This Privacy Policy (the “Policy”) outlines how we collect, use, disclose, manage and safeguard your Personal Information (“PI”) and Personal Health Information (“PHI”). All our employees and contractors are required to adhere to the protections described in this policy and to other confidentiality and information disclosure rules. Please read this Privacy Policy carefully before you use this app or the LifePath Service. By accessing or using the Services you are agreeing to the terms of this Policy. The Policy should be read in conjunction with the Terms of Use. You should not use the Services unless you fully understand and agree to the Terms of Use and the Policy. 

References to “Elastic Care”, “we” or “us” mean Elastic Care Inc. a company registered and operating out of 95 Apple Creek Blvd., Markham, L3R 1C7 in the Province of Ontario in Canada. Elastic Care may share information among its subsidiaries or affiliates for the purposes of improving this app, and for no other purpose. Any information collected under this Privacy Policy is always protected under the terms of this Privacy Policy. Except as otherwise noted in this Privacy Policy, Elastic Care is the data controller responsible for processing your personal information as described in this Privacy Policy. 

“LifePath Remote Patient Monitoring Platform” is a platform (the “Platform”), created by Elastic Care, which allows users of the LifePath Patient Application (the App”) to gather certain personal and health related information and communicate such data it to the user’s chosen healthcare practitioners or professionals i.e. registered clinician or doctor (the “Clinician”). The App and Platform are used for the purposes of direct medical consultation (“Consultation”) between users and the Clinician they choose to have their information sent to. The Platform, the App, the website www.elasticcare.com (the “website”) and the information and services made available through these, are collectively referred to as the “Services”. 

For the purposes of this Policy, “Personal Information” or “PI” means Personal Information about an individual which allows them to be identified. “Personal Health Information” or “PHI” means information about an identifiable individual that relates to the individual’s physical or mental health. PHI includes name of the user, gender, date of birth, past medical history and treatments, allergies, medications taken, smoking status, symptoms, vital signs and symptoms experienced. PHI may be submitted by the user for review by their Clinician. 

PRIVACY PRINCIPLES AND OUR COMMITMENT

We take the privacy of our users very seriously and are committed to safeguarding your Personal Information and PHI. Accordingly, we make the following commitments to you, as a user of our services.

• We will never disclose your Personal Information or PHI to anyone without your consent.
• We will never rent or sell the Personal Information or PHI that we collect.
• We have implemented industry-standard physical, administrative and technological safeguards to protect Personal Information and PHI from unauthorized access.
• We will comply with applicable privacy and personal health information legislation applicable to locations where we operate.

INFORMATION WHICH WE COLLECT AND STORE

We may collect the following information from you when you download the LifePath App and register for a LifePath account (“Account”) or when you use the Services:

• REGISTRATION AND PERSONAL HEALTH INFORMATION
  When you register for a LifePath Account, we will collect identification and contact information. When you use the App and the Platform, we will collect and store Personal Health Information and other PHI information for transmission, unaltered, to your designated Clinician. Your Clinician may or may not use the information you provide to assess your condition, exercise clinical judgement, make diagnoses and suggest possible treatment or remedial actions.
  
  
• CHARGES AND FEES
  The Services made available via this App and Platform are offered free of charge to users. There are no fees for use of the App or the Platform. Please be aware, however, that your Clinician may charge you or your health insurance provider for any medical consultation or service rendered using the LifePath Service. Elastic Care has no involvement in such fees and receives no compensation or payment from users or Clinicians for providing the LifePath Platform, App or Service.
  
  
• LOG AND WEBSITE INFORMATION
  When you access and use the Services, we may automatically collect certain technical information about your visit, including the date, time, browser type, your internet service provider, your IP address, device information (including device identifiers), geo-location information, computer and network performance data, any URL that you are coming from and your navigation history. This information is gathered in order to customize your experience of the Services, to improve our Services and for research purposes only.
  
  
• INFORMATION FROM USE OF THE APP Data obtained from use of the App and Platform will be anonymized and de-identified before being analyzed and used by us for product development and research purposes.

USE AND DISCLOSURE OF YOUR INFORMATION

• HEALTHCARE CONSULTATIONS
  
  We will transmit and disclose your Personal Information, including PHI, only to the healthcare professional whom you designate as your Clinician, in the App. We collect such information from you, with the sole purpose of passing it on, unaltered, to the Clinician of choice.
  
  If any information is required to be disclosed to a third-party, not associated with us or with LifePath, we will only make such disclosure after obtaining your express consent. Note, however, that your Clinician may provide information related to you, to other third parties in the course of their medical practice. We exercise no control or influence over this. If you wish that your Clinician should not share your PI or PHI with any third party, you should communicate this to your Clinician directly.
  
  We do not provide you with any healthcare services and cannot guarantee the accuracy, fidelity, timely transmission or receipt of your Personal Information, including PHI to your Clinician or that your Clinician will take any timely or correct action.
  
  Access to your Personal information will be logged and controlled. We will put in safeguards, and perform audits to ensure that your Personal Information is accessed, read or retrieved only by persons specifically authorised to do so, that such authorization is issued only for reasons related to maintaining or improving the LifePath Platform and /or App and that the information is only accessed on a ‘need to know’ basis. We may retain your Personal Information on our customer support systems and software for the purposes of user technical support.
  
  
• THIRD-PARTY SERVICE PROVIDERS
  
  We may transfer your Personal Information, including PHI to a third-party service provider for processing and storage in Canada. Whenever we engage such a a third-party service provider, we will ensure that the information is properly safeguarded at all times at a comparable level of protection the information would have received if it had not been transferred.
  
  
• LEGAL ISSUES
  
  We may use your Personal Information to detect, investigate, address and prevent fraudulent or illegal activities. We reserve the right to disclose your personal information as required by law, when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal process served on us and to defend against legal claims. These situations may include, but are not limited to, disclosing potentially life saving information during medical emergencies and reporting infectious diseases.
  
  
• CORPORATE MATTERS
  
  We may disclose and share your Personal Information to explore and/or undertake a corporate transaction, including a merger, acquisition, amalgamation, IPO, reorganization or sale of Elastic Care. Your Personal Information relevant to such transaction, will used and disclosed solely for the purposes related to the transaction and will be protected by security safeguards appropriate to the sensitivity of the information.
  
  This section does not relate to your PHI, which will not be disclosed and will remain confidential.

YOUR RIGHTS

• ACCESSING YOUR PERSONAL HEALTH INFORMATION
  
  Elastic Care does not retain your PI, PHI or other records beyond the periods described here. If you wish to have a copy of your patient information, you must obtain it directly from your Clinician or from the App where it is stored locally (i.e. on your mobile phone).
  
  
• LIMITATIONS ON ACCESS
  
  You will be denied access to the App or Platform if, in our view, providing you access would result in abuse of the LifePath App, Platform or underlying software or systems. You may also be denied access if you attempt to violate any of the terms of use the Service.
  
  
• ACCURACY
  
  The information held in the LifePath App or Platform is only as accurate as the information what you enter into your App. We will not modify, correct, update, interpret or check for accuracy, any information you provide using the App, the Platform or your Service.
  
  
• ANONYMIZED INFORMATION
  
  When conducting product development or research we will only use anonymized, de-identified and aggregated information.
  
  
• INFORMATION SAFETY
  
  Elastic Care is committed to information security and protects Personal Information and PHI through physical, technological and administrative controls and safeguards. We have implemented access and security controls at various levels, to protect infrastructure and applications against unauthorized access.
  
  Secure Storage: We store all Personal Information and PHI in a secure, data centre in Canada, owned and operated by Pathway Communications, an affiliated company of Elastic Care. The Pathway data center carries the following certifications: PCI DSS (Payment Card Industry Data Security Standard), HIPAA compliance (Health Insurance Portability and Accountability Act), ISO 27002, ISO 27018, SOC 2 Types I and II, Tier III (Uptime Institute)
  
  Privacy Policies and Training: Elastic Care has implemented written policies and procedures that specifically address the privacy and security of your PHI. All employees and contractors receive privacy training on Personal Information safety and risk mitigation and are legally bound by confidentiality and non-disclosure agreements.
  
  
• BREACH RESPONSE
  
  There is no guarantee against data breaches. However, Elastic Care has taken reasonable measures to prevent a breach, as described above. In the event of a data breach, we will immediately apply remedial measures and notify users of the breach at the first reasonable opportunity.
  
  
• CHANGES TO THIS POLICY
  
  If we decide to make material changes to this Policy, we will notify you and other users by placing a notice on our Website and App. You should periodically check the Website and the App for updates.
  
  
• CONTACTING US
  
  If you wish to contact us in respect of our privacy practices or this Policy please do so, by email to our Designated Privacy Contact at support@elasticcare.com . If we are unable to resolve your issue to your satisfaction, you may file a complaint with the local privacy authorities in your state, province or county or with the Office of the Privacy Commissioner of Canada.