1. Scope
This Privacy Notice applies to personal information processed by DrLoop in connection with:
- DrLoop Go;
- DrLoop Go accounts;
- Trip searches, requests and bookings;
- Ride Now and Plan Ahead functionality;
- One Way and Round Trip transportation;
- Trip management and tracking;
- payment and transaction functionality;
- Trip-related communications;
- safety and support functions;
- cancellation and refund processes;
- account and privacy requests;
- related Rider-facing services.
Separate privacy notices or agreements may apply to:
- DrLoop Driver;
- Hospital or Facility workflows;
- Provider Portal;
- drloop.ca;
- other DrLoop products or services.
This Notice describes DrLoop's handling of information. Other organizations involved in a Trip may have their own privacy obligations and policies.
2. Privacy Accountability
DrLoop is responsible for personal information under its control and maintains privacy practices intended to support compliance with applicable privacy requirements. DrLoop designates responsibility for its privacy program to its Privacy Officer or other authorized privacy official. DrLoop's privacy responsibilities include matters such as:
- privacy governance;
- privacy inquiries and complaints;
- access and correction requests;
- account and data deletion requests;
- consent and privacy choices;
- privacy and security incidents;
- service-provider oversight;
- retention and deletion practices;
- privacy-policy review.
Privacy inquiries may be directed to: Privacy Officer DrLoop Inc. info@drloop.ca If DrLoop establishes a dedicated privacy contact address, this Notice may be updated accordingly.
3. Information We Collect
The information DrLoop collects depends on how you use DrLoop Go, the features you use, whether you are arranging transportation for yourself or another Rider, and the circumstances of the applicable Trip. The categories of information we may process are described below. DrLoop does not seek to collect personal information merely because it may become useful at some point in the future.
4. Account and Contact Information
When you create or use a DrLoop Go account, DrLoop may collect information such as:
- name;
- email address;
- telephone number;
- account identifier;
- authentication information;
- security information;
- preferred language;
- communication preferences;
- profile information you choose to provide.
We use this information to:
- create and maintain your account;
- authenticate you;
- communicate with you;
- protect account security;
- provide DrLoop Go services;
- respond to support and privacy requests.
5. Information About Riders
The DrLoop Go account holder and the person receiving transportation may be different individuals. Where DrLoop Go allows transportation to be arranged for another Rider, DrLoop may process information about that Rider that is reasonably necessary to arrange, coordinate or perform the Trip. This may include:
- Rider name;
- contact information where required;
- Pickup;
- Destination;
- transportation requirements;
- mobility or accessibility requirements;
- equipment requirements;
- Trip instructions;
- other information reasonably relevant to the transportation.
A person providing information about another individual must have appropriate authority to do so. Authority to arrange transportation for another person does not automatically provide unrestricted access to all information about that person.
6. Trip Information
When you search for, request, schedule, confirm, manage or complete transportation, DrLoop may process information such as:
- Rider;
- Pickup;
- Destination;
- requested date and time;
- Ride Now or Plan Ahead selection;
- One Way or Round Trip selection;
- selected Transportation Provider;
- Vehicle type;
- transportation requirements;
- Trip instructions;
- Trip status;
- Provider assignment;
- Vehicle or Driver assignment;
- ETA and related timing information;
- arrival and departure information;
- cancellations;
- waiting or no-show information;
- completion information;
- applicable charges;
- refunds or adjustments;
- confirmation number;
- Trip history.
Trip information may be sensitive because it can reveal where a person travels, when they travel, or that they are receiving medical transportation.
7. Transportation Requirements
DrLoop Go may collect information reasonably necessary to identify transportation that may be suitable for the Rider. Depending on the Trip, this may include requirements such as:
- Wheelchair;
- Stretcher;
- Oxygen;
- Stair Chair;
- Cardiac Monitor;
- mobility assistance;
- accessibility requirements;
- stairs or access conditions;
- escort requirements;
- equipment requirements;
- relevant transportation precautions.
DrLoop seeks to limit this information to what is reasonably relevant to transportation, coordination, safety and related legitimate purposes. Transportation requirements associated with an identifiable Rider may constitute sensitive personal or health-related information.
8. Relevant Diagnosis or Condition for Transportation
For certain Trips, DrLoop Go may allow or request information described as: Relevant diagnosis or condition for transportation This means diagnosis or condition information only where it may reasonably affect:
- transportation requirements;
- transportation-related assistance;
- safety;
- relevant precautions;
- care requirements during the Trip.
DrLoop Go is not intended to collect a Rider's complete medical history merely to arrange transportation. Please do not provide unrelated:
- diagnoses;
- complete clinical histories;
- medical records;
- medical documents;
- health information
that is not reasonably relevant to the transportation. DrLoop does not use this field to provide a medical diagnosis. DrLoop does not use Relevant diagnosis or condition information for unrelated behavioural advertising or marketing profiling.
9. Sensitive Information
Depending on the circumstances, information processed through DrLoop Go may be particularly sensitive. This may include:
- Relevant diagnosis or condition information;
- health-related transportation information;
- disability or mobility information;
- transportation equipment requirements;
- precise location;
- Pickup and Destination;
- healthcare-related destinations;
- Trip history;
- Trip communications;
- payment and transaction information;
- safety or incident information.
DrLoop applies safeguards and access controls intended to reflect the sensitivity, purpose and risk associated with the information.
10. Location Information
Certain DrLoop Go features may use location information. Depending on the feature and your device permissions, DrLoop may process location information to support functions such as:
- identifying Pickup;
- displaying map information;
- locating available transportation;
- routing;
- ETA;
- Trip tracking;
- safety;
- customer support.
This may include precise location where required for the applicable feature and permitted by your device settings. Where supported, you may be able to manually enter a Pickup or Destination instead of providing device location. You can manage applicable location permissions through your device settings. Disabling location may affect features that depend on it. DrLoop does not treat acceptance of the DrLoop Go Terms of Use or acknowledgement of this Privacy Notice as a substitute for an operating-system location permission where one is required. DrLoop does not use precise Trip location to create unrelated behavioural advertising profiles.
11. Provider, Vehicle and Driver Information
In connection with a Trip, DrLoop may receive, process and display information about the Transportation Provider, Vehicle, Driver or crew involved in providing or preparing to provide transportation. This may include:
- Provider name;
- Provider identity or logo;
- Vehicle type;
- Vehicle information;
- assigned Driver or crew information where applicable;
- availability;
- transportation capabilities;
- Trip status;
- Vehicle position where available;
- ETA.
DrLoop uses this information to support transportation coordination, transparency, safety, support and Trip management.
12. Payment and Transaction Information
DrLoop Go may process information related to payments and transactions. Depending on the payment arrangement, this may include:
- payment method type;
- payment token or reference;
- masked payment information;
- authorization information;
- Trip charges;
- cancellation charges;
- waiting or no-show charges where applicable;
- taxes;
- refunds;
- adjustments;
- transaction identifiers;
- transaction history;
- receipt information.
Payment-card information may be processed by an authorized payment service provider. DrLoop seeks to minimize direct storage of full payment-card credentials where an authorized payment processor can perform that function. The payment service provider may independently process certain information under its own applicable privacy and legal obligations.
13. Communications
DrLoop may process communications connected with DrLoop Go, including:
- Trip Chat;
- in-app messages;
- support messages;
- Provider-related communications;
- email;
- SMS;
- push notifications;
- complaints;
- safety reports;
- feedback.
Trip-related communications may be associated with the applicable Trip where reasonably necessary for purposes such as:
- transportation coordination;
- support;
- safety;
- billing review;
- dispute resolution;
- fraud prevention;
- compliance.
Please avoid including unrelated sensitive or medical information in communications. Trip Chat and ordinary DrLoop communications are not emergency communication services.
14. Device and Technical Information
DrLoop may process technical information reasonably necessary to operate, secure, maintain and troubleshoot DrLoop Go. Depending on the production technologies actually used, this may include:
- device type;
- operating system;
- App version;
- IP address;
- language;
- network information;
- authentication events;
- security events;
- crash information;
- diagnostic information;
- technical logs;
- feature-performance information.
DrLoop seeks to configure technical, diagnostic and analytics systems so that they do not unnecessarily receive sensitive health information, Trip content or precise transportation information. The exact data disclosed through applicable App Store privacy disclosures should reflect the technologies actually enabled in the production version of DrLoop Go.
15. Information From Other People and Organizations
DrLoop may receive information concerning a Rider or Trip from authorized individuals or organizations. Depending on the circumstances, these may include:
- a family member;
- caregiver;
- guardian;
- substitute decision-maker;
- authorized representative;
- Hospital or Facility;
- Transportation Provider;
- Driver or crew;
- another authorized person involved in arranging or supporting the Trip.
DrLoop seeks to process such information only for purposes reasonably connected with the applicable authorized relationship or Trip.
16. How We Use Personal Information
DrLoop may collect, use or otherwise process personal information where reasonably necessary to:
- create and manage DrLoop Go accounts;
- authenticate users;
- protect accounts;
- identify transportation options;
- show Provider or Vehicle availability;
- arrange and coordinate transportation;
- schedule Trips;
- communicate Pickup and Destination information;
- communicate transportation requirements;
- support accessibility and mobility requirements;
- provide routing and ETA functionality;
- provide Trip status and tracking;
- process payments;
- issue receipts;
- manage cancellations;
- manage refunds and billing reviews;
- provide support;
- communicate with Riders and authorized Trip participants;
- investigate safety concerns;
- respond to accidents or incidents;
- prevent or detect fraud;
- investigate misuse;
- enforce applicable agreements;
- protect DrLoop systems;
- troubleshoot technical problems;
- maintain security;
- comply with applicable legal requirements;
- improve DrLoop Go using information appropriately available for that purpose.
DrLoop limits use to purposes that are reasonably connected to the collection of the information or another purpose permitted by applicable law.
17. Health-Related Information and Transportation Purposes
Health-related information collected through DrLoop Go should remain connected to legitimate purposes involving matters such as:
- transportation requirements;
- accessibility;
- assistance;
- Trip coordination;
- safety;
- authorized support;
- incident handling;
- other properly disclosed transportation-related purposes.
DrLoop does not use a Rider's Relevant diagnosis or condition, health-related transportation requirements or precise Trip location for unrelated behavioural advertising.
18. Information Shared With Transportation Providers
To arrange, coordinate and perform a Trip, DrLoop may provide the applicable Transportation Provider and authorized personnel with information reasonably necessary for that Trip. Depending on the circumstances, this may include:
- Rider identity;
- Pickup;
- Destination;
- applicable contact information;
- transportation requirements;
- mobility or accessibility requirements;
- equipment requirements;
- Trip instructions;
- relevant precautions;
- Relevant diagnosis or condition for transportation where reasonably necessary.
DrLoop seeks to limit Provider and Driver access to information relevant to their authorized transportation role. A Driver or Provider user should not receive unrelated medical history simply because that information exists elsewhere. A Provider's access to information through DrLoop does not authorize personal, unrelated or unauthorized use of that information.
19. Transportation Providers' Independent Responsibilities
Transportation Providers may have their own:
- legal;
- regulatory;
- insurance;
- transportation;
- safety;
- employment;
- recordkeeping;
- privacy
responsibilities. Information lawfully provided to a Transportation Provider may therefore also become part of records that the Provider independently maintains under its own lawful responsibilities. DrLoop does not represent that it can delete, modify or control information that is independently and lawfully controlled by another organization. Where DrLoop contractually requires a Provider to protect information obtained through DrLoop, those obligations do not eliminate responsibilities independently imposed on the Provider by applicable law.
20. Hospitals and Facilities
Where a Trip is arranged, supported, coordinated or otherwise connected with an authorized Hospital or Facility workflow, DrLoop may exchange information reasonably necessary for that purpose with the applicable organization. Depending on the circumstances, this may include:
- Rider identity;
- Trip details;
- Pickup or Destination;
- transportation requirements;
- applicable health-related transportation information;
- Provider;
- Vehicle;
- ETA;
- Trip status;
- relevant coordination information.
Hospitals and Facilities may have their own privacy, health-information and recordkeeping obligations. This Privacy Notice describes DrLoop's handling of information and does not replace another organization's applicable privacy notice or legal responsibilities.
21. Drivers and Crew
Authorized Drivers or crew may receive information reasonably necessary to perform an assigned Trip. Their access should be limited according to:
- the assigned Trip;
- their authorized role;
- legitimate operational need.
Technical access to information does not provide permission to access, use, copy or disclose that information for an unrelated purpose. DrLoop may use access controls, logs or other measures to support appropriate access and investigate suspected unauthorized access.
22. Service Providers and Technology Vendors
DrLoop may use third-party service providers to support functions such as:
- cloud infrastructure;
- hosting;
- database services;
- authentication;
- mapping and routing;
- payment processing;
- communications;
- email or messaging delivery;
- push notifications;
- security;
- diagnostics;
- technical monitoring;
- customer support.
DrLoop seeks to provide service providers only the information reasonably necessary for the services they perform. Where a service provider processes personal information on behalf of DrLoop, DrLoop uses contractual, technical or organizational measures appropriate to the information and service. Service providers handling personal information on DrLoop's behalf are expected to protect that information in accordance with applicable contractual obligations and privacy and security requirements and not use it for unauthorized unrelated purposes. DrLoop remains responsible for personal information under its control as required by applicable law.
23. No Unrelated Vendor Use of Sensitive Information
DrLoop does not authorize a service provider to use a Rider's:
- Relevant diagnosis or condition;
- health-related transportation requirements;
- precise Trip location;
- sensitive Trip information
for the service provider's own unrelated behavioural advertising merely because the provider supplies technology to DrLoop. A service provider's access should remain connected to the approved service and purpose.
24. Processing Outside Ontario or Canada
Some DrLoop service providers may process or store personal information outside Ontario or outside Canada. When information is processed in another jurisdiction, it may be subject to the laws applicable in that jurisdiction, including lawful access requirements. DrLoop considers factors such as:
- the type of information;
- sensitivity;
- purpose;
- service-provider safeguards;
- contractual protections;
- processing location
when managing service-provider relationships. DrLoop does not make an absolute representation that all DrLoop Go information remains physically stored only in Ontario or Canada unless such a representation is specifically confirmed for the applicable service.
25. Legal, Safety and Security Disclosures
DrLoop may collect, use, preserve or disclose personal information where permitted or required by applicable law or where reasonably necessary in connection with matters such as:
- lawful legal process;
- court orders;
- regulatory requirements;
- emergencies;
- safety concerns;
- fraud;
- security incidents;
- enforcement of legal rights;
- investigation of misuse;
- protection of individuals;
- protection of DrLoop systems.
Where appropriate, DrLoop seeks to limit the information disclosed to what is reasonably necessary for the applicable legal or protective purpose.
26. Business Transactions
If DrLoop is involved in a proposed or completed:
- merger;
- acquisition;
- financing;
- restructuring;
- corporate reorganization;
- sale of business or assets;
personal information may be used or disclosed as permitted by applicable law and subject to appropriate safeguards. A business transaction does not authorize unrelated use of health-related or other sensitive information.
27. Consent
Where consent is required, DrLoop seeks to provide information sufficient for you to reasonably understand:
- what information is being collected;
- why it is needed;
- how it will be used;
- who may receive it;
- reasonably foreseeable consequences of providing or declining the information.
The form of consent may depend on:
- sensitivity;
- purpose;
- circumstances;
- reasonable expectations;
- applicable law.
Sensitive information may require a more explicit form of consent depending on the circumstances.
28. Privacy Notice Acknowledgement Is Not Blanket Consent
DrLoop may ask you to acknowledge that this Privacy Notice was presented to you. For example: I acknowledge that I have read the DrLoop Go Privacy Notice. That acknowledgement:
- confirms that the applicable Privacy Notice was presented for review;
- does not constitute blanket consent to every collection, use or disclosure of personal information;
- does not waive privacy rights;
- does not replace contextual consent where required;
- does not replace device or operating-system permissions.
Acceptance of the DrLoop Go Terms of Use is also separate from privacy consent.
29. Contextual Choices and Sensitive Information
Where appropriate or legally required, DrLoop may provide additional information or request a separate choice in the context in which sensitive information is collected or used. This may occur, for example, in connection with:
- device location permissions;
- optional sensitive transportation information;
- a materially different use of personal information;
- another feature requiring a specific privacy choice.
A general account agreement should not be used to obscure a materially different or unexpected privacy practice.
30. Optional Information
Where personal information is optional and not reasonably necessary for the applicable service, DrLoop seeks to provide an appropriate choice. A Rider should not be required to provide unrelated medical information merely to use a transportation function that does not require that information. Where a feature cannot reasonably operate without particular information, declining that information may prevent use of that feature.
31. Withdrawal of Consent
Where DrLoop relies on consent that may lawfully be withdrawn, you may withdraw that consent subject to applicable:
- legal restrictions;
- reasonable notice;
- legitimate operational requirements;
- contractual requirements that may lawfully apply.
Withdrawal may affect functionality that requires the applicable information. Withdrawal does not automatically require deletion of information DrLoop remains legally required or permitted to retain.
32. Changes in Purpose
DrLoop will not treat this Privacy Notice as unlimited authorization to use personal information for any future purpose. If DrLoop proposes a materially different collection, use or disclosure that is not reasonably connected to the previously identified purpose, DrLoop will assess whether:
- additional notice;
- a new privacy choice;
- fresh consent;
- another lawful basis
is required before that processing begins.
33. Accuracy
Accurate transportation information may be important to the appropriateness and safety of a Trip. Users should take reasonable steps to keep relevant information accurate and current. You may request correction of personal information where appropriate. An accurate historical record of what occurred may sometimes need to remain as a historical record even where circumstances subsequently change.
34. Retention
DrLoop retains identifiable personal information only for as long as reasonably necessary for the purposes for which it was collected and applicable:
- legal;
- financial;
- contractual;
- safety;
- security;
- fraud-prevention;
- dispute-management;
- operational
requirements. Different categories of information may have different retention periods. For example, information needed to support a financial or transaction record may be retained longer than raw precise location or health-related transportation details where those details are no longer required. DrLoop maintains or develops retention and deletion practices intended to prevent indefinite retention merely because storage is technically available.
35. Sensitive Information Retention
Sensitive information such as:
- Relevant diagnosis or condition;
- detailed transportation requirements;
- precise location;
- Trip communications
should not be kept identifiable indefinitely merely because it was once associated with a Trip. Where identifiable information is no longer reasonably required, DrLoop will take appropriate steps to:
- delete it;
- securely destroy it;
- de-identify it;
- otherwise limit its continued use
in accordance with applicable requirements and DrLoop retention practices.
36. Trip and Transaction Records
Certain Trip or transaction records may need to remain after transportation ends for purposes such as:
- billing;
- receipts;
- accounting;
- transaction history;
- support;
- safety;
- dispute resolution;
- fraud prevention;
- legal compliance.
Retention of a Trip record does not mean that every sensitive category originally associated with the Trip must remain identifiable for the same period. DrLoop seeks to separate longer-term legitimate transaction records from sensitive information that no longer needs to remain identifiable.
37. De-Identified and Aggregated Information
DrLoop may retain information that has been appropriately de-identified, anonymized or aggregated where it is no longer reasonably associated with an identifiable individual under the applicable standard. Such information may be used for legitimate purposes such as:
- service analysis;
- operational planning;
- service reliability;
- product improvement;
- aggregate transportation analysis.
Removing a name alone does not necessarily mean information is anonymous. DrLoop considers whether remaining information could reasonably permit re-identification. DrLoop does not intentionally re-identify properly anonymized information without an appropriate basis.
38. Account Deletion
DrLoop Go users may request deletion of their account through the account-deletion process provided by DrLoop. The intended in-app path is: Profile → Account → Privacy & Data → Delete Account DrLoop also provides or intends to provide an applicable public account-deletion request process as required for supported platforms. A verified deletion request will close the DrLoop Go account and initiate deletion of associated personal information that DrLoop is not required or permitted to retain. Limited information may remain where legitimately required or permitted for purposes such as:
- legal obligations;
- transaction or financial records;
- safety;
- security;
- fraud prevention;
- disputes;
- privacy accountability.
Additional information is provided in DrLoop Go Account & Data Deletion.
39. Deleting the App Does Not Delete the Account
Removing or uninstalling DrLoop Go from your device does not by itself delete:
- your DrLoop Go account;
- Trip records;
- information maintained by DrLoop.
Use the DrLoop account-deletion process if you want to request deletion of your account.
40. Information Independently Held by Other Organizations
Deleting a DrLoop Go account does not automatically delete records independently and lawfully maintained by:
- Transportation Providers;
- Hospitals;
- Facilities;
- payment providers;
- other organizations.
Those organizations may have independent legal, regulatory, contractual, financial, safety or recordkeeping responsibilities. DrLoop will not represent that it can delete information outside DrLoop's legal or contractual control.
41. Security
DrLoop uses administrative, technical and organizational safeguards designed to protect personal information according to its sensitivity and risk. Depending on the information and system, safeguards may include measures involving:
- authentication;
- authorization;
- access controls;
- encryption;
- secure communications;
- audit logging;
- infrastructure security;
- secure software development;
- security monitoring;
- incident response.
No digital system can guarantee absolute security. DrLoop therefore does not represent that unauthorized access or security incidents can never occur.
42. Role-Based Access
Access to sensitive personal information should be limited to individuals whose authorized role reasonably requires it. For example:
- Riders should access information associated with their applicable account or authorized Trip;
- Transportation Providers should receive information reasonably required for applicable transportation;
- Drivers or crew should receive information reasonably necessary for assigned Trips;
- authorized Hospital or Facility users should receive information appropriate to authorized workflows;
- DrLoop personnel should access sensitive information only where their role requires it.
Technical access alone does not establish authority to view or use information.
43. Unauthorized Access and Snooping
Using valid technical credentials to access personal or health-related information without an authorized purpose is not permitted. DrLoop may maintain:
- access logs;
- security logs;
- administrative audit records;
- other appropriate evidence
to help detect, investigate and respond to suspected unauthorized access. DrLoop may take appropriate technical, contractual, account, employment-related or other action depending on the circumstances and applicable relationships. Unauthorized access to health information can constitute a serious privacy breach under Ontario health privacy law in applicable healthcare contexts.
44. Privacy and Security Incidents
DrLoop maintains processes intended to identify, investigate, contain and respond to privacy and security incidents involving personal information. Depending on the incident and applicable law, DrLoop may:
- investigate and document what occurred;
- restrict or revoke access;
- contain further disclosure;
- take steps to reduce potential harm;
- notify affected individuals;
- notify an applicable privacy regulator;
- notify a Transportation Provider, Hospital, Facility or other organization where appropriate;
- cooperate with lawful investigations;
- implement corrective measures.
The response will depend on factors such as:
- the information involved;
- sensitivity;
- number of affected individuals;
- circumstances of the incident;
- probability and seriousness of harm;
- applicable legal obligations.
45. Applicable Health Privacy Laws
Certain information processed through DrLoop Go may constitute personal health information where applicable health privacy legislation applies. DrLoop's legal role in relation to personal health information may depend on the particular:
- information flow;
- Trip;
- Hospital or Facility relationship;
- Transportation Provider relationship;
- contractual arrangement;
- custody or control of the information;
- applicable law.
Nothing in this Privacy Notice should be interpreted as stating that DrLoop has the same legal status under health privacy legislation in every circumstance. Where DrLoop processes information in connection with an organization subject to specific health privacy requirements, applicable law, contracts, authorizations and the organization's own responsibilities may also govern that processing.
46. Children, Minors and Authorized Representatives
Transportation involving a minor or another person represented by an authorized decision-maker may require information from a:
- parent;
- guardian;
- substitute decision-maker;
- caregiver;
- other authorized representative.
DrLoop may take reasonable steps to verify authority where appropriate. DrLoop will not disclose, change or delete another person's sensitive information solely because someone claims to represent that person without appropriate verification.
47. Caregivers and Family Members
A caregiver or family member may arrange or support transportation where they have appropriate authority. Authority to arrange a Trip does not automatically provide unrestricted access to:
- health information;
- complete Trip history;
- account information;
- other sensitive personal information
about the Rider. Access should remain connected to the applicable authority and purpose.
48. Access Requests
Subject to applicable law and permitted exceptions, you may request access to personal information DrLoop holds about you. DrLoop may require reasonable identity verification before providing access. The level of verification may depend on:
- sensitivity;
- risk;
- nature of the request.
DrLoop will not disclose sensitive information merely because a requester knows basic details concerning a Rider or Trip. Certain information may be withheld where withholding is required or permitted by applicable law.
49. Correction Requests
You may request correction of personal information that is inaccurate or incomplete, subject to applicable law. Where information is an accurate historical record of what occurred, DrLoop may preserve the historical record while documenting an appropriate:
- correction;
- clarification;
- update;
- dispute
where applicable.
50. Privacy Complaints
You may contact DrLoop if you have a concern about how your personal information has been:
- collected;
- used;
- disclosed;
- accessed;
- retained;
- deleted;
- protected.
DrLoop may request information reasonably necessary to:
- verify identity;
- understand the concern;
- investigate;
- respond.
DrLoop seeks to investigate privacy complaints in a fair and appropriate manner.
51. Regulatory Rights
You may first raise a privacy concern with DrLoop through its Privacy Officer. Depending on the circumstances and applicable law, you may also have the right to raise a concern with an applicable privacy regulator, which may include:
- the Office of the Privacy Commissioner of Canada; or
- the Information and Privacy Commissioner of Ontario.
Nothing in this Privacy Notice limits a legally available right to complain to an applicable regulator.
52. Communications Preferences
Certain communications are reasonably necessary to provide or protect DrLoop Go services. These may include:
- account-security communications;
- authentication communications;
- Trip confirmations;
- Driver or Provider updates;
- Trip-status updates;
- receipts;
- payment information;
- cancellation information;
- safety information;
- important service notices.
Where DrLoop sends optional promotional or marketing communications, applicable preference or unsubscribe mechanisms will be provided as required. Changing marketing preferences does not necessarily stop communications required to provide, administer or protect a service you requested.
53. Push Notifications
DrLoop Go may use push notifications for functions such as:
- Trip updates;
- Provider or Driver updates;
- reminders;
- account information;
- service or safety information.
DrLoop seeks to avoid unnecessarily displaying sensitive health information in lock-screen notifications. You may manage notification permissions through your device settings. Disabling notifications may affect your ability to receive certain real-time App alerts.
54. Analytics and Diagnostics
DrLoop may use appropriately configured analytics or diagnostic information to:
- maintain DrLoop Go;
- identify technical problems;
- understand feature performance;
- improve reliability;
- improve usability;
- protect the service.
Ordinary analytics and diagnostics should not intentionally receive:
- Relevant diagnosis or condition information;
- complete Trip Chat content;
- unnecessary health-related Trip information;
- precise Trip location
unless that information is genuinely necessary for an approved function, appropriately protected and lawfully processed. DrLoop does not treat ordinary analytics as permission to build health-related behavioural advertising profiles.
55. Third-Party Software and SDKs
DrLoop Go may contain third-party software or SDKs used to provide approved functionality. Before using third-party components that receive personal information, DrLoop seeks to assess matters such as:
- purpose;
- information collected;
- retention;
- security;
- data sharing;
- processing location;
- applicable contractual protections.
Third-party code does not receive unrestricted permission to collect or use DrLoop information merely because it is integrated into the App. DrLoop's App Store and other platform privacy disclosures should accurately reflect material data practices of third-party components actually used in production.
56. Advertising and Sensitive Information
DrLoop does not use a Rider's:
- Relevant diagnosis or condition;
- health-related transportation requirements;
- disability information;
- precise Trip location
to create unrelated behavioural advertising profiles. DrLoop does not sell such sensitive transportation or health-related information for behavioural advertising purposes. If DrLoop materially changes its advertising or tracking practices in the future, applicable notice, consent and platform requirements will be assessed before the new practice is implemented.
57. Electronic Privacy Notice Acknowledgement
When DrLoop presents this Privacy Notice during account onboarding or following an applicable update, DrLoop may ask you to review and acknowledge the Notice electronically. The review experience may require you to:
- open the Privacy Notice;
- be presented with the complete applicable version;
- reach the end of the displayed document;
- return to the acknowledgement screen;
- manually select the acknowledgement checkbox;
- select the final applicable confirmation control.
Reaching the end of a displayed document does not allow DrLoop to determine whether a person mentally read or understood every word. DrLoop may record that:
- the Notice was presented;
- the Notice was opened;
- the end of the document was reached;
- review was completed;
- the acknowledgement control was selected.
DrLoop may maintain an electronic acknowledgement record containing information such as:
- authenticated account identifier;
- document identifier;
- Privacy Notice version;
- document content hash;
- date and time of acknowledgement;
- App version;
- platform;
- applicable session or system information.
The purpose of this record is to establish which Privacy Notice was presented and acknowledged.
58. Acknowledgement Does Not Waive Privacy Rights
Acknowledgement of this Privacy Notice does not:
- waive rights available under applicable privacy law;
- provide unlimited consent to future processing;
- authorize unrelated use of personal information;
- replace location or other device permissions;
- eliminate DrLoop's privacy responsibilities;
- eliminate the need for fresh consent where applicable.
Where consent is required for a separate sensitive or materially different practice, DrLoop must address that consent separately as appropriate.
59. Changes to This Privacy Notice
DrLoop may update this Privacy Notice as:
- DrLoop Go changes;
- information practices change;
- service providers change;
- new features are introduced;
- applicable requirements change.
The current version will display its: Effective Date Last Updated and applicable: Version Where a change materially affects how personal information is collected, used or disclosed, DrLoop may provide additional notice and may obtain additional consent or acknowledgement where appropriate or required. A change to the text of this Notice does not itself authorize processing that otherwise requires additional consent.
60. Historical Versions and Privacy Evidence
DrLoop may preserve historical versions of this Privacy Notice and records showing which version was presented or acknowledged. These records may be retained for legitimate purposes such as:
- privacy accountability;
- legal compliance;
- dispute resolution;
- demonstrating applicable disclosures;
- security;
- fraud prevention.
Publishing a new Privacy Notice version does not modify the content of an earlier historical version that was previously presented or acknowledged.
61. Relationship to Other DrLoop Privacy Notices
This Notice applies specifically to DrLoop Go. Separate privacy documentation may apply to:
- DrLoop Driver;
- Hospital or Facility services;
- Provider Portal;
- drloop.ca;
- other DrLoop products.
Information may move between authorized DrLoop services where reasonably necessary to coordinate an applicable Trip or provide another authorized function, subject to applicable:
- purposes;
- permissions;
- access controls;
- safeguards;
- legal requirements.
62. Your Privacy Choices
Depending on your circumstances and applicable law, your privacy choices may include:
- managing device permissions;
- managing notification permissions;
- updating account information;
- requesting access;
- requesting correction;
- withdrawing applicable consent;
- managing communication preferences;
- requesting account deletion;
- making a privacy complaint.
Some choices may affect functionality that reasonably requires the applicable information.
63. Contact
For questions, requests or complaints concerning personal information handled by DrLoop: Privacy Officer DrLoop Inc. info@drloop.ca Please do not send unnecessary medical or sensitive Patient information through ordinary email. Where your request relates to a particular Trip, provide only enough information to allow DrLoop to identify and address the issue. DrLoop may request additional information where reasonably necessary to verify your identity, authority or request. For general DrLoop Go support, use the support options available through DrLoop Go or drloop.ca. For an immediate medical emergency or immediate danger, contact the appropriate local emergency service.
