LEGAL

Privacy Policy

Effective Date: July 30, 2021

KixCare Inc. (referred to in this privacy policy as the “Company”, “us”, “we”, “our”) is committed to the confidentiality and security of the personal information we hold. The Company has developed this privacy policy to be transparent with users (“you”, “your”) about our privacy practices.Personal information is defined as information about an identifiable individual, either alone or when combined with other information. Personal information includes personal health information defined as information concerning the physical or mental health of an individual.The Company enables regulated and allied health care professionals (“Authorized Clinicians”) to provide health care services to your child. This includes gathering, storing, and processing information related to the observation, examination, assessment, care, service, or procedure that is provided by an Authorized Clinician to you or your child to diagnose, treat, or maintain the child’s wellbeing and overall health (the “Service” or “Services”).In providing these Services, the Company manages personal information, including personal health information, on behalf of Authorized Clinicians. The Company retains custody and control of the personal information as an information custodian whereas the information is stored by our third-party service providers including our electronic medical records (“EMR”) provider. Authorized Clinicians may be subject to federal and/or provincial privacy laws. To clarify, we collect personal information through our website. We are the custodian for personal health information provided by you to Authorized Clinicians in our EMR.

Please read this policy carefully as it contains important information about our privacy practices.

Our privacy policy should be read with our Terms of Use https://www.kixcare.com/terms-of-use. This policy explains what personal information may be collected, how that information may be used, disclosed and safeguarded, and how long the information may be stored by us. Unless otherwise defined in this policy, the terms used in this policy have the same meaning as in our Terms of Use.This privacy policy discusses the following topics:Collection of Personal Information and Personal Health Information Sharing Personal Information Cookies and Similar Technologies Choice/Opt-out Settings Retention of Personal Information International Transfers Safeguarding Your Personal Information Correcting or Accessing Your Personal Information Children’s Data Changes to our Privacy Policy Contact Us

Collection of Personal Information and Personal Health Information

While using our Service, you may be asked to provide the following types of personal information. The personal information is collected and stored on the Company’s systems or on the servers of the Company’s service providers. This personal information may include personal health information that is collected by Authorized Clinicians in order to provide you with Services.We describe below the categories and types of personal information collected. The list below is comprehensive but not exhaustive. We may collect additional information that is not specifically listed here.

The Company collects the following types of data:

1. Personal Information – This includes, but is not limited to, your first and last name, your child’s full name, date of birth, gender, contact information, health card number. In addition, we collect information while you browse our website, such as your IP address, browser type and device type. Finally, if you pay for Service using a credit card, we collect the last four digits of your credit card number. We rely on a third-party payment processor to collect and store your payment information.This information is used to validate your identity and prevent fraud. It is also used to manage your account and notify you about our Services. The Company may send you pertinent communications related to its Services even when you have not opted in to receiving marketing messages (e.g. account information, technical outages or changes to our Privacy Policy).The Company may also use your personal information to better understand your preferences and recommend Services that may be relevant to you or your child.

2. Personal Health Information – This includes information about your family history and your child’s health. This information includes, but is not limited to, medical history, ailment information, family medical history, and other healthcare providers within your circle of care or as you direct (e.g. family physician).This information is used to provide you with Services. Moreover, as Authorized Clinicians use this data to provide Services, this information may be subject to policies and regulations governing Authorized Clinicians and their staff, including internal Company policies as well as governing regulations from provincial and federal licensing and certification bodies.

Sharing Personal Information

Our Company will not share your personal information for any purpose to any external parties except as specified in this policy, including:

Sharing with our service providers: we employ third-party service providers (e.g. EMR, back-end data analysis, website hosting, payment processing and support) in Canada and internationally, to facilitate or provide certain services on our behalf. These third-party service providers have access to your personal information or personal health information only to perform these tasks on our behalf and are contractually bound not to disclose or use it for any other purpose.
Personalized content and advertising: we may use personal information such as browsing data to deliver customized content within the Service. If we share this browsing data with third parties, we will de-identify and aggregate the data prior to sharing. We will use personal information for advertising only when users opt in and consent to marketing activities. This personal information will never be shared outside of the platform.
Business transfers: we may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. We will provide notice before your personal information is transferred.
As permitted or required by law: under certain circumstances, the Company may be required by law to disclose personal information in connection with a law enforcement investigation, a legal or regulatory proceeding or in response to valid requests by public authorities (e.g., a court or a government agency).
For continuity of care: we may share personal information among healthcare providers, including your healthcare team, who assist in the provision of healthcare to your child.

De-identified or Aggregated Data

Our Company may collect or share de-identified or aggregated data generated from users who interact with our Service for analytical purposes and/or to improve user experience on our website (www.kixcare.com).De-identified or aggregated data may be derived from your personal information, including personal health information, but are not considered personal information at law as this data does not directly or indirectly reveal your identity. However, if we combine or connect the data with your personal information to the extent that you can be directly or indirectly identified, we treat the combined data as personal information which will be used in accordance with this policy.Cookies and Similar TechnologiesA cookie is a small text file that our website may place on your device as a tool to provide you with a more personalized experience, including things like remember your preferences and display more relevant information next time you visit our website. You may instruct your browser to refuse all cookies by selecting the appropriate settings. However, please note that if you disable cookies, you may not be able to use some portions of our Service.Examples of cookies we use:

Analytics cookies: these allow us to collect page views, session and user behavior, amongst others, in order to better understand how users interact with our website and improve the website’s performance.
First and third-party cookies: these allow us to collect analytics data and user-specific preferences in order to improve the user experience on our website. Third-party cookies are placed and tracked by third-party service providers for purposes of cross-site tracking, targeted advertising and to help provide you with ad-serving.
Advertising cookies: these allow us to gather information from you in order to display advertisement that are geared towards topic of interest to you. These may include site and search retargeting cookies, display and email retargeting cookies, and Google Adwords and Google Analytics tracking.

Choice/Opt-out Settings

Our Company may communicate with you regarding Company information, changes to our service offerings, details of upcoming events or activities. Any marketing communications is on an opt-in basis.Should you decide that you no longer wish to receive marketing communications, you may unsubscribe from our marketing communications by clicking the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by contacting us info@kixcare.com with the subject line Attention: Privacy . However, we may still contact you for administrative and technical purposes. Withdrawing consent will not apply to actions we have already taken based on your prior consent.

Retention of Personal Information

The Company will retain your personal information as long as necessary for the purposes set out in this privacy policy and as detailed in any contractual arrangements we have with the custodian of your personal information. We will retain and use your personal information 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.

International Transfers

As noted above, our Company may rely on external service providers who are located in Canada or internationally. Some personal information collected by the Company may therefore be retained in countries other than Canada where privacy laws may offer different levels of protection, and personal information may be subject to access by and disclosure to law enforcement agencies in those jurisdictions. Personal health information stored by our HIPAA and PIPEDA compliant EMR vendors are stored on servers located in Canada.

Safeguarding Your Personal Information

The security of your personal information is important to us. We are committed to implementing security safeguards that are appropriate to the sensitivity of the personal information we hold. As part of the Company’s commitment to privacy, we take appropriate and reasonable technical, physical and administrative security measures to safeguard your personal information from such risks as unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.You can keep your personal information secure by safeguarding your account details including password information. We encourage you to take active measures to protect your account, including by choosing a unique and strong password.Please note that no method of data transmission over the internet or otherwise, or method of electronic storage, can be guaranteed to be completely secure. As a result, while we strive to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.If you have a security related concern, please contact us at privacy@kixcare.com. We will work closely with you to ensure a quick and personal response to your concerns.

Correcting or Accessing Your Personal Information

We rely on you to ensure that the personal information you enter into the Service is as accurate, complete and up to date as necessary for the purposes for which it is intended to be used. You may review and update your personal information by accessing your account settings located within your user profile on our patient portal at https://kixcare.inputhealth.com/.You have a right to access and correct your personal information held by the Company. You also have a right to know if your personal information has been shared with any third parties. To access or correct personal information we have about you, please contact us. The Company reserves the right, as permitted by applicable federal and provincial privacy legislation, to charge a reasonable fee for copying the requested information. Unless required by law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or for other legal basis. We will provide you an explanation for the reason for any such denial of access.

Children’s Data

Protecting the personal information and privacy of children is paramount. Our Services are intended for use by persons 14 years of age and older. The parent or legal guardian of a child may register an account on our website on behalf of a child to be used by the parent or legal guardian or by the child. Please do not use the Website or Services at any time or for any reason if you are under the age of 14 years, without the consent of a parent or legal guardian. By using the Website or Services, you affirm that you are 14 years old or older.

Contact Us

If you have any questions or a complaint about our privacy practices, please contact us in writing at privacy@kixcare.com. If our representative is unable to resolve the concern, or if there is a further complaint, you have the option to contact your respective provincial privacy commissioner or the Privacy Commissioner of Canada at (www.privcom.gc.ca) or at 112 Kent Street, Ottawa, ON, K1A 1H3, Toll Free: 1-800-282-1376, Fax: (613) 947-6850.