- Orpyx Sites include the mobile application (the “App”), the website which contains general information for the public about Orpyx (the “Website”) and the dashboard used by healthcare providers to monitor and track patients using the App (the “Dashboard”).
- Orpyx works with healthcare providers to identify patients who are good candidates for the App based on their health needs. In some cases, the App may be used by users on behalf of Patients. A “Patient” is an individual who is using the Orpyx sensory insoles (described below) for medical purposes, and whose medical information is entered into or collected by the App (“Patient Data”). A “User” is an individual who is entering information about a Patient into the App. In some cases, the User is a Patient; in some cases, the User is a guardian, friend, or relative of a Patient that is involved in the care of a Patient. The App is intended to help Users, Patients, and healthcare providers track the Patient’s foot health. In most cases, the term “User” and “you” will include both Users and Patients, unless we say otherwise.
Understanding the Orpyx Technology
The Orpyx system uses an insole with special sensors (a “sensory insole”) which is intended to help identify areas of excessive foot pressure and variances in foot temperature to help decrease the risk of foot injury in individuals at risk of foot wounds. The Patient’s healthcare provider prescribes the Orpyx sensory insole (Custom or Flex) (the “Device”). The Device senses and may store pressure, temperature, data about the mobility and health of a Patient’s feet, and generates summary data (“Patient Data”) to help prevent foot ulceration, and wirelessly sends the Patient Data to the App. The App collects the Patient Data, may store the Patient Data, and sends the encrypted Patient Data to a secure cloud-based Orpyx data repository. The Patient’s healthcare provider is permitted to view and analyze the Patient Data in the Orpyx data repository through the Orpyx Dashboard.
2. Collection of Your Personal Information
Some areas of the Sites can be accessed without submitting any personal information. Some areas of the Sites require an account to access.
We collect personal information when:
- You complete the online forms to create an account
- You contact us using online forms, email, phone, or other means of communication
- You request information or assistance through the Sites
- You transmit Patient Data through the App to the Orpyx data repository
- You authorize your doctor or other healthcare provider to access your health information through the Orpyx Dashboard
- You authorize your doctor or other healthcare provider to transmit your health data to Orpyx such as when your healthcare provider sends prescription details or other relevant health information associated with your plan or medical history
- You complete online forms to view webinar replays or subscribe to our newsletter
- You complete online forms to purchase products or services
- You establish a candidate profile in our job applicant tracking system.
The personal information that you provide and Orpyx collects through these areas of the Sites may include:
- your name;
- username and password;
- e-mail address;
- telephone number;
- date of birth;
- insurance information;
- treating physician information;
- facility/physician office information; and
- any other personal information that you include in a user profile or in other submissions to us.
What Information is Automatically Collected?
We automatically may collect information such as:
- The serial number of your Device (the sensory insole);
- The date and time Patient Data is collected;
- The date and time Patient Data is sent to the Orpyx data repository;
- The IP address of the computer used to send the Patient Data to the Orpyx data repository;
- The type of computer, smart phone, or other device used to send Patient Data to the Orpyx data repository;
- Technical information about the computer, smart phone, or other device used to send Patient Data to the Orpyx data repository, such as the operating system, browser, and internet service providers it uses;
- Data on advertisements or links on which you click, and the websites that you visit before or after you visit the Sites;
- Website analytic data, such as the number of people who have visited the Sites, what times they visited, which Site pages they looked at, how long they spent visiting the Sites, and similar information.
Automatically collected information will be anonymized to protect your privacy. All unique identifiers that are not connected to Orpyx products (such as IP addresses or mobile device ID’s) will be changed to random codes, Orpyx will not attempt to reverse this process and identify you.
All other automatically collected information will be encrypted before it is stored in the Orpyx Cloud. This information will only be shared with third parties or connected with your personal information:
- In order to provide goods or services you have requested;
- In order to complete a task we have agreed to perform for you;
- In order to operate our business, including to troubleshoot problems with the App or the Sites, or exercise our legal rights;
- It is necessary to comply with our legal obligations; or
- In a circumstance where we have informed you ahead of time that personal information and automatic information shall be combined, and we have acquired your consent.Orpyx may maintain this type of data directly, or may use service providers that act on behalf of Orpyx.
3. Use of Your Personal Information
We may use the personal information you provide to us, separately or in combination with pre-existing information, or in combination with personal information from your healthcare provider, for the following purposes:
- to provide the Orpyx technology, services, and functionalities, and to notify you of any changes;
- to provide any requested information, products or services;
- To provide you with cloud-based health management services if applicable;
- To respond to any request we may receive from you, such as requests for Orpyx technology or account support;
- To continue to develop, test and improve the Orpyx Sites, including to offer new functionality and features;
- To better understand how you interact with the Orpyx Sites, including their functionality and features, as well as to ensure that content is presented in the most effective manner;
- To support, maintain and troubleshoot, or fix any issues with the Orpyx Sites, including as part of our efforts to keep the Orpyx Sites effective safe and secure;
- To conduct data and statistical analysis, testing, research, or as part of our efforts to keep the Orpyx Sites safe and secure;
- To allow you to participate in interactive features of the Orpyx Sites, when you choose to do so;
- To invite you to participate in surveys, opinion groups or promotional and marketing activities related to your operation and use of the Orpyx Sites, your Orpyx Site account or our products and services, including in conjunction with selected third parties;
- To customize your experience or homepage on the Sites;
- To contact you with more information about Orpyx and its products;
- To make suggestions and recommendations about products or services that may interest you,
- As necessary if we need to issue a safety notice or corrective action related to the Sites;
- To conduct data and statistical analysis, testing, research, as part of our efforts to keep the Sites safe and secure;
- To improve the performance of the Orpyx technology, or to develop new Orpyx technology or services;
- To conduct our business operations, to protect our rights, or to comply with law.
Orpyx will only retain your personal information through the Site should you or your agent choose to provide it.
- You are not required to provide personal information to Orpyx; however, if you do not provide personal information, Orpyx may not be able to provide certain services to you.
- We also receive your personal information through other channels, such as through third party service providers that we have entered into agreements with or such as when your healthcare provider sends us a prescription to make your sensory insoles.
Email and Other Opt-Outs and Unsubscribes
If, at any time, you prefer not to receive further email communications from Orpyx (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every broadcast e-mail that is sent to you by Orpyx. If, at any time, you prefer not to receive any other form of communication from Orpyx, you will have the ability to unsubscribe from such communications by contacting us at email@example.com.
4. Disclosure of Your Personal Information
We may disclose your personal information to third parties that are related to us (subsidiaries and affiliates), and to third parties that we have entered into agreements with (service providers).
We may disclose personal information to third parties in order to:
- Craft the sensory insoles (Custom or Flex), or provide any necessary customization, repairs or corrections;
- Provide support services, including maintenance of the Sites and operation of Orpyx’s data repository;
- Research and evaluate how the Orpyx Sites and technology are used;
- Evaluating the performance of the Orpyx Sites and Orpyx technology;
- Testing and validating the Orpyx Sites and Orpyx technology;
- Design and deliver promotional materials and surveys;
- Conduct marketing and business analytics activities;
- Answer customer questions about our services;
- Process credit card payments and perform billing services;
- Provide other specialized services, as disclosed to you at the time you provide the information;
- Provide information to a prospective seller or buyer in the event of a sale or purchase of any Orpyx business or asset so that the buyer can continue to provide you with information and services
- Assist with the development and delivery of existing and new services and products; and
- Track, communicate and keep you up to date relating to any Orpyx job applications.
Orpyx only provides the personal information that these companies require to provide the services requested of them, and they are contractually prohibited from using the information for any other purpose.
Mergers and Other Major Transactions
In the event that Orpyx is involved in a transaction such as a merger, stock purchase or sale, or sale of substantially all of Orpyx assets, your personal information may be transferred to the other party as part of such transaction and in accordance with applicable law.
Legal and Regulatory Requirements; Consent
Orpyx may disclose personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by applicable law.
To Protect and Defend Safety or Other Rights
In addition, Orpyx reserves the right to disclose your personal information based on the good faith belief that such action is necessary or appropriate to: (a) protect and defend the rights or property of Orpyx; or (b) act in urgent circumstances to protect the safety or security of the public or of users of Orpyx products and/or the Site.
5. Storage and Retention of Your Personal Information
- We store and process personal information in Canada, the USA, or both.
- Your personal information will be subject to applicable foreign laws while it is being stored or processed in such country, which may permit government and national security authorities to access information in certain circumstances. Please contact us at firstname.lastname@example.org for more information about Orpyx's policies with respect to these practices and to answer any questions you may have about how these practices may impact you.
We store your personal information until:
- We no longer need the information for the purpose(s) it was collected;
- All legal requirements related to the data, including legal retention periods, have been fulfilled
- You ask us to delete the data. Note that if we require the data to fulfill certain business functions, or to comply with law, we are not able to delete the data even if you ask us to.
6. Protection of Your Personal Information
- Orpyx and its subcontractors that collect, store or use personal data use safeguards to protect your data.
- Safeguards include physical, technical and administrative procedures that are intended to limit access to personal data only to those who need that access to perform legitimate functions.
- We review our safeguards regularly to evaluate how they are working, and to determine if safeguards need to be added or changed.
- Even with all the safeguards, transmission of information is not always secure, and sometimes safeguards can be defeated. While Orpyx works hard to protect your personal information, we cannot guarantee the security of the transmission of information via our Site.
- You are also responsible for protecting against unauthorised access to your account on any Orpyx Site. Orpyx recommends that you use strong password security, by using a mix of letters, numbers and symbols, and a different password for your Orpyx account than you use for any other accounts that you may have. Keep your account information password confidential and do not share it with anyone. Orpyx is not responsible for any lost, stolen or compromised passwords or for any access to your Orpyx account from unauthorised users due to user negligence, or the negligence or malfeasance of external entities that are not related to Orpyx. Users are responsible for securing their own means of access to Orpyx services. If you think your account has been compromised, please contact us as soon as you can at email@example.com.
If you have any questions about the security of personal information collected by Orpyx, please contact us at: firstname.lastname@example.org.
7. Cookies and Other Tracking Technologies
- Cookies are small data files that are sent to your browser and placed on your computer's hard drive when you visit a website.
- You may be able to adjust your browser settings to block cookies or to notify you before a cookie is set. Please refer to your browser Help instructions to learn more about cookies and how to manage their use.
- Some of the services provided by Orpyx may require cookies to work properly.
- If you block cookies, certain functionalities of the Sites or the App may not be available to you, and Orpyx may not be able to provide some services to you.
- We use Google Analytics, which uses unique device identifiers to analyze traffic on the App, Dashboard and website. For instance, Google Analytics tells us how many people have used the Sites, how they move through the Sites, and how long they spend on each area of the Sites.
- We may use anonymized (not personally identifiable) information for medical research, market research, and other business purposes. Orpyx may use a third-party service provider to conduct the research or other business activity. Neither Orpyx nor the third party will attempt to re-identify the anonymized data.
8. California Requirements
California Consumer Privacy Act (CCPA)
- Orpyx is not subject to the CCPA. However, Orpyx seeks to protect the privacy of individuals who visit the Sites, use the App, and conduct business with Orpyx.
- Orpyx never sells individually identifiable data.
- Orpyx provides individually identifiable data to third parties:
- So that the third party can provide services related to fulfilling the business transactions requested by you;
- To support your healthcare provider in providing healthcare services to you; and
- Some third-party websites keep track of your browsing activities when they serve you content; this allows them to customize ads to your interests.
- Your internet browser has a "Do Not Track" feature which, when turned on, sends a signal (the "DNT signal") to websites and applications that indicates the user does not want to be tracked.
- Orpyx does not track visitors across websites if it receives a “Do Not Track” signal from the user’s browser. The Orpyx App does not respond to “Do Not Track” signals.
- You can learn more about Do-Not-Track at https://allaboutdnt.com/.
9. Children’s Privacy
Orpyx recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests.
- The Sites are not intended for children under the age of 13.
- Orpyx does not target its services or any Site to children under 13.
- Orpyx does not knowingly collect personal information from children under the age of 13.
- If you believe Orpyx has collected personal information from a child under the age of 13, please notify Orpyx so we can remove it.
10. Access and Accuracy
- Orpyx makes every reasonable effort to provide access to your personal information if you request such access in writing to email@example.com.
- Orpyx will endeavor to respond to an individual's request for information within 45 days of receiving the written request and will indicate whether the individual is entitled to access the information.
- Please note that we must be sure that the individual requesting access has the right to receive the information. We cannot provide access if we cannot confirm that the requester is either the individual to whom the information relates, or an authorized agent.
- If access is refused, Orpyx will provide reasons for the refusal, the name of the person who can answer questions about the request and advise of the right to have the decision reviewed by the applicable authority.
- Orpyx uses commercially reasonable efforts to ensure that personal information in our possession is accurate and complete.
- If you are aware of an error in personal information about you that is under our control, please let us know and we will correct it on request whenever possible.
- In some cases, Orpyx may ask for a written request for correction.
- We may take reasonable steps to verify your identity before granting access or making corrections.
12. Questions or Comments
Orpyx Medical Technologies Inc.
Suite 205, 1240 – 20th Avenue S.E., Calgary, AB T2G 1M8
Original Effective Date: February 6, 2012
Last Updated: July 4th, 2023