PRIVACY POLICY

ExquisiCare Inc. and its affiliates (collectively, “ExquisiCare” “we”, “our” or “us”) recognizes the importance of privacy. The purpose of this Privacy Statement is to inform you about our privacy practices, including how we collect, use, and disclose your personal information.

Personal Information We Collect

“Personal information” means information about an identifiable individual as described under Canadian privacy laws.

Generally, personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business, or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.

We may collect, use, and disclose different types of personal information, depending on our relationship with you. Generally, the types of personal information we collect can be grouped into the following categories (not all of which may apply to you):

• identity information, such as your name, username or similar identifier, marital status, title, date of birth and gender
• contact information, such as your address, e-mail address and telephone numbers
• technical and usage information when you use our website, such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website
• health information, such as your health history, accident reports, health care programs and services you receive from us, and the names of your health care providers
• marketing and communications information, such as your preferences for receiving our newsletter

We also collect, use, and share aggregated and anonymized data for any purpose. Aggregated and anonymized data is not considered personal information because it cannot be used to identify you.

How We Use Your Personal Information

We generally use your personal information for the following purposes:

• to determine your eligibility for our services in accordance with applicable laws and our policies
• if you use any of our technology applications, to administer your use of those applications
• to respond to your inquiries, complaints, or requests
• to communicate with you through our newsletter or other communications
• to improve the effectiveness and efficiency of our operations, products, services, and programs
• to investigate legal claims and protect our rights, operations or property
• for such other purposes as you may consent to from time to time
• as otherwise required or permitted by law.

We do not use your personal information to engage in interest-based or behavioral advertising of our services across third-party websites or service offerings.

You have a variety of tools to control the information collected by cookies, web beacons, and similar technologies when you use our website. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

How We Share Your Personal Information

We generally identify to whom, and for what purposes, we disclose your personal information at the time we collect such information from you and obtain your consent to such disclosure.

We may disclose your information when we believe such disclosure is required or permitted by law. In addition, we may disclose your personal information to a third party in the event of any significant business transaction, such as a merger or reorganization.

We rely on service providers to perform a variety of services on our behalf, such as technical support providers, and data storage and processing service providers. If we transfer your personal information to a service provider, we require that they maintain the confidentiality of your personal information and keep it secure. We also require that our service providers comply with applicable privacy laws and only use your personal information for the limited purposes for which it is provided.

Your Consent to the Collection, Use and Disclosure of Your Personal Information

We collect, use, and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question. Generally, we will seek your consent at the time we collect your personal information, either orally, electronically, or in writing.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Statement.

If you wish to withdraw your consent to our collection, use, or disclosure of your personal information, please contact us using the contact information in the “How to Contact Us” section below. We will accommodate your request to withdraw consent, subject to legal or contractual restrictions. In some cases, withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services.

Retention and Storage of Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and as permitted or required by law. Information that we collect is stored on servers located in Canada.

Information Security

We have implemented physical, organizational, contractual, and technological security measures in an effort to protect your personal information from loss or theft, unauthorized access, use, or disclosure. For example:

• we train our employees and agents on the importance of safeguarding personal information
• we restrict access to your personal information to those employees or agents who need access for authorized purposes
• we protect personal information in electronic form using technological means such as firewalls, access controls, and encryption

Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in such risks as phishing and identity theft. In such cases, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately.

Accessing and Updating Your Personal Information

We expect you to supply us with updates to your personal information, when required. We will not routinely update your personal information unless such a process is necessary.

You may make a request to review any personal information about you that we have collected, used, or disclosed, and we will provide you with any such personal information to the extent required by applicable laws.

We may require that you provide sufficient identification to fulfill your request to access or correct
your personal information. Any such identifying information will be used only for this purpose. You may have the right to make a complaint to the Privacy Commissioner of Canada or the applicable provincial privacy commissioner if you object to how we handle your request.

Third-Party Websites and Services

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy statements and policies of the respective third party. This Privacy Statement does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.

Changes to this Privacy Statement

From time to time, we may make changes to this Privacy Statement. When changes are made, they will become immediately effective when published in a revised Privacy Statement posted on our website, unless otherwise noted. We may also communicate the changes to this Privacy Statement by other means.

How to Contact Us

All comments, questions, concerns, or requests regarding your personal information or our privacy practices should be forwarded to our Privacy Officer as follows: Privacy Officer

Privacy and Accessibility Office SE Health 90 Allstate Parkway, Suite 300
Markham, Ontario L3R 6H3
Tel: 1-866-636-9914
Fax: 905.940.9934
privacyofficer@sehc.com