TEN31 Healthcare – Privacy Policy and Notice of Privacy Practices

Operated by Vapendama Corporation

1. Introduction

TEN31 Healthcare is a Canadian clinical practice management platform designed to support healthcare professionals in managing clinical documentation, client information, appointments, assessments, treatment planning, reporting, and administrative activities.

TEN31 Healthcare is committed to protecting the privacy, confidentiality, and security of personal information and personal health information entrusted to our platform.

We manage personal information in accordance with applicable Canadian privacy legislation, including British Columbia's Personal Information Protection Act (PIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA) where applicable, as well as other relevant legal and contractual obligations.

This Privacy Policy explains how we collect, use, disclose, store, protect, and manage personal information.

2. Information We Collect

Depending on how our services are used, TEN31 Healthcare may process the following categories of information:

·       Personal identification and contact information, including names, email addresses, and telephone numbers.

·       Healthcare provider registration and professional information.

·       Appointment schedules, attendance records, and service-related communications.

·       Clinical intake information, assessment responses, treatment plans, progress notes, and discharge reports.

·       Billing, payment, and administrative records.

·       Account authentication information, access records, and system activity logs.

We collect and process information only as reasonably necessary to provide our services, support authorized healthcare activities, meet contractual obligations, and comply with applicable laws.

3. How We Use Your Information

Personal and health information may be used for:

·       Supporting healthcare professionals in delivering and coordinating care.

·       Managing clinical intake, assessments, treatment planning, progress documentation, and discharge reporting.

·       Scheduling appointments and sending service-related notifications.

·       Generating clinical and administrative reports.

·       Supporting authorized billing and payment activities.

·       Maintaining account security and verifying user identities.

·       Monitoring system performance, investigating security incidents, and maintaining service reliability.

·       Meeting applicable legal, professional, regulatory, and contractual requirements.

TEN31 Healthcare does not sell personal health information to advertisers or data brokers.

4. AI-Assisted Clinical Documentation

TEN31 Healthcare may provide artificial intelligence-assisted functionality to help authorized healthcare professionals prepare clinical documentation, organize relevant information, summarize treatment records, and generate draft reports.

AI-generated content is intended to assist professional judgment and does not replace independent clinical assessment, decision-making, or professional responsibility.

Healthcare professionals are responsible for reviewing, verifying, correcting, and approving AI-assisted documentation before relying on it for clinical purposes.

Where AI services involve third-party technology providers, information may be processed under applicable contractual, privacy, and security arrangements.

TEN31 Healthcare seeks to minimize unnecessary disclosure of directly identifying information when using AI-assisted features.

AI-assisted documentation is not intended to make autonomous treatment decisions.

5. Information Sharing and Disclosure

TEN31 Healthcare may disclose information when reasonably necessary to:

·       Support healthcare services requested or authorized by the individual.

·       Facilitate authorized communications between healthcare professionals and relevant service participants.

·       Support administrative, billing, and payment processing.

·       Provide secure technology infrastructure and application functionality.

·       Comply with applicable laws, court orders, or lawful regulatory requirements.

·       Investigate or respond to security incidents.

Information may be processed by authorized third-party service providers acting on behalf of TEN31 Healthcare.

We seek to limit access and disclosure to information necessary for the relevant purpose.

6. Data Storage and Security

TEN31 Healthcare uses cloud-based infrastructure, including Amazon Web Services (AWS), to support application hosting and data management.

Security measures may include:

·       Encryption of information during transmission.

·       Encryption of stored information where implemented.

·       Role-based access controls.

·       User authentication and access restrictions.

·       System activity monitoring and audit logging.

·       Database access controls and administrative safeguards.

·       Backup and recovery procedures.

·       Security maintenance and vulnerability management.

No electronic system can guarantee absolute security. TEN31 Healthcare takes reasonable measures appropriate to the sensitivity of the information and the risks involved.

7. Data Residency and Third-Party Processing

TEN31 Healthcare uses Canadian cloud infrastructure for its primary application and database hosting.

Certain supporting services, including email delivery, artificial intelligence processing, technical support, and other technology services, may involve third-party providers.

Depending on the service and its configuration, information may be processed, accessed, transmitted, or retained outside Canada.

Where applicable, TEN31 Healthcare assesses third-party service arrangements and implements appropriate contractual, technical, and organizational safeguards.

We do not represent that every category of information remains exclusively within Canada unless that has been independently verified.

8. Email Communications

TEN31 Healthcare may send transactional emails relating to:

·       Account verification and one-time passwords.

·       Appointment confirmations and reminders.

·       Informed consent requests.

·       Clinical assessment invitations.

·       Administrative notifications.

·       Other communications necessary for service delivery.

These communications may be delivered through third-party email service providers.

Email messages and attachments may be processed by the relevant provider as part of transmission, delivery monitoring, security, and troubleshooting.

Where appropriate, secure authenticated access to information is preferred over including sensitive clinical details directly in email communications.

Recipients should be aware that ordinary email may carry privacy and security risks.

9. Your Privacy Rights

Subject to applicable law, individuals may have the right to:

·       Request access to personal information held about them.

·       Request corrections to inaccurate or incomplete personal information.

·       Withdraw consent where permitted by law, subject to applicable limitations.

·       Ask questions about how their information is collected, used, stored, or disclosed.

·       Raise concerns or submit privacy complaints.

·       Request information about relevant privacy practices and safeguards.

Certain requests involving clinical records may need to be directed to the healthcare professional or clinic responsible for those records.

TEN31 Healthcare will assist with requests as appropriate to its role and legal responsibilities.

10. Data Retention and Disposal

Personal and clinical information is retained according to applicable legal, professional, regulatory, and contractual requirements.

Retention periods may vary depending on the type of record, the healthcare provider's obligations, and the purposes for which the information was collected.

Where records are no longer required, appropriate procedures are used to securely delete, anonymize, or otherwise dispose of information, subject to legal holds and applicable retention obligations.

11. Privacy Breaches and Incident Response

TEN31 Healthcare maintains procedures for identifying, investigating, containing, and responding to suspected privacy or security incidents.

Where an incident involves personal information, we assess the circumstances, sensitivity of the information, potential risks, and applicable legal and contractual notification requirements.

Affected individuals, healthcare organizations, regulators, or other parties will be notified where required by applicable law or contractual obligations.

12. Responsibilities of Healthcare Professionals

Healthcare professionals and organizations using TEN31 Healthcare are responsible for:

·       Obtaining appropriate consent and providing required privacy notices.

·       Accessing and using client information only for authorized purposes.

·       Maintaining the confidentiality of their login credentials.

·       Reviewing clinical documentation, including AI-assisted drafts.

·       Complying with applicable professional, legal, and contractual requirements.

·       Reporting suspected unauthorized access or privacy incidents promptly.

TEN31 Healthcare provides technology and administrative functionality but does not replace the professional obligations of healthcare practitioners.

13. Changes to This Privacy Policy

TEN31 Healthcare may update this Privacy Policy to reflect changes in applicable laws, technology, security practices, service providers, or platform functionality.

Updated versions will be published on our website with an appropriate effective date.

14. Contact Information

For questions, privacy concerns, requests for access or correction, or complaints regarding personal information, please contact:

Privacy Officer

TEN31 Healthcare

Vapendama Corporation

British Columbia, Canada

Email:admin@ten31healthcare.com

Website: https://ten31healthcare.com