Our Commitment To You

At MD Connected Ltd. (the “Company”, “we”, “us”, “our”), the privacy of its users, consumers, clients, service providers, distributors, retailers, suppliers and other individuals (“you”, “your”) is a top priority. Your privacy is at the core of the way we design and build the services and products we provide to you. We appreciate that you put your trust in us when you provide us with your personal information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We strive to be transparent in the way we process your data. We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your personal information.

Privacy Policy

This Privacy Policy (the “Privacy Policy”) sets out the privacy policies and practices for the Company with respect to how the Company collects your personal information. It also describes how the Company uses, maintains, retains, transfers and discloses your personal information. This Privacy Policy applies to information collected from you by the Company via https://www.mdconnected.ca/ and our mobile applications (collectively, the “Platform”) and other places where, or means by which, we may collect personal information. This Privacy Policy also sets out how you can access certain information that the Company may collect about you and explains the choices you have regarding any collection, use, maintenance, retention, transfer and disclosure of such information, and how you may access or correct that information. In this Privacy Policy, “personal information” means any information about an identifiable individual or information that allows an individual to be identified, as defined from time to time in applicable privacy legislation. Personal information does not include business contact information such as your name, title or position, business address, telephone number, facsimile number or e-mail address.

Your Consent

BY SUBMITTING PERSONAL INFORMATION TO US, YOU AGREE THAT WE MAY COLLECT, USE, MAINTAIN, RETAIN, TRANSFER AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent at any time by contacting the Company’s Privacy Officer at the address provided below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you, or continue to provide you, with certain services, products or information. You are responsible for ensuring the accuracy of the personal information that you submit to us. Inaccurate information will affect your experience when using the Platform and our ability to contact you as described in this Privacy Policy.

Amendments of This Privacy Policy

We may change, modify, add or remove portions of this Privacy Policy at any time and from time to time, without prior notice to you. We will treat your continued use of the Platform following such change, modification, addition or removal as your acceptance of such revisions. All revisions will be posted on the Platform and will apply to any personal information collected on or after the date posted. We will obtain the necessary consents required under applicable privacy laws if we seek to collect, use, maintain, retain, transfer or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.

This Privacy Policy was last updated on June 1, 2023.

Collection of Your Personal Information

We are the controller and the responsible party for your personal information. We may collect personal information in connection with your use of the Platform or with your use or purchase of the Company’s products and services, which may include personal information provided in connection with your use of the Platform.

When you use our Platform, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our Platform. The personal information that we may collect may include:

1. Information you provide to us when you are:

   1. Registering for a MD Connected account, you provide us with your name, e-mail address, your age, your health records, government issued identification, your physical or mental health and health history of your family. By choosing to provide this information, you consent to our processing of that information;
   2. Participating in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials;
   3. Registering or filling in forms on the Platform;
   4. Purchasing any product or service from the Company and/or when you subscribe to a paid service or make a purchase directly from us (rather than through a third-party platform), you provide us or our payment service provider with information, such as your credit card and debit card numbers (with expiration dates and CVV) or other financial information. We use Transport Layer Security (TLS) encryption technology to encrypt sensitive personal information (such as your payment information) before it travels over the internet. Credit card numbers are never stored on our database or servers; however, we use third-party providers to process any payments made by you and such third-party providers may store your personal information on their databases and/or servers;
   5. Reviewing any product or service from the Company or from another user of the Platform;
   6. Participating in our promotions, events or contests and in such instances, we collect the information that you use to register or enter;
   7. Requesting for us to communicate with or otherwise process information of other people and in such instances, we collect the information about others that you give us in order to complete your request. If you provide us with personal information of another individual, you represent to us that you have that individual’s consent to allow us to collect, use, maintain, retain, transfer and disclose that personal information in accordance with this Privacy Policy;
   8. Requesting information or assistance from the Company. This includes information you may provide when you request additional information about the Company’s products and services or sign up to receive the Company’s e-mail newsletters or coupons. The Company may also keep a copy of any communications or correspondence you may send to it, including any e-mail communications; and
   9. Using other features, including Interactive Functions (as such term is defined in the Platform’s Terms and Conditions of Use (the “Terms and Conditions”)) of the Platform that may be offered from time to time, and may require such information in order to utilize the feature (including but not limited to making a User Submission as defined in the Terms and Conditions);

2. Information others provide to us about you. We will apply this Privacy Policy to any personal information received from third parties, unless we have disclosed otherwise. In addition to the information you provide to us directly, we may receive information about you from other parties, for instance:

   1. Other users may provide information about you as they use our products and services. We may also collect information about you from other users if they contact us about you; and
   2. We may receive personal information about you from our affiliates or service providers. We may supplement the information we collect about you through the Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google Ad Network and Facebook Ad Network may tell us which ads about the Company you clicked on.

3. Information collected when you use the Platform. When you use our Platform, we collect information about which features you’ve used, how you’ve used them and the devices you used to access our Platform, for instance, we collect information:

   1. About your activity on our Platform (for example, date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on, etc.) and how you interact with other users (for example, users you connect and interact with, time and date of your exchanges, number of messages you send and receive, etc.) and your relationship with such users;

   2. About the device(s) you use to access our Platform including:

      • hardware and software information such as manufacturer, model, IP address, device identification and type, operating system and identifiers associated with cookies or other technologies that may uniquely identify your device or browser (such as, IMEI/UDID and MAC address);
      • information on your wireless and mobile network connection such as, your service provider and signal strength and information on device sensors (such as accelerometers, gyroscopes and compasses);

   3. From the device(s) you use to access our Platform including your:

      • device-specific and application settings and characteristics, application crashes, advertising IDs (such as Google LLC’s AAID and Apple Inc.’s IDFA), browser type, version and language, time zones, etc.; and

   4. Other information with your consent such as:

      • your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, magnetic field sensors, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the Platform if the permission you gave us expressly permits such collection;
      • your photos, images and videos (for instance, if you want to publish a photo, video or streaming on the Platform); and
      • any other personal information that you choose to include in your account, your User Submissions (as defined in the Terms and Conditions) or in other communications to the Company.

We may collect personal information even when you are not using the Platform. We may combine personal and non-personal information about you collected by us or by our affiliates, retailers, distributors and other third parties with whom we have a relationship, and we may combine this information with information from external sources.

In obtaining your consent to collect, use, maintain, retain, transfer and disclose your personal information we will use reasonable efforts to inform you of the purpose for which personal information will be collected, used, maintained, retained, transferred or disclosed. The form of consent may vary depending on the circumstances and type of information disclosed. We will take into account the sensitivity of the personal information and your reasonable expectations when determining the appropriate form of consent.

Online Communications

You may voluntarily submit personal information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, registering for an account, purchasing a product or service, reviewing a product or service provided by the Company or by another user of the Platform, receiving a review of your product or service from another user of the Platform, subscribing to a newsletter or a mail or e-mail list and participating in contests and surveys. If you are a registered user on the Platform, we may combine and store personal information about your use of the Platform and information you have provided to us with certain other online and offline information we may have collected.

E-mail Communications

We may send you marketing or promotional e-mail communications. In this process, we may collect certain information such as the date and time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of instances you click through our articles and your total click-through activity on the contents of our e-mail communications. We may also combine and store any such information to manage and improve our e-mail communications. If you no longer wish to receive any future marketing or promotional material from us, our promotional e-mail communications will include instructions on how to unsubscribe and inform us of your preferences.

Cookies

We aim to provide a secure Platform and to improve our Platform for you, including by remembering your preferences, recognizing you when you visit our Platform and personalizing and tailoring ads to your interests. To accomplish these purposes, we may use a browser feature called a “cookie” to collect information when you access the Platform. A cookie is a small text file containing a unique identification number that identifies your browser, but not necessarily you, to our computers each time you visit the Platform. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your device, such as user settings, browsing history and activities conducted while using our Platform. We also may link information from cookies with other personal information we hold about you. In addition to the purposes described in our Privacy Policy, we may use such personal information and share it with third parties with whom we have a commercial relationship to measure the use of the Platform, to improve the functionality and content of the Platform and to simplify your usage of the Platform.

We also use similar technologies for example, web beacons, Facebook Pixel and cookies that other third-party ad-networks use, that enable us to recognise when someone has visited our Platform or opened an e-mail that we have sent them. For simplicity, we also refer to these technologies as “cookies” in this Privacy Policy.

There are different types of cookies including:

1. First-party cookies which are cookies placed on your device directly by us;
2. Third-party cookies which are cookies placed on your device by our affiliates and service providers;
3. Session cookies which only last until you close your browser or exit the Platform. We use session cookies for various reasons, including to learn more about your use of our Platform during one single session and to help you to use our Platform more efficiently; and
4. Persistent cookies which have a longer lifespan and are not automatically deleted when you close your browser or exit the Platform. These types of cookies are primarily used to help you quickly sign-in to our Platform again and for analytical purposes.

When you use our Platform, some or all of the following types of cookies may be set on your device:

1. Essential website cookies: we use such cookies to provide you with the products and services available on our Platform and to use the features of our Platform;
2. Analytics cookies: we use such cookies to understand how you use our Platform and how effective our marketing campaigns are and help us customize and improve our Platform for you;
3. Advertising cookies: we use such cookies to make our advertising messages more relevant to you for instance by preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on your interests and measuring the number of ads displayed and their performance; and
4. Social networking cookies: we use such cookies to enable you to share pages and content that you find interesting on our Platform through third-party social networking platforms and other websites and applications. We may also use these types of cookies for advertising purposes. Depending on your social media account settings, we automatically receive information from the social media platform. To learn more about social media cookies, please refer to your social media platform’s cookie policy and privacy policy.

Unless you specifically inform us (for instance, by sending us correspondence from the Platform), we will not know who you are. You can reset your browser either to notify you when you receive a cookie or refuse to accept cookies. If you refuse to accept cookies, you may not be able to use some of the features available on the Platform.

We would like to provide you with some information about controlling your cookie settings. Some web browsers allow you to control or reject cookies or to alert you when a cookie is placed on your computer. Please review the specific steps involved for such settings in your particular browser help menu as each browser uses different procedures. You also may be able to reset device identifiers by activating the appropriate setting on your device. The procedure for managing device identifiers is slightly different for each device so please review the specific steps in the help or settings menu of your particular device. With respect to interest-based advertising tools, you may opt out of seeing online interest-based advertising from participating companies by using the following applications: (a) the Digital Advertising Alliance; (b) the Interactive Digital Advertising Alliance; or (c) Appchoices. Please note that opting out does not mean you will not see any advertisements; it only means that you won’t see personalized advertisements from the companies that participate in the opt-out programs. Lastly, if you delete cookies on your device after you opted out, you will need to opt-out again.

Third Party Websites

We may also include links to other websites on the Platform or in our e-mail communications. These third-party websites may collect your personal information and they may have different privacy policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the third parties operating these third-party websites. We strongly encourage you to read the privacy policies of these websites to enable you to make an informed decision whether or not to provide your personal information to these websites’ operators.

We may disclose your personal information to Stripe, Inc., PayPal, Inc. and their respective affiliates to:

1. Prevent, detect, mitigate and investigate potentially illegal acts, fraud and/or security breaches, and to assess and manage risk, including to alert you if fraudulent activities have been detected on your account;
2. Store your personal information;
3. Provide customer service, including to help service your account; and
4. Facilitate the processing of payment cards and payments when you pay for our products or services and we use the services of Stripe, Inc. and PayPal, Inc. to process your payment.

Please review the privacy policies of Stripe, Inc. and PayPal, Inc. as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of Stripe, Inc. and PayPal, Inc.

Third-Party Analytics

To evaluate the usage of the Platform, we use automated devices and applications provided by third parties, such as Google Analytics. We use these tools to help us improve our products and services, our performance and user experiences. These entities may: (a) use cookies and other tracking technologies which collect information to perform their services; and (b) collect personal information directly through the use of cookies and other tracking technologies. Please go to these third-party websites to learn more about their privacy policies. If you wish to opt out of Google Analytics data collection, please use the Google Analytics Opt-Out Browser Add-On.

IP Addresses

An IP address is a device’s numeric address, by which it can be located within a network. We may record your IP address when you visit the Platform. We may use your IP address to: (a) help diagnose problems with the Company’s server; (b) administer the Platform; (c) identify you when we believe it is necessary to enforce compliance with this Privacy Policy or the Terms and Conditions; or (d) protect the Platform and our systems, information, employees, service providers, business partners, affiliates, users, customers, distributors, retailers and others.

Protection of Your Personal Information

To: (a) prevent unauthorized access to, or disclosure of, personal information; (b) maintain data accuracy; and (c) facilitate the appropriate use of your personal information; we use physical, technological and administrative procedures to protect your personal information that we collect from loss, unauthorized access, modification, unauthorized disclosure or other misuse. Nevertheless, internet or wireless transmissions are never completely private or secure. You understand that any messages, content or information you send or submit through the Platform may be read or intercepted by others. If you have any questions about the security of your personal information collected by us, please contact the Company’s Privacy Officer at the address below. The only employees, who are granted access to your Personal Information, are those with a business need-to-know’ or whose duties reasonably require such information.

Use of Your Personal Information

Once we collect your personal information, we may use such personal information internally, separately or in combination with any pre-existing information for the following purposes:

1. To provide our products and services to you, including:

   1. To administer your account;
   2. To assist with billing and the collection of accounts;
   3. To provide you with transaction receipts;
   4. To process and fulfill your purchases, including to send you e-mails to confirm your purchase status, and other related e-mails;
   5. To develop, enhance, market, sell or otherwise provide information, products or services;
   6. To contact you and to respond to any communications that you may have had with us;
   7. To conduct or administer contests, sweepstakes or other promotions in which you have participated; and
   8. To distribute our newsletters and other informational e-mail communications and other material to individuals on our mail and e-mail lists;

2. To connect you with other users of the Platform, including:

   1. To show users’ accounts to one another; and
   2. To enable you to purchase and review the products or services of other users of the Platform or to receive reviews of your products or services from other users of the Platform;

3. To ensure consistent experience with our Platform across all of your devices, including:

   1. To troubleshoot problems with the Platform;
   2. To customize your experience or homepage on the Platform;
   3. To obtain your feedback on the Platform, our products and services; and
   4. To establish and conduct commercial relationships, including to process transactions and to conduct or administer other transactions that you may engage in with us;

4. To improve our products and services and to develop new products and services, including:

   1. To evaluate our service providers and their qualifications;
   2. To help us learn more about your preferences; and
   3. To conduct surveys, research, evaluations and measurement activities;

5. To prevent, detect and fight fraud or other illegal or unauthorized activities, including:

   1. To detect, and to protect the Company and other third parties against, error, negligence, breach of contract, fraud, theft and other illegal activity; and
   2. To audit compliance with our policies and contractual obligations;

6. To ensure legal compliance, including:

   1. To enforce our Terms and Conditions and this Privacy Policy;
   2. As permitted by, and to comply with, any legal or regulatory requirements or provisions; and
   3. To use, maintain, retain, transfer and disclose your personal information if the Company is required to do so by law or legal process or if the Company determines, in its sole discretion, that such action is necessary to protect the rights of the Company, third parties and other users of the Platform or to respond to your request for customer service; and

7. For our business purposes, including:

   1. To engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving the Company;
   2. To market, sell or otherwise provide products and services of third parties with whom we have a commercial relationship;
   3. To develop and manage our business and operations; and
   4. For any other purpose to which you consent.

To process your information as described above, we rely on the following legal bases:

1. The primary reason we process your personal information is to perform the contract that you have with us for instance to maintain your account, to make your account viewable to other users and recommend other users’ accounts to you;
2. We may use your personal information where we have legitimate interests to do so for example to improve our products and services by analyzing users’ behavior on our Platform and for administrative, fraud detection and other legal purposes; and
3. We may occasionally ask for your consent to use your personal information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy. You may expressly instruct that your personal health information not be used or disclosed for healthcare purposes without your consent.

Disclosure of Your Personal Information

Except as provided for in this Privacy Policy, we will not sell, rent, lease, commercially exploit or otherwise disclose your personal information or data to third parties unless: (a) we are required to do so by law or to cooperate with legal investigations; (b) it is required to protect the legal interests of the Company, including for credit checking and collection purposes or in connection with a potential financing, merger or acquisition; or (c) you provide consent to such disclosure.

Occasionally, we may disclose your personal information to:

1. Other users of the Platform. Please be careful with your information and make sure that the content you share by using our Platform is information that you’re comfortable with being shared;
2. Third party service providers or vendors: for instance, third party service providers or vendors with whom we have a contractual relationship, an organization or individual retained by us to collect outstanding debts, our financial institution and our distributors and retailers;
3. A person who, in our reasonable judgment, is providing or seeking the information as your agent;
4. Our personnel or contractors;
5. Government authorities, regulatory agencies, insurers, benefits providers, consultants or agents;
6. Professional regulators; and
7. Any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

In certain situations, we may use, maintain, retain, transfer or disclose your personal information without your knowledge or consent (as permitted or required by law). Such situations may be:

1. Where your personal information is publicly available;
2. Where collection or use of the personal information is unmistakably in your interests and consent cannot be obtained in a timely manner;
3. To investigate a breach of an agreement or a contravention of law;
4. In the event of a corporate change in control of the Company resulting from, for example, a merger, a reorganization, a sale of assets or bankruptcy;
5. To comply with a subpoena, warrant, court order or as required or otherwise permitted by law; and
6. When information is being collected for the detection and prevention of fraud or for law enforcement.

Retention of Your Personal Information

After we have collected your personal information, we may retain a record of your personal information (including correspondence or comments). We will continue to use, maintain, transfer, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as required or permitted by law. However, we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for our business purposes.

Cross-border Data Transfers

Sharing your personal information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. To increase our efficiency, we use password-protected electronic file storage on cloud servers based outside of Canada, in countries where laws regarding collection, use, maintenance, transfer and disclosure of personal information may be less stringent than the laws in Canada. We do not assume any responsibility for the privacy practices, policies or actions of such cloud server providers or of any governmental authority of the country in which such cloud servers are based.

Control of, Access to, and Correction of, Your Personal Information

If you do not want your personal information collected, used, maintained, transferred, disclosed or retained by us as provided in this Privacy Policy, you should not use the Platform and you should refrain from: (a) registering for any specific tool or application that collects personal information; and (b) purchasing any product or service from us. Further, you may uninstall the Platform from your device using the standard uninstall process for your device. If you uninstall the Platform from your device, the unique identifier associated with your device will continue to be stored by us. If you re-install the Platform on the same device, we will be able to re-associate this identifier to your previous transactions and activities. You may also use tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the Platform. Lastly, devices have permission systems for specific types of device data and notifications, such as address book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Please note that changing such device settings may result in your loss of full functionality of the Platform.

You may request a copy of the personal information which you have provided to us by advising our Company’s Privacy Officer at the address provided below. If you have any questions or enquiries relating to our privacy practices or procedures, or if you believe that the personal information that the Company holds about you is not accurate, complete or up-to-date, you may write to the Company’s Privacy Officer at the address provided below. If you are able to establish that the information is not accurate, complete or up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up-to-date. We may ask you to provide proof of identity before we can answer the above requests.

We will attempt to respond to each of your written requests not later than 30 days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada and/or the Information and Privacy Commissioner of Ontario in respect of this time limit.

We will not charge any costs for you to access your Personal Information in our records or to access our privacy practices without first providing you with an estimate of the approximate costs, if any.

Non-Canadian Users

If you are located outside of Canada, please note that the information you provide to us will be used, maintained, retained, transferred and disclosed in Canada, where laws regarding use of personal information may be less stringent than the laws in your country. By using our Platform, you consent to such use, maintenance, retention, transfer and disclosure. You also consent to the adjudication of any disputes arising in connection with the Platform, this Privacy Policy and the Terms and Conditions in the Federal Court of Canada and the courts of the Province of Ontario.

Questions or Comments

We welcome questions and comments about this Privacy Policy. If you wish to access, verify and/or amend your personal information or make a complaint under this Privacy Policy, please contact the Company’s Privacy Officer at: privacy@mdconnected.ca.