Privacy Policy

R.I.C Diagnostics Inc., (Reproductive Immunology Canada) (“RIC”, “we”, “us”, “our”)
Effective date: [August 01, 01, 2025] • Version: 1.0

1) Who we are & scope

This Privacy Policy explains how RIC collects, uses, discloses, protects, and retains Personal Information (PI) and Personal Health Information (PHI) through our website (the “Site”), our communications, home-visit blood draws, and any telehealth or laboratory coordination we provide. We comply with PIPEDA (federal) and applicable provincial laws (e.g., PHIPA in Ontario). If you are located in Quebec, we also follow obligations applicable under Law 25.

Important: RIC is not a medical practice and does not provide diagnosis or treatment. Clinical tasks (e.g., venipuncture) are performed by registered nurses (RNs) and nurse practitioners (NPs) within their professional scope and provincial standards. Where a test requires an authorized ordering provider, an NP (within scope) or a collaborating authorized provider will order it—or it will not be performed.

2) What we collect

We collect only what we need for the purposes below.

Identity & contact – name, date of birth, address (including for home visits), email, phone.
Health-related information (PHI) – relevant medical history you provide (e.g., prior IVF/RPL/RIF history), requisitions, consent forms, test data and interpretations from labs, clinician details you authorize us to contact.
Logistics & visit data – preferred times, access notes for home visits, identity verification metadata.
Payments – transaction metadata via third-party processors (we do not store full card numbers).
Communications – messages, intake forms, consents, and preferences (including CASL marketing opt-ins).
Technical/usage – device, browser, IP, general location, pages viewed, cookies, analytics events (see Cookies).
Consents & signatures – signed/checked consent records (e.g., Mobile Phlebotomy Consent, PHI/Privacy Consent).

3) How we collect it

Directly from you (forms, emails, phone, telehealth, during home visits).
From your clinician/clinic when you authorize us to coordinate or share results.
From labs and service partners (e.g., test status/results, courier status).
Automatically via cookies/analytics when you use the Site (see Cookies).

4) Why we use your information (purposes)

Provide and coordinate services – scheduling, identity verification, venipuncture, specimen handling, lab submissions, results delivery, and (with your authorization) sharing results with your clinician/clinic.
Administrative & operations – customer support, training, quality assurance, safety, audit logs.
Payments – process fees/call-outs and manage invoices/receipts.
Compliance & legal – meet regulatory/college requirements, respond to lawful requests, prevent fraud.
Communications – service notices, appointment reminders, and (with CASL consent) educational/news emails.
Analytics & improvement – de-identified/aggregated analysis to improve user experience, services, and Site performance.
Security – detect, investigate, and mitigate security incidents.

4) Why we use your information (purposes)

Provide and coordinate services – scheduling, identity verification, venipuncture, specimen handling, lab submissions, results delivery, and (with your authorization) sharing results with your clinician/clinic.
Administrative & operations – customer support, training, quality assurance, safety, audit logs.
Payments – process fees/call-outs and manage invoices/receipts.
Compliance & legal – meet regulatory/college requirements, respond to lawful requests, prevent fraud.
Communications – service notices, appointment reminders, and (with CASL consent) educational/news emails.
Analytics & improvement – de-identified/aggregated analysis to improve user experience, services, and Site performance.
Security – detect, investigate, and mitigate security incidents.

5) Consent & your choices

We generally rely on your consent (express or implied) to collect, use, and disclose your information for the purposes above. You may withdraw consent at any time, subject to legal/contractual limits and reasonable notice, by contacting us (see Contact). If you withdraw consent, we may be unable to provide or continue certain services.

PHI sharing with your clinician/clinic requires explicit consent (you may revoke later).
Marketing (CASL) requires a separate opt-in; you can unsubscribe anytime.
We may collect/use/disclose without consent where permitted or required by law (e.g., serious safety risk, court order, investigations, or for compliance/reporting).

6) Disclosures (who sees your information)

We disclose only what’s necessary, with safeguards and contractual protections:

Laboratories (independent accredited labs) – to perform ordered tests.
RNs/NPs and clinical collaborators – to perform venipuncture, ordering (where within scope), and logistics.
Couriers & mobile services – to transport specimens within required time/temperature windows.
Payment processors – to process fees (we don’t store full card details).
IT vendors – secure hosting, email, scheduling, telehealth platforms, secure portal/document tools, analytics.
Your clinician/clinic – only with your explicit authorization (except where otherwise permitted by law).
Regulators/Colleges or law enforcement – where legally required or to address serious safety risks.
Professional advisors – legal/accounting (subject to confidentiality).
Business transactions – in the context of a merger, acquisition, or asset transfer with appropriate safeguards.

We do not sell your PI/PHI.

7) Cross-border transfers & data residency

Some service providers may store or access data outside of Canada (e.g., cloud infrastructure). When we use such providers, we implement contractual and technical safeguards appropriate to the sensitivity of the information. Data may be subject to lawful access by foreign authorities. If you have questions about data location for specific services, contact us.

8) Retention

We retain PI/PHI only as long as needed for the purposes described, or as required by law and professional standards. Health-related records are typically retained for significant periods (often up to 10 years after last entry, or longer for minors), subject to applicable provincial requirements. When no longer required, we securely destroy or de-identify the information.

9) Security safeguards

We apply administrative, technical, and physical safeguards appropriate to the sensitivity of PI/PHI, including role-based access controls, encryption in transit, secure storage, need-to-know access, staff training, vendor due diligence, and audit/monitoring. No method is 100% secure; if we detect a privacy breach that poses a real risk of significant harm, we will notify you and the appropriate privacy regulators as required.

10) Your rights

Subject to limited exceptions, you have the right to:

Access your PI/PHI and obtain a copy.
Request correction of inaccuracies.
Withdraw consent (we will explain any service impacts).
Ask questions or make a complaint about our privacy practices.

We respond to access/correction requests within 30 days (or as permitted by law). We may need to verify your identity and, in limited cases, charge a reasonable fee for copies.

11) Cookies & analytics

We use cookies and similar technologies to operate the Site, measure performance, and improve content.

Strictly necessary cookies (security, session) – always on.
Performance/analytics (e.g., GA4) – help us understand usage; we configure privacy-sensitive settings where possible (e.g., IP masking).
Marketing cookies – used only with your consent (if/when applicable).

You can manage non-essential cookies via our cookie banner and your browser settings. Disabling some cookies may affect Site functionality.

12) Home-visit specifics (mobile phlebotomy)

Before a visit, we collect necessary details (address, access notes, hazards). At the visit, our RN/NP will verify identity, obtain informed consent, and record information required for the draw, chain of custody, and lab submission. You agree to provide a safe, well-lit area, restrain pets, and disclose hazards. Staff may decline or end a visit if conditions are unsafe.

13) Telehealth & electronic communications (if applicable)

If you use telehealth, you consent to virtual care and acknowledge its limitations compared to in-person assessments. If you opt to receive information electronically (email/portal), you acknowledge inherent risks (e.g., interception, mis-delivery) and agree to keep your contact details current.

14) Children & minors

Our Site is not directed to children. For services involving minors, we obtain consent from a parent/guardian as required by law. Records for minors are kept for longer retention periods (see Retention).

15) Links & third parties

The Site may link to third-party websites or services. We are not responsible for their privacy practices. Review their policies before providing information.

16) Changes to this Policy

We may update this Policy from time to time. Changes take effect on posting with an updated “Effective date.” Material changes will be highlighted on the Site or communicated directly where appropriate.

17) How to contact us

Privacy Officer
Reproductive Immunology Canada
Email: legal@unexplainedinfertility.ca

18) Complaints

If you are not satisfied with our response, you may contact your provincial regulator or the Office of the Privacy Commissioner of Canada (OPC). In Ontario, you may contact the Information and Privacy Commissioner of Ontario (IPC) regarding PHIPA matters.