Privacy Policy
Effective date: January 11, 2024.
Updated: January 16, 2025
Mutuo Health Solutions ("us", "we", or "our") operates the https://mutuohealth.com website (hereinafter referred to as the "Website") and provides applications and solutions for healthcare providers (Services). We are committed to protecting your personal information and complying with applicable data protection and privacy laws. This “Privacy Policy” tells you how we do so.
We will update this Privacy Policy as necessary. Please check it regularly.
1. What information do we collect?
Personal Information
While using our Service, we may ask you to provide us with certain personally identifiable information that can
be used to contact or identify you ("Personal Information"). Personally identifiable information may include, but
is not limited to:
• Email address
• First name and last name
• Cookies and Usage Data
Patient Information
Through the Services, Mutuo Health collects Patient Information in three ways:
• It will create a word-for-word transcript of the dialogue between the patient and their physician
during their appointment, using voice recognition software and other technologies.
• It will create an audio recording of the appointment with the physician.
• It will collect limited Patient Information directly from the patient’s physician and/or their office staff
for the purposes of verifying their identity.
All of the Patient Information that we collect will be handled in accordance with this Privacy Policy.
Usage Data
We may collect information on how Mutuo Health’s Services are accessed and used ("Usage Data"): this would
be the visitor for the Mutuo Health Website, and healthcare provider users when accessing the Services. This
Usage Data may include information such as the website visitor/ Service user’s computer's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our Service that the user visits, the time
and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies and Website Data
Unless you opt-out, the Website uses “Cookies” and other automatic data collection technologies with your
consent to collect personal information whenever you visit or interact with the Website, including unique
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identifiers and preference information such as IP address, technical usage, browser type, time zone settings,
language preferences, operating system, unique device identifiers, search history, page response times and
length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online
interactions.
These Cookies help us understand how you use the Website and interact with the content of the Website in
order to make improvements. We also may use these Cookies to promote our services through marketing and
advertising.
Some of the information mentioned above that are collected by Cookies can constitute personal information of
the person visiting the website. You can opt out of Cookies or prevent third-party websites from accessing our
Cookies through the privacy settings on your browser. However, opting out of our Cookies may disable some of
the Website’s features, and may prevent us from providing you with the information and services you have
requested.
Direct Marketing
If you sign up to receive direct marketing or promotional communications from Mutuo Health, we will collect your
name, email and any other information you may provide to inform you about Mutuo Health products and services.
2. Why do we use personal information?
Patient Information collected and processed by the Services
Patient Information is used by the Services in the following ways:
• At the conclusion of each appointment, AutoScribe uses the transcript from that appointment to generate
an information handout for the patient. The information handout summarizes the discussion between the
physician and patient during the appointment, including any action items that were discussed. The
information handout can be printed and provided to the patient or sent to the patient by email, with the
patient’s consent.
• Mutuo Health analyzes each appointment transcript using machine learning, in order to automate and
support the physician’s clinical documentation of the appointment. Learning required authorization from
the practitioner and, in the case of some Services such as AutoScribe Express, information may be deidentified prior to analyzing. Appointment transcripts are also used to maintain and improve the quality
and effectiveness of the Services and to develop new services and features for its users. It is up to the
healthcare provider to collect consent or use the appropriate tool in compliance with applicable privacy
laws.
• Mutuo Health uses the appointment audio recordings generated by the Services solely to confirm the
correctness and completeness of appointment transcripts and does not retain any copies after deletion
in accordance with its service agreement with the Data Controller.
• Mutuo Health may also use Patient Information if required by law, for instance to prevent fraud or to
comply with legal requirements.
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Personal Information
Mutuo Health Solutions uses the collected Personal Information for various purposes:
• To provide and maintain our Website and Services.
• To notify you about changes to our Website and Services.
• To allow you to participate in interactive features of our Services when you choose to do so.
• To provide customer support.
Tracking Cookies and Website Data
Mutuo Health Solutions uses Tracking Cookies and Website Data:
• To provide and maintain our Website.
• To gather analysis or valuable information so that we can improve our Website.
• To monitor the usage of our Website.
• To detect, prevent and address technical issues.
3. Who do we share the personal information with?
Patient Information collected and processed by the Services
Mutuo Health may share Patient Information with entities that provide services to us where the entities are under
contract to process on our behalf. Our service providers are permitted to use Patient Information only on our
instruction. Our contracts ensure they comply and not use your personal information for their own purposes. They
are also required to take appropriate measures to protect the Patient Information.
Mutuo Health will not disclose Patient Information to anyone else, except with the Data Controller’s authorization
or as required or permitted by law. We will never sell or rent Patient Information.
Personal Information Tracking Cookies and Website Data
We only share your personal information with service providers to operate the Website and the Services. This
includes sharing information for fraud prevention, payment processing and notifications, providing requested
services or information, operating the Website and Services, and customer service.
We only use service providers who ensure a comparable level of protection for your personal information. Our
contracts with our service providers ensure they comply with that obligation and not use your personal
information for their own purposes.
We may be required to disclose your personal information to law enforcement agencies if they demonstrate the
legal authority to request it.
We may also disclose your personal information in connection with a corporate reorganization, amalgamation, or
sale of the business (or potential sale of our business). We shall ensure that all such information disclosed as part
of such process is protected in a manner consistent with this Privacy Policy.
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We may employ third party companies and individuals to facilitate our Website, perform service-related services
or assist us in analysing how our Website and Services are used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are
obligated not to disclose or use it for any other purpose.
4. How does Mutuo Health use artificial intelligence?
Mutuo Health utilizes a third-party artificial intelligence service provider (the “AI Service Provider”) to assist in its
translation of text to speech and generation of notes. Our contract with our AI Service Provider ensures that they
only collect and process data needed to provide the services in accordance with existing agreements. They do not
have a right to retain or use Patient Information for the purposes of training an AI models. The AI Service Provider
may process the data from outside of Canada.
5. How long do we keep personal information?
Patient Information
Mutuo Health will retain Patient Information only for as long as necessary to fulfill the purposes for which it was
collected, unless otherwise permitted or required by law. For example, we will retain each audio recording of an
appointment only for as long as necessary for our customer to confirm that the accompanying transcription of the
appointment is correct and complete. After that, the recording will be securely disposed of in accordance with the
service agreement with the Data Controller.
6. How do we keep personal information accurate?
We take reasonable steps to ensure that personal information in our custody is accurate and up to date. However,
we primarily rely on the Data Controller as the healthcare practitioners to notify us of any changes to the
information they have provided.
7. How do we protect your personal information?
Mutuo Health uses appropriate physical, administrative, and technical safeguards to protect Patient Information
and Personal Information against loss, theft, and unauthorized access, disclosure, copying, use, disposal, and
modification. These security measures include restricting access to Patient Information and Personal Information
to authorized employees who need access in order to carry out their job functions, training our employees on
their privacy obligations and requiring them to sign confidentiality agreements, and encrypting Patient
Information and Personal Information while at rest and in transit.
8. Where do we store personal information?
Mutuo Health stores Patient Information securely using cloud storage provided by Amazon Web Services. All data
is retained in Canada; however, information may need to be processed and temporarily stored in the United
States.
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9. Links to third-party sites
Our Website may direct you to third-party websites, including those that advertise other products or services.
Those organizations are separate and distinct from Mutuo Health and have their own separate privacy policies.
We are not responsible for how any third party collects, uses, or discloses your personal information. Therefore,
it is essential to familiarize yourself with the privacy policies of these websites before providing your personal
information to them.
10. Direct marketing
You may sign up to receive marketing or promotional communications from Mutuo Health. Where you have
expressly consented, we may use your personal information to inform you about us and our products and our
services, including promotional offers and events.
If you no longer wish to receive marketing or promotional communications from us, you can opt out at any time
by:
• using the unsubscribe feature found in our emails and other electronic communications, or
• contacting us via email at privacy@well.company.
We will stop sending you marketing e-mails within seven (7) days of receiving your unsubscribe request.
11. Contacting us
Any questions about your healthcare practitioners use Mutuo Health’s product or services need to be directed to
your healthcare provider.
Accountability with respect to your personal information is important to Mutuo Health. If you have any questions
(including how Mutuo Health manages personal information), complaints or concerns about this Privacy Policy,
or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email to
privacy@well.company.
Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer
at privacy@well.company.
If, after contacting us, you remain unsatisfied, you have the right to file a complaint with your local data protection
authority.
12.Your rights
Based on the applicable laws of the province where you live and receive health care, you may have the following
rights over your person health information:
• updating or withdrawing your consent to the use or disclosure of personal information,
• requesting access your personal information, including your personal health information,
• requesting restrictions on our use or disclosure of your personal information,
• objecting to or making a complaint to our use or disclosure of your personal information,
• requesting that we edit or correct, but not remove, certain information (like an e-mail address),
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• requesting that we transfer to another organization the personal information you have provided us, and
• requesting deletion of the personal information we hold about you, where permitted.
Contact us at privacy@well.company to exercise any of these rights. If you request access to your personal health
information, we may refer your request to the relevant healthcare provider to comply with your request. We will
respond within 30 days. If we cannot grant your request, for example if you make an access request and providing
you access would disclose personal information about another person, we will give reasons.
We will address all requests with equal attention.
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://mutuohealth.com
Definitions
Service
Service is the https://mutuohealth.com website operated by Mutuo Health Solutions
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
· Email address
· First name and last name
· Cookies and Usage Data
Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
· Session Cookies. We use Session Cookies to operate our Service.
· Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
· Security Cookies. We use Security Cookies for security purposes.
Use of Data
Mutuo Health Solutions uses the collected data for various purposes:
· To provide and maintain our Service
· To notify you about changes to our Service
· To allow you to participate in interactive features of our Service when you choose to do so
· To provide customer support
· To gather analysis or valuable information so that we can improve our Service
· To monitor the usage of our Service
· To detect, prevent and address technical issues
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Mutuo Health Solutions legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Mutuo Health Solutions may process your Personal Data because:
· We need to perform a contract with you
· You have given us permission to do so
· The processing is in our legitimate interests and it is not overridden by your rights
· To comply with the law
Retention of Data
Mutuo Health Solutions will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Mutuo Health Solutions will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Mutuo Health Solutions will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Legal Requirements
Mutuo Health Solutions may disclose your Personal Data in the good faith belief that such action is necessary to:
· To comply with a legal obligation
· To protect and defend the rights or property of Mutuo Health Solutions
· To prevent or investigate possible wrongdoing in connection with the Service
· To protect the personal safety of users of the Service or the public
· To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Mutuo Health Solutions aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Mutuo Health Solutions relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site 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.
Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
· By email: info@mutuohealth.com