PRIVACY POLICY

WELL Health Technologies Corp. and its subsidiaries and affiliates (“WELL” or “we”) are proud to offer you the apps.health site (the “Site”) and all services related to the app marketplace (the “Marketplace”). WELL is committed to protecting your personal information on the Site. This Privacy Policy tells you how we do so.

The Marketplace offers a digital forum to explore health related apps that may be stand-alone or may integrate with various electronic medical records programs or other software (“Apps”). These Apps are provided by third parties (“App Providers”) or may be offered by WELL directly. While each App Provider has agreed to a minimum set of privacy and security standards to be listed on the Marketplace and has agreed to obtain customer consents with respect to the collection, use and disclosure of personal information, each App Provider has their own unique privacy policy. It is important that you familiarize yourself with each App’s privacy policy to understand how your personal information may be used.

We update this Privacy Policy as needed. Please check it regularly.

1. What information do we collect?

To use the Site and Marketplace, we collect the personal information as set out below.

Website Access

Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Site, including unique 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 helps us understand how you use the Site and the content of the Site in order to make improvements. We also use these Cookies to promote our services through marketing and advertising.
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 Site’s features, and may prevent us from providing you with the information and services you have requested.

Apps

When you submit a form to obtain more information on an App in the Marketplace, we will collect your name, e-mail, phone number, clinic/organization you work for, information about your clinic or organization, and the province in which the clinic or organization is located. This information will be used by WELL and shared with the relevant App Providers to communicate with you and provide you with the information you requested. In some circumstances, we may collect your credit card information and billing details in order to process payments.
The App and the App Provider may collect additional personal information, and will have their own privacy policy with respect to the collection of personal information and your use of the App. It is important to review the App Provider’s privacy policy to understand how your information will be used and protected.

Developers

When you submit a form to obtain more information on integrating your EMR solution with WELL’s OSCAR McMaster Professional Edition EMR network, or indicate that you are interested in beta access to apps.health’s API documentation, we will collect your name, e-mail, phone number, company name and webpage, and information about your product. This information will be used by WELL to communicate with you and provide you with the information you requested.

Direct marketing

If you sign up to receive direct marketing or promotional communications from WELL, we will collect your name and e-mail to inform you about WELL and our products and services.

2. Why do we use personal information?

We use your personal information to:

• manage our relationship with you and provide you with the information or services you request,
• connect you with the App Providers you indicated you are interested in learning about through the Marketplace,
• conduct research and evaluate research and development on the Site and the Marketplace, including analyzing testing data to improve our services,
• communicate with you regarding inquiries for information or customer service request or employment opportunities,
• detect, prevent or investigate security breaches,
• properly invoice and charge you for requested services,
• protect our business, and
• maintain appropriate records for internal administrative purposes.

WELL reserves the right to aggregate and anonymize personal information (or other information) stored on its system and use such aggregated information as it sees fit.

3. Who do we share the personal information with?

We only share your personal information with service providers, including App Providers, in order to operate the Site and offer you the Apps or the information you request. This includes sharing your personal information for

• fraud prevention,
• payment processing,
• providing requested services or information,
• operating the Site and Marketplace, and
• customer service.

We only use service providers that ensure a comparable level of protection for your personal information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information for the services requested.
Exceptionally, as allowed or required by law, we may have to disclose your personal information to law enforcement agencies where they demonstrate they have the legal authority to request it.
If we merge with another business, we will inform you of any impact on your personal information.

4. How long do we keep personal information?

We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with applicable legal and regulatory requirements.

5. How do we keep personal information accurate?

We take reasonable steps to ensure that any personal information in our custody is accurate and up to date but we mostly rely on you to notify us of any changes to personal information you provided us.

6. How do we protect your personal information?

We use reasonable and appropriate physical, administrative and technical measures designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with WELL is prohibited and constitutes grounds for disciplinary action.
Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee no breach will ever occur.

7. Where do we store personal information?

All personal information we collect is stored on secure servers in Canada; however, personal information processed by our third-party service providers, or the personal information collected by the App Providers, may be done outside of Canada.
While outside of Canada, personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.
For more information on our service providers or where we store personal information, contact us at privacy@well.company. Any questions about a specific App should be directed to the relevant App Provider.

8. Links to third-party sites

Our Site may lead you to third party websites, including App Provider’s websites to allow you to download and use an App. These organizations are separate and distinct from WELL and have their own separate privacy policies. We are not responsible in any way for how any third-party, including the App Providers, collects, uses, protects or discloses your personal information, so it is important to familiarize yourself with the privacy policies of these websites, Apps and App Providers before providing your personal information to them.

9. Direct marketing

You may sign up to receive marketing or promotional communications from WELL. Where you have expressly consented, we may use your personal information to inform you about us and products and services offered by WELL, 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 marketing@well.company.

We remove your contact information from our marketing lists within 48 hours as soon as you unsubscribe.

10. Your rights

You also have the right to:

• rescind or withdraw your consent to the use or disclosure of personal information,
• request to access your personal information, including your personal health information,
• request us to restrict our use or disclosure of your personal information,
• object to our use or disclosure of your personal information,
• request that we edit, but not remove, certain information (like an e-mail address),
• request that we transfer to another organization the personal information you have provided us, and
• request us to delete the personal information we hold about you.

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.

11. Contacting us

Accountability with respect to your personal information is important to WELL. In the event that you have any questions (including how personal information is managed by WELL), 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. 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 are still not satisfied, you have the right to file a complaint with your local privacy authority.

Last Revised: August 15, 2021