Psirenity Platform Privacy Statement

Psirenity Inc. (“Psirenity”, “we”, “us”) is dedicated to protecting your privacy rights. This Privacy Statement (“Policy”) describes how Psirenity collects, protects, uses and discloses information and data created in the course of your access to and use of the Psirenity Platform (as hereafter defined). We last updated this Policy (“Policy”) on July 26, 2022. We post the current version of the Policy at www.psirenity.com. We reserve the right to amend the Policy at any time to account for changes in Applicable Law, our practices and the Psirenity Platform. Please check to see if we have amended the Policy since you last used the Psirenity Platform to ensure you are aware of (and agree to) our current privacy practices. If you continue to access or use the Psirenity Platform or any of its services after any revisions to this Policy are posted, you will be deemed to have accepted those revisions.

What’s in this Privacy Policy?

This Policy addresses the following topics:

Definitions

The following provides the meaning of certain terms used in this Policy. If not defined below, the capitalized words and phrases in this Policy have the same meaning as in Psirenity’s Terms of Use. “Psirenity Platform” means, collectively, the health and wellness management program provided by Psirenity through its information technology platform consisting of applications, websites, content, products and services. The Psirenity Platform enables registered users (“Users”, “you”, “your”) to monitor and manage your health and wellness, access services provided by healthcare professionals and health coaches (collectively, “Authorized Providers”) and certain other services related to your health and wellness (collectively, the “Services”).

Telehealth healthcare services are also delivered through interactive text, audio and/or video technology, where the patient and the healthcare provider are not in the same physical location. These services may include services provided by physicians or nurse practitioners (“Medical Services”) and services provided by registered health coaches (“Coaching Services”). The telehealth services provided through the Psirenity Platform by healthcare providers and registered health coaches are referred to in these Terms collectively as “Telehealth Services”.

The Psirenity Platform also enables Users to store certain personal and personal health information (collectively “PHI”), share their PHI with Authorized Providers so to aid in optimizing healthcare outcomes and continuity of care. “Applicable Law” in relation to Psirenity, Authorized Providers or Users, means the laws and regulations including privacy laws and regulations to which each is subject. “Content” means the content that Psirenity makes available to you on the Psirenity Platform in the course of providing Services, including marketing materials, text, audio, video, photographs, maps, illustrations, graphics, the trademarks and other media.

Agreement with TELUS Health

If you are an Authorized Provider, your arrangement with Psirenity – your rights and obligations and those of Psirenity - is set out in the agreement directly between the Authorized Provider and Psirenity.

If you are a User receiving Medical Services, the arrangement between you and Psirenity and your rights and obligations as it relates to the Medical Services is set out in TELUS Health MyCare Terms and Conditions and where applicable, supplementary Terms.

If you are a User receiving Coaching Services – your rights and obligations and those of Psirenity – is set out in these Terms of Use and where applicable, supplementary Terms.

Application of this Policy

This Policy describes Psirenity’s management of PHI, including the purposes for which we collect, use and disclose PHI and the safeguards we use to protect PHI. This Policy does not apply to the collection, use, retention, disposal, destruction, and protection of PHI by physicians and nurse practitioners through the Medical Services provided by way of TELUS Health, which is part of the said physician or nurse practitioner’s records. The Psirenity Platform is a tool used by Authorized Providers that does not alter their obligations or responsibility for PHI they collect. Authorized Providers are subject to privacy legislation and professional requirements that govern their record keeping and management of PHI, regardless of the tools they use to collect, use, disclose and hold the PHI. Please direct any questions you have about how an Authorized Provider will treat your PHI to the Authorized Provider.

Psirenity’s collection and use of PHI

Psirenity collects and uses PHI to the extent necessary to develop, evaluate, improve and provide the Psirenity Platform and related services. We do not collect or use PHI if non-identifying information will suffice. We do not record or transcribe the audio or video portions of coaching sessions. More specifically:

Third party service providers

Psirenity may use third-party software and service providers for a variety of services including but not limited to healthcare virtual consulting, technical, operational and other business, data storage, payment processing and research, analytics and marketing services. We require our third party service providers to limit their use of PHI (that you or we provide or allow them to access) to that necessary for their services, and to have security measures in place that are appropriate for the protection of PHI. Subject to the receipt of any necessary consents, some of our service providers may operate from outside of Canada, which means that PHI they use on our behalf for their services may be subject to the law of country or state in which they operate (“Country”) including lawful orders to produce the PHI to among others, the government of the Country, its law enforcement and other agencies including where applicable national security authorities, and courts.

For additional details about Psirenity's third party service providers, please contact us as set out in the “Contact Us” section of this Privacy Statement.

Psirenity’s disclosure of PHI

Emergency contacts, on consent. Where applicable, we disclose PHI to emergency contacts as described above and for purposes for which we have User consent, including consent to disclose PHI to an insurer or other Third Party Payer.

Compliance, Fraud Prevention. We disclose PHI to the extent we, in our good faith judgment, are required to do so to comply with Applicable Law including to respond to a subpoena, order, or similar obligation to produce information, establish or exercise Psirenity’s legal rights including defend against legal claims, detect, investigate, suppress, prevent or take action regarding illegal or prohibited activities, including without limitation suspected fraud and threats to the reputation or safety of any person.

Business transactions. We may disclose PHI for the purposes of conducting required due diligence or the completion of a business transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including agreements and notice requirements that apply to the disclosure of PHI for such transactions.

Emergency/Risk of Harm. We may disclose PHI to a third party where required or permitted to do so by Applicable Law, where an Authorized Provider is permitted by applicable law to disclose a User’s (or Registered Dependent’s) PHI if the Authorized Provider believes that such disclosure is necessary to eliminate or reduce a significant risk of serious bodily harm to a person(s).

Psirenity’s retention/deletion of PHI

Unless we notify you otherwise, we will retain your PHI only for as long as needed to fulfill the purposes for which the PHI was collected in the first place.

Accessing and correcting PHI

You can access your PHI by logging in to your Account.

You may update or otherwise correct your PHI, except PHI an Authorized Provider has viewed or created. To update or correct PHI on the Psirenity Platform you can contact us through the means set out in the “Contact Us” section of this Privacy Statement.

We may require that you provide sufficient identification to fulfill your request to access or correct your PHI. Any such identifying information will be used only for this purpose.

Privacy Settings

The Psirenity Platform offers you functionality and choices for protecting your privacy, which include:

Please contact us directly at info@psirenity.com if you require assistance using the privacy functionality described above or more generally have questions about how to use the Psirenity Platform. To protect your privacy, we may request information to verify your identity when you contact us.

Safeguarding PHI

We have in place appropriate physical, technological, and organizational safeguards including access controls to protect PHI against loss, theft, and unauthorized access, use and disclosure. Notwithstanding the safeguards we employ and our commitment to protecting PHI, we cannot guarantee the security or error-free transmission or storage of PHI. There are risks inherent in the use of electronic means to transmit and hold information in electronic format. These risks can be minimized but not eliminated by the use of appropriate security measures, such as the measures Psirenity employs. These risks include interception, loss, corruption, unauthorized access to, use and disclosure of PHI, and delay in the availability of PHI.

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.

Psirenity’s use of de-identified Data

Psirenity obtains the authorization of Authorized Providers to collect from them and use data created by de-identifying PHI so that it no longer identifies a User (“Data”). This Data is not PHI as it is not identifiable to you or any other individual. Psirenity may use Data for monitoring the compliance of Users and Authorized Providers with the Psirenity Platform terms of use, for making use of the Psirenity Platform (and more generally of patient-initiated telehealth services) more accessible and enhancing the experience for Users and Authorized Providers through analyzing Authorized Provider usage and utilization patterns, and designing surveys (to be posted and completed at the discretion of Users). We may also use or disclose Data for the purposes of academic research. We will not use Data to re-identify Users or for any other purpose prohibited by Applicable Law. We will only de-identify PHI in a manner that complies with Applicable Law and do so in a manner that it is not possible to re-identify the User from which the Data was developed.

Technical Information, Cookies and similar technologies

Like most websites and other electronic services, we may collect certain technical and device information about your use of the Psirenity Platform. Such information may include your Internet protocol address, information about your device, browser and operating system, and the date and time of your visit.

The Psirenity Platform, email messages, and marketing materials use “cookies” and other technologies such as pixel tags and web beacons. We use these technologies to better understand the use of the Psirenity Platform, analyze trends, and administer, personalize and improve the experience of using the Psirenity Platform for Users and Authorized Providers.

Psirenity uses cookies including third party cookies to obtain information about the use of the Psirenity Platform.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. 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.

Third Party Services and Links to third party websites

The Psirenity Platform may allow you to access services provided by others and to interact with other service providers, including TELUS Health when receiving Telehealth Services. These services provided by others are subject to the privacy practices of the third party service provider and are governed by their privacy statements and policies, not those of Psirenity.

The Psirenity Platform may contain links to websites that we do not own or operate. The provision of these links is not an endorsement of or referral to the linked websites. We provide the links solely for your convenience.

This Policy does not apply to third party services or linked sites or pages and we are not responsible for the content or privacy practices applicable to them or used by their operators. We strongly encourage you to review the privacy policies and terms of use applicable to any third party services or site you visit.

Contact Us

If you have any questions, concerns or suggestions about our privacy practices, please contact our Privacy Officer at info@psirenity.com. Please include your name and contact information if you would like us to respond to you.