Privacy Policy

Chronically Simple Inc.

Last updated on February 12, 2020


Chronically Simple Inc. has been designed to empower its users to post, share and store medical information in one secure place. This Service, as defined below, is user-driven with various features offered to allow users to control what information is stored in their patient portal and with whom that information may be shared.

We understand that the success of our services depends on providing thoughtful, easy-to-use, secure and transparent services for your personal information, including your personal health information.In this digital world, users must be able to trust that their data will not be misused, and that companies operating in this space communicate in a simple and straightforward manner with their users.

Innomar Strategies Inc. owns Chronically Simple Inc. (together “we”, “us” and “Chronically Simple”) and owns and operates the website and mobile application (together the “Service”).

Your privacy is important to us and we are committed to keeping your information secure and confidential, in accordance with this Privacy Policy and with applicable laws. We aim to protect the security and integrity of your personal information, and to provide clear explanations about how your information will be collected, used and disclosed. We encourage you to review this policy carefully as well as any other fair notice practices while using our Service.

By signing up for an account with us or using the Service, you agree to this Privacy Policy and that we may collect, use and disclose your personal information in accordance with it. If you do not agree to the terms of this Privacy Policy, please do not use the Service.

What is Personal Information?

“Personal information” is any information about an identifiable individual, whether alone or in combination with other information, including, but not limited to, contact information, name, address, phone number or email address, gender, date of birth, and any data about yourself that you choose to provide through the Service. See table below for more details.

“Personal health information” includes, for example, information relating to your physical or mental health, as well as your health history, medical records, prescriptions, and your health number (“personal information” and “personal health information” collectively referred to as “Personal Information” in this policy).

What Personal Information can we collect and for what purpose?

Our Service is designed to help you store, organize and share your medical information or the medical information of your loved one for whom you are a care-giver. We require very little Personal Information from users to register for the Service but we provide a secure platform where you can store as much Personal Information as you would like. Below is an easy-to-read table that categorizes the different kinds of Personal Information you can upload and store about yourself or your loved one and, where applicable, the purpose for which we may use that Personal Information.


Profile Data


First name, last name, gender, date of birth, country of residence.


Verify your identity.

Allow our Help Desk access to assist you with any troubleshooting needed.

Register for an Account


Contact Data


Address, email address, emergency contact information, mobile phone number.


Verify your identity.

Allow our Help Desk access to assist you with any troubleshooting needed.

Allow invited care team members to contact emergency services on your behalf if required


Financial Data


Last three digits of your credit card, security code and expiry date, billing address, expenses (e.g. parking receipts, medical device receipts, insurance submissions), date of expense transactions.


Process billing and administration of the Service.

Allow users to store and track medical expenses.


Sensitive Data / Personal Health Information


Health Card number.

Description of your concerns/symptoms, your diagnosis, allergies, blood type, appointment notes.

Symptom tracking and symptom history, including environmental factors.

Clinic and clinician name and location; appointment dates, times and locations.

Physician specialty, supporting health care professional name and type (e.g., physiotherapist, medical device provider, personal support worker) and contact information and address. This list may be amended from time to time and you can see the current list by checking the Website and this Privacy Policy.

Care team name and contact information, relationship to user.

Insurer, health insurance policy number and claim submission information and history.

Lab and diagnostic test results, scans, physician orders.

Medication name and Drug Indentification Number (DIN), dosage, prescribing physician name, name, address and contact information of pharmacist and dispensing pharmacy.


Allow users to store, manage and share medical information.

Conduct research, statistical analysis, survey/demographical information and other data analysis based on the data collected from your use of the Service (de-identified information, or where you have explicitly consented, identifiable information).

Aggregate report on outcomes, efficacy, adherence, co-pay, reimbursement, patient support program design and share or publish studies and research with Health Canada, other research partners and interested parties, including pharmaceutical manufacturers and insurers.

Understand how a treatment works in real-life with people such as yourself so as to help provide aggregated insights into the patient journey, the impact of chronic illness and to assist to improve Canadian patient access to pharmaceutical products.

We may share aggregate insights and research with Health Canada, other research partners, and interested parties, including pharmaceutical manufacturers and insurers.


Technical Data


Browsing behaviour, IP address, type of mobile device used, your device’s operating system.


Improve the content of our Service and to create a better experience for users of the Service.

Allow you to manage the Service and products.

Allow our Help Desk access to assist you with any troubleshooting needed.

Analyze and evaluate the effectiveness of our Service, including usage data, location data, cookies and other similar technologies to track activity through service providers such as Google Analytics.

Allow our Help Desk access to assist you with any troubleshooting needed.


Marketing and Communications


Opt-in preferences to receive marketing, and non-transactional messages from Chronically Simpe.


Provide you with communications, special offers and general information about the Service, including electronically, if you have consented.

Provide opportunities for participation in market research or educational initiatives in your area.

Aggregated and de-identified information

Your Personal Information may be de-identified and in some cases aggregated with de-identified information from other users. De-identified information is any data that has been collected in which all personal identifiers have been removed, such that the information could not reasonably be used to identify an individual. De-identified information is not considered Personal Information.

As noted above, de-identified information may be used to assess various factors, including trends in health, outcomes, efficacy, co-pay and reimbursement, adherence and compliance rates, which are useful to understand and improve upon health care services and delivery. We may also use or disclose your de-identified information for research purposes, reporting/publication, for promotion, to ensure the functionality of our systems and/or to determine whether improvements to the Service are required.

Contacting you

You understand that we may contact you in connection with the administration of the Service and you agree to be contacted by us regarding the Service including to provide updates of this privacy policy, send you newsletters if you subscribed and to administer your account.

You may update your preferences or withdraw your consent at any time. If you require assistance in cancelling your subscription please contact Please be advised that the withdrawal of your consent or authorization will not be retroactive. With your consent and in accordance with your preferences, we may send you push notifications regarding your medication schedule, disease education or other information you have indicated you would like to receive.

How do we collect your Personal Information?

We collect Personal Information in the following ways:

Information you give us
We collect personal information from you when you, for example:

- Register for an account and interact with our Service
- submit medical records and other health information to our Service including symptoms, appointment notes, patient preferences and habits;
- interact with your invited team members through our chat feature;
- contact our customer support services; and,
- participate in market research or educational initiatives.

Information others give us about you
We collect and store Personal Information others give to us about you. For example, we collect Personal Information when the Care Team members you have invited to your community on the Website or the App post information about you.

With whom do we disclose your Personal Information?

We have relationships with different service providers and Chronically Simple affiliates who help us provide the Service to you; to administer our business, including administrative and billing matters; and design, maintain and improve the Service and our systems and computer security. For example, we use Google Cloud to store your Personal Information and Stripe to store your financial information and process any payments. We may also use service providers to analyze de-identified data collected on the Service as well.

To the extent we disclose your Personal Information to our service provider for the purposes in the Privacy Policy, they will only be permitted to collect it or use it for purposes that are consistent with this Privacy Policy, legal agreements they enter into us, and applicable privacy laws.

In order to facilitate our provision of the Service to you, your Personal Information may be used, stored and/or disclosed to an affiliate or a service provider outside of Canada. All such information will be protected in accordance with this Privacy Policy. However, your Personal Information would be subject to the laws of the country to which it is transferred and stored. See the section on International Data Transfers for more information.

Chronically Simple collects, uses and discloses your Personal Information without your consent only in limited circumstances as permitted by law. For example, Personal Information may be used or disclosed without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. Under certain circumstances, we may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court order). We will cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information.

We will obtain your consent before collecting, using or disclosing your Personal Information for new purposes unrelated to the purposes described in this Privacy Policy.

Do we collect the Personal Information of children?

The Service is only to be used if you are over the age of 18. The Service is not directed or marketed at children under 18. Children under the age of 18 are not allowed to register with or use the Service or provide their Personal Information without a supervising adult. Any Personal Information that is provided during the registration process that does not result in an active account is automatically deleted from our servers. Should you choose to store the Personal Information of a minor on the Service, you do so at your own risk.

International data transfers

Your Personal Information is stored on servers located in Canada. If your Personal Information is transferred outside the jurisdiction in which you are situated, it may become subject to the laws of the receiving jurisdiction, which may differ from the laws of your jurisdiction. By using our Service, you consent to the transfer of your Personal Information outside of your jurisdiction for the purpose of storing your Personal Information or processing it.

Our security safeguards

We are committed to protecting the security of your Personal Information. We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use your Personal Information. We apply security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making Personal Information accessible only to authorized employees on a need-to-know basis. Our security practices include encryption and a 2-step user authentication and verification process to activate your account.

While every effort has been made to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk from unauthorized access.

Although we will make reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems.

Links to Other Websites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit.We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services

Cookies and other similar technologies

Chronically Simple uses cookies and other related technologies. Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. They enable us and our affiliates to remember you when you are using that computer or device to browse websites and online services. Cookies and other similar technologies are also used to manage a range of features and content as well as storing your online or in-app searches and presenting personalized content including advertisements.

When accessing our website, you will be given the option to consent to the use of cookies while you access our Service. You may not be able to take full advantage of our website if you decide not to allow the use of cookies and other technologies.

Several cookies and other technologies we use last only for the duration of your website or App session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Service and will last longer even after you stop browsing our site or exit the App.For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies or share your advertising ID with companies like ours or our advertising service providers. For information on controlling your mobile choices, you can visit

Deleting Cookies
You can delete cookies or adjust your browser settings to notify you when a cookie is sent. Please consult your browser's help menu for instructions. Visiting our website with analytics cookies disabled will have no significant impact on your browsing experience.

Web server analytic
The web servers we use automatically collect information, including but not limited to the IP address of the computers that access our site, the browser type, and the pages viewed on the website. An IP address is a number that is assigned to your computer when you access the internet. We use this information in aggregate form to understand how our site is used and how we can better serve our users.

Google Analytics
Google Analytics uses third-party cookies containing a unique identification number that recognizes your computer’s browser when you visit our website. This is done to collect and generate information (including your IP address) about your visits to our website. This information is then transmitted to the Google server in an anonymous form for processing.

Google uses the information to:
- evaluate your use of the website
- draw up reports on activity on the website, and
- provide other services relating to website activity and internet usage.

Google studies patterns of website activity so that we can improve the experience of visitors to our sites. The use of this tool does not allow us or our analytics service provider to identify individuals. Google currently offers a free Google Analytics opt-out tool for Microsoft Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera:

For more information about the cookies we use (and the purposes for which we use them), and how to block them, please see our Cookie Policy for more information.

Data retention

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will not retain your Personal Information for any longer than we think is necessary. When determining the relevant retention period, we consider:

- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on 'How we use your personal information' above);
- guidelines issued by relevant data protection authorities; and
- other legal purposes, including to resolve disputes.

Otherwise, we will anonymize your Personal Information unless it is necessary to comply with a legal obligation or resolve disputes. Alternatively, we will securely erase your information where we no longer require your information for the purposes collected.

Changes to this Policy

We may update this Privacy Policy from time to time by notices, other policies, guidelines and rules in response to changes in the Service or Chronically Simple’s operations, the law, and/or decisions of governmental agencies and regulators. This Privacy Policy may be updated from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

We will advise you when materials changes are made to this Privacy Policy via email, notice on our Website or by other means. The date that this Privacy Policy was last amended will appear at the top of the page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted.

Contact us

If you have any questions about this Privacy Policy or how we manage Personal Information, please contact us:
- By email:
- By visiting this page on our website: