Modern Caregiving Solutions Privacy Policy

Effective Date: September 2024

Modern Caregiving Services (“MCS”) is committed to protecting your privacy and safeguarding

your personal information in compliance with the Health Information Act (“HIA”) of Alberta.

This Privacy Commitment explains how MCS collects, uses, discloses, and stores your Personal Information, including your Personal Health Information when you use the MyHuddle mobile app or other services. Please read this Privacy Commitment carefully. By accessing, downloading or using MyHuddle, you or your substitute decision-maker consent to the collection, use, disclosure, and storage of Personal Information in accordance with this Privacy Commitment.

MyHuddle is an application designed to help users coordinate healthcare for themselves or someone they care for, it is not a medical device or a medical record.

1. Definitions

You - An individual who uses, or registers to use, MyHuddle, or a substitute decision maker on behalf of an individual. 

Patient Record(s) - A record of your Personal Health Information as defined under section (1)(1) (k) of the Health Information Act of Alberta. This includes but is not limited to diagnostic, treatment, and care information and registration information as defined under the Act. 

Personal Health Information - Any Personal Information regulated under applicable health privacy legislation, including information related to an individual’s physical or mental health, healthcare history, provision of healthcare, payments or eligibility for healthcare, healthcare provider, substitute decision-maker, health card number, or other healthcare-related personal identification numbers.

Personal Information - Any information about an identifiable individual other than business contact information used to contact the individual in their business or professional capacity. Personal Information includes information you provide to create your MyHuddle account and Personal Health Information (including your Patient Record). Personal Information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.

Services - The MyHuddle app, our website, and all Services we may offer, including but not limited to individual or group coaching and educational videos.

Health Information Custodian - MCS is not a health information custodian, and you are not required to input your health information in order to use MyHuddle.


2. Collection and Use of Personal Information

Account Creation: To use MyHuddle, you must download the MyHuddle app and create an account by providing your first and last name, email address, and password. To complete your profile, you may need to provide your phone number, and any health conditions you want to disclose. Optional information includes insurance and health card details.

Service Messages: We may contact you by email, text message, or push notification to provide information related to MyHuddle, such as appointment alerts or refill reminders. You can opt out of these notifications in the app's settings.

Technical Support: Personal Information may be required by or accessible to technical support staff to resolve issues. Our support team will resolve issues without viewing Personal Information whenever possible.

Developing and Enhancing Services: We analyze non-identifiable actions you take on the MyHuddle app to understand and improve our Services. This information is de-identified and cannot be linked back to you.

Marketing Communications: With your consent, we may use your contact details to send health-related news and offers. You can opt-out of receiving marketing messages at any time.

Satisfaction Surveys: We may use your contact details to request feedback on your experience with our Services.

Cookies: We use cookies to remember your preferences and authenticate you. You may set your browser to notify you when you receive a cookie or not to accept certain cookies. However, you will not be able to log into the MyHuddle platform without accepting authentication cookies.


3. Consent

By using MyHuddle, you consent to our collection, use, disclosure, and storage of your Personal Information in accordance with this Privacy Commitment. You can withdraw your consent at any time, subject to legal or contractual restrictions. Withdrawal of consent may limit our ability to provide you with certain Services.


4. Anonymity and Data Minimization

MCS strives to collect as little information as possible with the highest degree of anonymity per sections 57 and 58 of the HIA to perform our Services. Whenever possible, information is de-identified to protect your privacy.


5. Sharing and Disclosure of Personal Information

Patient Linking: The app's patient-linking feature allows you to share your information with another individual. You control who can view and manage your information and can revoke access anytime by amending their permissions, found in the Settings tab.

Legal and Regulatory Requirements: We may disclose Personal Information as required by law, such as in emergencies or response to valid court orders.

Third-Party Links: MyHuddle may contain links to third-party websites or platforms. These links are not endorsements, and we are not responsible for the privacy practices of these third parties.

6. Access, Corrections, and AccuracyYou can request access to or correction of your Personal Information by contacting us at info@moderncaregiving.ca. We rely on you to keep your Personal Information up-to-date and accurate. You may update your account profile in the MyHuddle app at any time.


7. Storage and Location of Personal Information

Your Patient Record is encrypted in transit and at rest and stored on third-party cloud platforms with data centers located in Canada. Third parties may temporarily view, access, use, or transfer information outside of Canada for maintenance purposes. We ensure that all information stored is always encrypted.


8. Retention

We retain Personal Information only as long as necessary to fulfill the purposes described in

this Privacy Commitment or to meet legal or regulatory requirements.


9. Safeguards

We have implemented comprehensive information security measures to protect your Personal Information. This includes written policies, security controls, and mandatory privacy and security training for our team members. While no security system is impenetrable, we use reasonable and appropriate controls to protect sensitive Personal Health Information.


10. Changes to this Privacy Commitment

This Privacy Commitment may be updated to reflect our practices or legal requirements changes. Significant changes will be communicated through the MCS platform and our website. We encourage you to review this Privacy Commitment for the latest information periodically.


11. Accountability and Governance

MCS has identified an internal privacy officer whose responsibility is to ensure compliance with the HIA and handle any questions or concerns related to health information. Additionally, privacy impact assessments (PIAs) are conducted, as required, under the HIA to assess the impact of any new or significantly modified initiatives involving health information.


12. Questions, Complaints, and Contact

If you have any questions, concerns, or need to report a privacy or security violation, please

contact our Privacy Officer at info@moderncaregiving.ca or the address below:

Modern Caregiving Solutions

c/o Privacy Officer

Rice Howard Place

10060 Jasper Ave Tower 1, Suite 2020

Edmonton, AB T5J 3R8

You may also seek advice from the Office of the Privacy Commissioner of Canada or the provincial Privacy Commissioner and file a complaint if appropriate.

Thank you for taking the time to read our Privacy Commitment. Your privacy is important to us, and we are committed to protecting your Personal Information.