Policy

12759233 Canada Inc. (“TelePets”, “we”, “us”) last updated this Privacy Policy (“Policy“) on July 10, 2023. We post the current version of the Policy at telepets.ca/privacy-policy.html. We reserve the right to amend the Policy at any time to account for changes in the Applicable Law, our practices, and the TelePets Platform. Please check to see if we have amended the Policy since you last used the TelePets Platform to ensure you are aware, and agree to our current privacy practices. This privacy policy outlines how TelePets protects the personal information of pet owners (clients) and the health information of their patient animals, and describes your rights and obligations.

TelePets complies with all applicable privacy legislation, including the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy laws.

TelePets uses Secure-Socket Layer (SSL/TLS) for all online transmissions.

Licensure or Registration

TelePets operates a veterinary telemedicine platform that enables the provision of virtual veterinary services by licensed veterinarians ("Veterinarians") to pet owners registered to use TelePets ("User" or "Client") within the provinces of Ontario and British Columbia. All Veterinarians are licensed and registered in good standing with their provincial veterinary regulatory college (e.g. the College of Veterinarians of Ontario (CVO) in Ontario and the College of Veterinarians of British Columbia (CVBC) in British Columbia) to engage in the practice of veterinary medicine in the required jurisdictions. TelePets enables virtual veterinary care through the following means ("The Services"): Email, Video Conferencing, Phone Conferencing, Website/client portal, and secure messaging.

Legal Compliance (Ontario, British Columbia, Federal)

TelePets complies with all provisions of applicable laws. This includes the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy and veterinary-practice legislation in the jurisdictions where we operate.

For clients in British Columbia, TelePets complies with applicable provincial privacy legislation governing the collection, use, and disclosure of personal information in the private sector. This legislation requires that we collect, use, and disclose personal information only for purposes a reasonable person would consider appropriate, and that we make our privacy policies publicly available.

TelePets does not facilitate the prescribing or dispensing of, or offer to facilitate the prescribing or dispensing of, veterinary medications that have not been approved by Health Canada's Veterinary Drugs Directorate (VDD) for use in the jurisdictions in which we operate, or that are not otherwise lawfully available for veterinary use. TelePets adheres to all applicable pharmacy licensure, veterinary drug safety, and supply-chain laws and regulations, including Health Canada veterinary drug regulations.

Location

TelePets operates in the provinces of Ontario and British Columbia. We only provide virtual veterinary services to clients whose patient animals are located in these provinces, using licensed veterinarians registered in those jurisdictions.

Controlled Substances

TelePets does not dispense or prescribe controlled substances as governed by the Controlled Drugs and Substances Act (CDSA). TelePets is not a pharmacy or drug manufacturer.

Consent to Use TelePets

You hereby acknowledge that you have read and fully understand the risks, limitations, conditions of use, and instructions for use of the selected Services. You understand and accept the risks outlined in the “Appendix” to this consent, associated with the use of the Services when interacting with TelePets veterinarians and administrative staff. You consent to the conditions and will follow the instructions outlined in the Appendix, as well as any other conditions that TelePets may impose in relation to clients using the Services.

Consent may be express or implied depending on the sensitivity of the information and the context. You may withdraw consent at any time, subject to legal and contractual limitations, by contacting our Privacy Officer.

You acknowledge and understand that despite recommendations that encryption software be used as a security mechanism for virtual care tools, it is possible that interacting with TelePets veterinarians or administrative staff using the Services may not be encrypted. Despite this, you agree to interact with the TelePets veterinarians or administrative staff using these Services with a full understanding of the risk.

Limitations of Virtual Care

TelePets will use reasonable means to protect the security and confidentiality of information sent and received using the Services. However, because of the risks outlined below, TelePets cannot guarantee the security and confidentiality of all virtual care tools:

• Use of virtual care tools to discuss sensitive information can increase the risk of such information being intercepted by third parties.
• Despite reasonable efforts to protect the privacy and security of information communicated through virtual care platforms, it is not possible to completely secure the information.
• Employers and online services may have a legal right to inspect and keep electronic communications that pass through their system.
• Virtual care tools can introduce malware into a computer system, and potentially damage or disrupt the computer, networks, and security settings.
• Communications through virtual care tools can be forwarded, intercepted, circulated, stored, or even changed without the knowledge or permission of TelePets or the client.
• Even after the sender and recipient have deleted copies of electronic communications, back-up copies may exist on a computer system.
• Communications through virtual care tools may be disclosed in accordance with a duty to report or a court order.
• Some videoconferencing platforms may be more open to interception than other forms of videoconferencing.

If the email or text is used as a virtual care tool, the following are additional risks:

• Email, text messages, and instant messages can more easily be misdirected, resulting in increased risk of being received by unintended and unknown recipients.
• Email, text messages, and instant messages can be easier to falsify than handwritten or signed hard copies. It is not feasible to verify the true identity of the sender, or to ensure that only the recipient can read the message once it has been sent.

Collection of Information

TelePets obtains your contact information (email address, phone number, mailing address) and information about your patient animal, including but not limited to species, breed, age, weight, prior veterinary diagnoses, surgeries, medication sensitivities, current medication list, and relevant history. At the time of registration, we also collect your username and password.

Personal information and animal health records are stored on our service provider's data centres (e.g. Microsoft Azure) and at TelePets's office.

TelePets collects this information only for purposes that a reasonable person would consider appropriate in the circumstances, consistent with PIPEDA and applicable provincial privacy legislation.

Use of Personal and Animal Health Information

Information is collected to facilitate the provision of virtual veterinary care to clients and their patient animals by licensed veterinarians. Animal health information can be disclosed, with your express consent, to other veterinarians or veterinary clinics (e.g. your pet's regular in-person veterinarian) involved in your pet's care at your request.

In some cases, TelePets or its veterinarians may be required by law to report certain findings (for example, reportable or notifiable animal diseases) to provincial or federal authorities under applicable animal-health legislation.

TelePets may also use information without additional consent in some limited ways, including risk management, error management, and quality improvement, such as where case outcomes are reviewed to evaluate the effectiveness of clinical practice or programs.

Third Party Services

TelePets may on occasion retain 3rd party software and service providers to provide operational, marketing or administrative support. For example, TelePets uses software including but not limited to Upvio Scheduling for secure online booking and Microsoft Azure for server hosting. On occasion, service providers that TelePets may contract may operate and store data outside of Canada. TelePets may also require the support of administrative staff at partner pharmacies or veterinary clinics. When selecting our partners, TelePets ensures they provide a comparable level of protection to assist in providing services for the purpose of developing or maintaining the electronic veterinary record. “Comparable level of protection” means that the third-party processor must provide protection that can be compared to the level of protection the personal information would receive if it had not been transferred (i.e. remained in Canada). It does not mean that the protections must be the same across the board but it does mean that they should be generally equivalent. Data that is held outside of Canada is subject to the laws of the country in which it is held, and when required by law may be subject to disclosure to governments, courts or law enforcement or regulatory agencies.

When personal information is transferred outside Canada, TelePets ensures through contractual means that the service provider provides a level of protection comparable to that required by PIPEDA and applicable provincial privacy laws. However, information stored outside Canada may be subject to lawful access by foreign authorities.

International Transfers

TelePets may host server data in other countries, including but not limited to the United States. This data is subject to regulatory disclosure to governments and/or regulatory agencies.

Transfers outside Canada are made only for reasonable business purposes and under safeguards meeting the “comparable protection” requirement of applicable Canadian privacy law.

Disclosure of Information

We will obtain your consent prior to collecting, using and disclosing your personal information and your pet's health information. We will disclose information, as required under Applicable Laws, to meet our legal obligations. You may withdraw your consent at any time by providing us with written notice.

Retention of information and deletion of information

TelePets maintains information on our online platform until you notify us in writing you would like to close your account. Once notified, we remove your profile and associated database information from our active server. We continue to store collected veterinary records as required under applicable provincial veterinary regulations and record-retention requirements.

TelePets retains veterinary records for the minimum period required by the applicable provincial veterinary regulatory college in the jurisdiction where the care was provided, or longer where required by regulation or for legal purposes.

Storage of Personal and Animal Health Information

TelePets stores your personal information and your pet's health records at TelePets's office or at our service provider's data centre, located in Toronto, Ontario.

Requesting Personal Information

We require you to confirm your identity to access personal information or your pet's health records. This includes authentication of your identity. Information that may be requested includes Legal Name, Given Name, Billing Address, Email Address, Cell Phone, and Home Phone.

Under PIPEDA and applicable provincial privacy legislation, you have the right to request access to, or correction of, your personal information by submitting a written request to the Privacy Officer. TelePets will respond within 30 days as required by law.

Correcting Information

If you wish to correct your personal information or your pet's health records, please reach out to us at info [at] telepets.ca or contact us by phone at ‭(519) 904-5280‬. ‬

Privacy Safeguards

TelePets has implemented physical, technical and administrative safeguards to protect personal information and animal health records from loss, theft and unauthorized access. This includes encrypting information when necessary, using strong passwords and 2 factor authentication (“2FA”), and restricting access to our system on a ‘need to know’ basis.

TelePets maintains reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, or disposal of personal information. This includes encryption, two-factor authentication, audit logging, and periodic security reviews.

Cookies and Safeguards

TelePets uses ‘cookies’ and other technologies to analyze, administer and improve the experience of users on our platform. You can block specific types of cookies when you visit TelePets's website through your browser settings. Most web browsers automatically accept cookies, and if you do not want to use cookies, you need to delete or block specific cookies. If you reject the use of some cookies, you will still be able to visit our website but some functionality may be limited.

Cookies are used only for functionality and service improvement. TelePets does not use cookies to track users across unrelated websites.

Links to 3rd Party Websites

TelePets may use a 3rd party to process payment for fees or access other associated veterinary services and technologies (e.g. Cogsworth/Upvio for secure online booking). You hereby consent to the disclosure of personal information necessary to obtain veterinary or other services.

Changes or Amendments to this Privacy Statement

We may change or amend this Privacy Policy at any time. If we make any change in how we collect, use, disclose, or otherwise process personal information, we will update the terms of this policy. If required by law, we will seek your prior consent to any changes to this policy.

Any material change that alters the purposes of collection or introduces new uses will be communicated prior to implementation, as required by applicable privacy legislation.

Contact Us

If you have any questions, comments or concerns please contact our Compliance Officer. We will require your name and contact information to respond.

TelePets
Attention: Compliance Officer
info [at] telepets.ca
Fax 833-510-0434
Phone: 519-904-5280
666 Wonderland Road North, Suite 3B
London, ON N6H 4K9

Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
📞 1-800-282-1376 🌐 www.priv.gc.ca

TelePets will notify affected individuals and, where required by law, applicable regulators of any breach of personal information or animal health records where there is a real risk of significant harm.

Appendix

While TelePets will attempt to review and respond in a timely fashion to electronic communications such as emails, secure messages, and instant messages, TelePets cannot guarantee that all electronic communications will be reviewed and responded to within any specific period of time. The Services will not be used for veterinary emergencies.

If your electronic communication requires or invites a response from TelePets and you have not received a response within a reasonable time period, it is your responsibility to follow up to determine whether the intended recipient received the electronic communication and when the recipient will respond.

Virtual care is not an appropriate substitute for in-person examination of your pet by a veterinarian when a hands-on assessment is clinically required, or for attending an emergency veterinary hospital when needed. You are responsible for following up on TelePets's electronic communication and for scheduling appointments where warranted.

Electronic communications or recordings of virtual encounters concerning diagnosis or treatment may be printed or transcribed in full and made part of your pet's veterinary record. Other individuals authorized to access the veterinary record, such as staff and billing personnel, may have access to those communications and recordings.

TelePets may forward electronic communications or recordings to staff and those involved in the delivery and administration of your pet's care. TelePets might use one or more of the Services to communicate with those involved in your pet's care. TelePets will not forward electronic communications or recordings to third parties without your prior written consent, except as authorized or required by law.

You and TelePets will use the Services to communicate sensitive information about your pet's health, which may include but is not limited to:

• Infectious or zoonotic disease screening
• Reproductive and behavioural health
• Chronic disease management and medication history

You agree to inform TelePets of any types of information you do not want sent via the Services, in addition to those set out above.

Some Services might not be used for therapeutic purposes or to communicate clinical information. Where applicable, the use of these Services will be limited to education, information, and administrative purposes.

TelePets is not responsible for information loss due to technical failures associated with your software or internet service provider.

Instructions for using the Services

To use the Services, you must:

• Ensure TelePets is aware when you receive an electronic communication from TelePets, such as by a reply message or allowing “read receipts” to be sent.
• Take precautions to preserve the confidentiality of electronic communications, such as using screen savers and safeguarding computer passwords.
• Withdraw consent only by email or written communication to TelePets.
• If your pet requires immediate assistance, or if its condition appears serious or rapidly worsens, you should not rely on the Services. Rather, you should contact your nearest emergency veterinary hospital or in-person veterinarian.

Other conditions of use in addition to those set out above:

• Reasonably limit or avoid using an employer's or other third party's computer.
• Conduct virtual care encounters in a private setting and using a secure device, where possible.
• Obtain TelePets's consent prior to making any recording of the virtual care encounter.
• Inform TelePets of any changes in your email address, mobile phone number, or other account information necessary to communicate via the Services.

If the Services include email, instant messaging and/or text messaging, the following applies:

• Include in the message's subject line an appropriate description of the nature of the communication (e.g. “prescription renewal”), and your full name and your pet's name in the body of the message.
• Review all electronic communications to ensure they are clear and that all relevant information is provided before sending to TelePets.