
Payments: If you choose to purchase any services from us, or if your services are covered by a third-party payer such as an auto insurance company, lawyer, or other approved payer, we may collect and process payment information. This may include your payment method, payment card number, CVV code, or information provided by the third-party payer. This Information is used to process your payments or facilitate reimbursement. We use a third-party service provider to facilitate secure payment processing. In the case of third-party payers, Brainbot may share necessary information, including service details and relevant documentation, to support payment processing or reimbursement claims, in compliance with applicable privacy and security regulations.
Electronic Communications: If you have provided appropriate consent, Brainbot may use your Information to send you appropriate electronic communications, such as emails and SMS messages, containing promotional marketing materials about Brainbot’s products or services, including our newsletter.
Technical Support: We may use your Personal Information in order to verify your account information in the context of providing you with technical support. When you speak to our technical support staff, all audio conversations may be recorded to ensure quality of service to you and for training purposes.
Job Applications: If you apply for a job at Brainbot, you may provide us with certain Information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We may retain this information for a reasonable period of time, in compliance with applicable laws, to consider you for future roles unless you request that we delete it.
Contact Us: When you contact us with a comment, question, or complaint, you may be asked for information that identifies you (such as your name, address, and telephone number), along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this Information to assist you in the future and to improve our customer service, service offerings, and the Brainbot Platform.
We will not rent, exchange, or sell your Personal Information or your Personal Health Information.
Authorized Healthcare Professional Services: If you receive Authorized Healthcare Professional Services, we may disclose your Information to and among our healthcare team for the purpose of providing or assisting in the provision of services to you. We may disclose your Information to third parties, such as other health professionals, specialists, pharmacists, pharmacies, and laboratories, for the purpose of providing or assisting in the provision of services to you.
Third-Party Systems Arrangements: In connection with the Brainbot Platform and/or services provided by Brainbot, your Information may be transferred to our suppliers, agents, or other organizations or individuals who provide services or functions on our behalf. Our service providers are given only the Information they need to perform their designated functions, and we perform diligence and use contractual arrangements to ensure compliance with PHIPA requirements.
Sale of Business: Brainbot may transfer Information as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Brainbot, or as part of a corporate reorganization or other change in corporate control.
Affiliates: Brainbot may disclose Information to its affiliates for the purposes set out in this Privacy Policy.
Legal: Brainbot and our affiliates and service providers may disclose Information to third parties where required or permitted by applicable law (which may include access by courts, law enforcement, and national security authorities).
Access Device and Browser Information: When you access the Brainbot Platform from a computer or other device, we may collect information from that device, such as your Internet protocol address (IP address), browser type, connection speed, and access times (collectively “Usage Information”). We use Usage Information to improve our products and services and to protect your data from unauthorized access.
Cookies: The Brainbot Platform may use a technology called “cookies”. A cookie is a tiny element of data that the Brainbot Platform sends to your browser, which may then be stored on your hard drive so that we can recognize your browser when you return. We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Brainbot Platform, you may not be able to take advantage of all of the features of the Brainbot Platform.
Device and Usage Information: We may also collect device-related information from your mobile device or computer. This information is used to help us authenticate you, deliver content appropriate for your device’s capabilities, and to deliver push notifications to notify you about activity on your account, such as messages from our healthcare team. Examples of information that may be collected and used include your device’s unique identifier, manufacturer, model, and operating system version. In addition, in the event our application(s) crash(es) on your mobile device, we may receive information about your mobile device model, software version, and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).
Real-Time Video and Audio Conversations: You may connect with our healthcare team through a real-time video and audio call to receive certain healthcare services and to verify your identity. All video and audio calls conducted through the Brainbot Platform are confidential and end-to-end encrypted and accessible only to you and the healthcare professional responsible for your care.
Recording of Conversations: To enable the provision of more efficient occupational therapy care, we intend to record the audio of your conversations with your occupational therapist. These recordings will solely be used for generating clinical notes. Once the clinical note has been completed, the audio recording will be deleted. All data collected will be encrypted during transfer and storage using industry-standard encryption protocols. Access is restricted to your occupational therapist and Brainbot's Chief Clinical Officer, Shelley Vaisberg, who may have technical access to recordings through the EMR system. You have the right to withdraw your consent to recording at any time by notifying us, without affecting your access to care.
Secure Messaging: Our Authorized Healthcare Professionals may use secure messaging to communicate with you through the Brainbot Platform. Personal Health Information may be discussed during secure messaging, and all such communications are protected using industry-standard security measures. Access is restricted to your occupational therapist and Brainbot's Chief Clinical Officer, Shelley Vaisberg, who may have technical access to recordings through the EMR system.
Third Party Links: The Brainbot Platform may contain links to other websites or platforms that Brainbot does not own or operate. Also, links to the Brainbot Platform may be featured on third-party websites or platforms on which we advertise. Except as provided in this Privacy Policy, we will not provide your Information to these third parties without consent. We provide links to third-party websites or platforms as a convenience to our users. These links are not intended as an endorsement of or referral to the linked websites or platforms. The linked websites or platforms have separate and independent privacy statements, notices, and terms of use. We do not have any control over such websites or platforms and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use, disclose, secure, and otherwise treat personal information.
We understand that data security is a critical issue for our clients, and we are committed to safeguarding the Information in our custody and under our control. Brainbot has implemented a comprehensive information security program that includes written policies and procedures and security controls. We have implemented reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, loss, modification, and disclosure of Information in our custody and control. All data will be encrypted both in transit and at rest using industry-standard encryption protocols. Data transmission will be secured using Transport Layer Security (TLS). We conduct audits and complete investigations to monitor and manage our privacy compliance. Our privacy practices are intended to comply with applicable privacy laws. We will maintain the privacy and security of your Information as required by applicable privacy laws. By using the Brainbot Platform, you consent that your Information may be stored, processed, or transferred to other provinces or countries. Regardless of the jurisdiction to which your Personal Information is transferred, Brainbot will ensure that it is protected to the same standard required by Canadian privacy laws, including PHIPA. Brainbot uses contractual agreements and data protection measures to safeguard your Information, even in jurisdictions where local laws may not provide the same level of protection. Please note that your Information may still be subject to the local laws of the jurisdiction where it is stored, and in certain circumstances, foreign governments, courts, law enforcement agencies, or regulatory authorities may have access to your Information. While we strive to protect your Information, it is important to acknowledge that transmission of data over the Internet is not completely secure. Although we take all reasonable measures to safeguard your Information, we cannot guarantee its absolute security during transmission through the Brainbot Platform. Any transmission of Information is done at your own risk. We are not responsible for any circumvention of the privacy settings or security measures deployed on the Brainbot Platform. In the event of a data breach involving your Personal Health Information (PHI), Brainbot will notify you in accordance with PHIPA regulations. This notification will include details of the breach, what information was compromised, and any steps you can take to protect yourself.
Brainbot takes reasonable steps to ensure your Information is accurate, complete, and up to date. If you become aware that any Information in our possession about you is not correct, please contact our customer support at info@brainbot.co. You are entitled to a copy of the Information that we have in our possession or under our control; if you would like a copy of such Information, please contact us. We will take reasonable steps to verify your identity before granting access or making corrections. In addition, your right to access or correct your personal information is subject to certain legal restrictions.
You are entitled to access your Personal Health Information and request corrections to any inaccuracies. To request access or corrections, contact us at info@brainbot.co. We will verify your identity and respond to your request within 30 days, subject to legal restrictions.
We retain Information only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required to meet legal or regulatory requirements. We will retain any and all Information that we are required to retain under any applicable laws and regulations for the full duration of time required under those laws and regulations. We may also retain non-identifiable information and continue to use this information in accordance with this Privacy Policy. You may request that we delete the Information that we maintain about you, but please note that we may be required to maintain certain Information in order to meet our legal obligations (in which case we will comply with your deletion request only after we have fulfilled such obligations). Once information is no longer needed, we securely destroy it using industry-standard methods to ensure complete removal from our systems. When we delete Information, it will be deleted from the active database but may remain in our archives, and we may also retain Usage Information. After we delete Information, we may retain non-identifiable Information and will continue to use non-identifiable information as permitted under this Privacy Policy. You can withdraw your consent to our collection, use, and disclosure of your Information by contacting us at info@brainbot.co subject to certain legal or contractual restrictions. However, if you refuse to provide certain information or withdraw your consent, this may limit our ability to provide you with certain services, products, and functionalities.
You should report any privacy or security violations, including any suspected or actual unauthorized access, use, or loss of Information, to us by sending an email to info@brainbot.co.
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Information, we will notify you by email to the email address specified in your account or through a revised privacy policy on the Website. We include the date the Privacy Policy was last revised at the bottom of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you and for periodically visiting our Website and this Privacy Policy to check for any changes.
We welcome your questions, comments, complaints, and requests regarding this Privacy Policy and our privacy practices. Please contact us at info@brainbot.co.
