Last Revised: August 8, 2023
COLLECTION AND USE OF INFORMATION
Frida provides individuals with access to authorized physicians and authorized non-physician health care providers such as nurse practitioners (collectively, “Health Care Practitioners”) and personal health assistants (“PHAs”) by secure text, video and audio chat for virtual care consultations (“Health Services”), and related healthcare and administrative support services (“Support Services”) through the Frida Platform (together referred to as “Services”).
Provision of Services: Frida collects and uses Information for the purpose of providing and facilitating the provision of the Services. For example, we use Information to verify your identify, determine your eligibility for Health Services, and provide you with services that you request us to perform on your behalf, such as transmitting your prescription to your chosen pharmacy.
Registration on the Frida Platform: You do not have to register in order to browse our Website. However, in order to use the Frida Platform to receive Services, you will need to register for an account with us and provide your name and email address. You will also need to disclose information about your current health condition and health history to Health Care Practitioners and PHAs in order to enable them to provide you with appropriate Services. We use your Information to identify who you are, communicate with you, and otherwise administer your use of the Frida Platform to receive Services. The Frida Platform in intended solely for individuals who have attained the age of majority in their jurisdiction of residence.
Quality of Care: If you receive Services, members of the Frida team may review your Personal Information and Personal Health Information in order to evaluate and/or improve the quality of Services or the Frida Platform, including responding to any inquiries from you.
Payments: If you choose to purchase any services from us, we collect your payment information such as your payment method, payment card number, and CVV code. This Information is used to process your payments. We use a third-party service provider to facilitate secure payment processing.
Electronic Communications: If you have consented, Frida may use your Information to send you electronic communications, such as emails and SMS messages, containing promotional marketing materials about Frida’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 will be recorded to ensure quality of service to you and for training purposes. For clarity, “technical support staff” does not include our Health Care Practitioners or PHAs. Your video and audio conversations with Health Care Practitioners and PHAs are never recorded.
Job Applications: If you apply for a job at Frida, you may provide us with certain Information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this Information for the purpose of processing and responding to your application for current and future career opportunities.
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 a 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 Frida Platform.
DISCLOSURE OF YOUR INFORMATION
We will not rent, exchange or sell your Personal Information or your Personal Health Information.
We may transfer or disclose Information as follows:
Circle of Care: If you receive Services through the Frida Platform, we may to disclose your Information to and among Health Care Practitioners and PHAs 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.
Service Provider Arrangements: In connection with the Frida Platform and/or Services provided by Frida, your Information may be transferred to our suppliers, agents or other organizations or individuals who provide services or functions on our behalf. For example, we may use service providers to process payments, host our Website and store information on our behalf. Our service providers are given only the Information they need to perform their designated functions and we use contractual controls to protect this Information. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.
Sale of Business: Frida 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 proceeding) involving all or part of Frida or as part of a corporate reorganization or other change in corporate control.
Legal: Frida 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 in Canada).
INFORMATION ABOUT OUR PLATFORM
As you use the Frida Platform, certain Information may be passively collected by Cookies, navigational data like Uniform Resource Locators (URLs) and third party tracking services, including:
Access Device and Browser Information: When you access the Frida 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 in order to improve our products and services and to protect your data from unauthorized access.
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 about activity on your account, such as messages from our Health Care Practitioners. 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 be required to connect with Health Care Practitioners and PHAs through a real-time video and audio call to receive certain Health Services such as diagnoses and advice, and to verify your identity. All video and audio calls conducted through the Frida Platform are confidential and end-to-end encrypted and accessible only to you and the Health Care Practitioners and PHAs responsible for your care. These calls are never recorded or stored and cannot be accessed at a later date.
Text-based Chat: No Personal Health Information will be requested during these conversations.
SECURITY OF 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.
Frida 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.
Frida’s security policies, procedures, and controls are tested and audited by a third party on an ongoing basis, using industry-standard practices.
Our privacy practices are intended to comply with applicable privacy laws, including without limitation, the Alberta Personal Health Information Act (“HIA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We will maintain the privacy and security of your Information as required by applicable privacy laws, including without limitation, HIA and PIPEDA and the regulations under those Acts. By using the Frida Platform, you consent that your Information may be stored, processed, or transferred to other provinces or countries which may not guarantee the same level of protection of personal data as the one in which you reside. Your Personal Information will be subject to the local laws of the jurisdiction where it is transferred and in certain circumstances, other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal information.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Information, we cannot guarantee the security of your Information transmitted through the Frida Platform. Any transmission of Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Frida Platform.
ACCESS AND CORRECTION OF INFORMATION
Frida 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. Contact information may be found under the heading “Contact Us”.
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.
We may use non-identifiable information created by us from your Information in order to better understand and improve the Freddie Platform and our service offerings. We may share such non-identifiable information with our partners to assist in research, planning, or product and service development.
RETAINING YOUR INFORMATION; WITHDRAWAL OF CONSENT
You can withdraw your consent to our collection, use and disclosure of your Information by contacting us at email@example.com, 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 firstname.lastname@example.org.
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