Privacy at AwareMD

Updated: October 28, 2021

AwareMD (“AwareMD”, “us” or “we”) and our parent company WELL Health Technologies Corp. (“WELL”) are proud to offer you the AwareMD webpage (the “Webpage”) and the Cerebrum suite of products (collectively, “Cerebrum”). AwareMD is committed to protecting your personal information and complying with applicable data protection and privacy laws. This “Privacy Policy” tells you how we do so.

THIS PRIVACY POLICY DOES NOT APPLY TO THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION BY HEALTH CARE PROFESSIONALS, INCLUDING PHYSICIANS, PHYSICIAN ASSISTANTS, NURSES, THERAPISTS, AND MEDICAL OFFICE ASSISTANTS (“HCPS”) WHO USE CEREBRUM TO PROVIDE OR FACILITATE HEALTH SERVICES. HCPS ARE SUBJECT TO THEIR OWN RESPECTIVE PRIVACY LAWS AND PROFESSIONAL REQUIREMENTS THAT GOVERN HOW THEY COLLECT, USE AND DISCLOSE PERSONAL INFORMATION. WE ENCOURAGE YOU TO READ THEIR RESPECTIVE PRIVACY POLICIES TO UNDERSTAND HOW YOUR PERSONAL INFORMATION (INCLUDING YOUR PERSONAL HEALTH INFORMATION) MAY BE COLLECTED, USED AND DISCLOSED.

We will update this Privacy Policy as necessary. Please check it regularly.

1. What information do we collect?

Webpage - Cookies

Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Webpage, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings, language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online interactions.

These Cookies helps us understand how you use the Webpage and the content of the Webpage in order to make improvements. We also may use these Cookies to promote our services through marketing and advertising. These Cookies may be accessed or disclosed to third-parties for the purpose of serving you relevant advertisements.

You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of the Webpage’s features, and may prevent us from providing you with the information and services you have requested.

Webpage - Contact-Us (online form, chat box, or e-mail)

When you submit a form on the Webpage, use our customer service chat messenger, or e-mail us with a question, we will collect personal information about you like your name, e-mail, phone number, and company name. This information will be used by AwareMD to communicate with you, provide you with the information you requested, and conduct appropriate follow-up.

Webpage - Direct marketing

If you sign up to receive direct marketing or promotional communications from AwareMD, we will collect your name and e-mail to inform you about AwareMD and the associated products and services. If you sign-up to receive newsletters or request additional information about WELL, we will share your name and e-mail address with WELL so they can provide you with the information you requested.

Cerebrum

When a clinic or HCP enters into an agreement with AwareMD for Cerebrum, AwareMD will collect personal information about the individual, including name, e-mail, phone number, and information about the medical practice, like its name, address and contact details. This information will be used by AwareMD to create an account and effectively administer the deployment of Cerebrum products, confirm identities in the future, and to contact the individual wish respect to the medical practice’s use of the Platform. Throughout the deployment of Cerebrum products, additional information about the clinic and HCP may be collected to ensure continuity of service.

Once the account is created, the HCP can use Cerebrum to collect their patient’s information, including their personal health information.

2. Why do we use personal information?

We use your personal information to:

• manage our relationship with you and provide you with the information or services you request,
• create an account for HCPS using Cerebrum,
• conduct research and evaluate development on the Webpage, including analyzing testing data to improve our services,
• communicate with you regarding inquiries for information or customer service request or employment opportunities,
• detect, prevent or investigate security breaches,
• process insurance, credit card or other payment information as agreed to on the Webpage or through the use of the Platform,
• protect our business, and
• maintain appropriate records for internal administrative purposes.

AwareMD reserves the right to aggregate and anonymize personal information stored on its system and use such aggregated information as it sees fit.

3. Who do we share the personal information with?

We may share some of your personal information with third-party service providers in order to operate the Webpage, Cerebrum, or to provide you with the information you request. We only use service providers that ensure a comparable level of protection for your information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information only for the services requested.

Exceptionally, we may collect, use or disclose personal information without your consent in the following limited circumstances:

• when the collection, use or disclosure of personal information is permitted or required by law or by regulatory proceedings,
• in an emergency that threatens an individual’s life, health, or personal security,
• when we require legal advice from a lawyer,
• to protect ourselves from fraud,
• to a collection agency to collect our unpaid accounts, or
• to investigate an anticipated breach of an agreement or a contravention of law.

If we merge with another business, we will inform you of any impact on your personal information.

Webpage

We only share your personal information with service providers, including our affiliates, in order to operate the Webpage. This includes potentially sharing your personal information for:

• providing requested services or information,
• operating and optimizing the Webpage, or
• customer service.

Cerebrum

We may share your personal information with our service providers for:

• fraud prevention,
• payment processing via Stripe,
• providing requested services or information,
• operating the Webpage or Cerebrum, and
• customer service.

4. How long do we keep personal information?

We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with applicable legal and regulatory requirements.

HCPs are subject to their own regulatory and professional rules which require them to retain patient information, including their personal health information collect and stored via Cerebrum, for a minimum length of time. HCPs are responsible for ensuring their own compliance with such provincial retention periods. We recommend you speak to the relevant HCP to understand how long your information will be stored by them.

5. How do we keep personal information accurate?

We take reasonable steps to ensure that any personal information in our custody is accurate and up-to-date but we mostly rely on you to notify us of any changes to personal information you provided us.

6. How do we protect your personal information?

We use reasonable and appropriate physical, administrative and technical measures (including encryption) designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with AwareMD or WELL is prohibited and constitutes grounds for disciplinary action.

HCPs who utilize Cerebrum will have their own security policies and procedures to manage individual’s personal information (including their personal health information). We recommend that patients read the HCP’s privacy and security policies to understand how they protect patient information.

Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee no breach will ever occur.

7. Where do we store personal information?

All personal information we collect, including all information stored on Cerebrum, is stored on secure servers in Canada.

However, personal information processed by our third-party service providers may be done outside of the jurisdiction where the data is stored. While being processed in another jurisdiction, such personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.

Further, HCPs who utilize Cerebrum will have their own data retention policies and may be required to store your personal information outside of Cerebrum. This may be done on systems and databases which store information in different jurisdictions in which you reside. We recommend that patients reach out to their HCP to understand where they store patient information.

For more information on our service providers or where we store personal information, contact us at privacy@well.company.

8. Links to third-party sites

Our Webpage may lead you to third-party websites, including websites advertising other products or services. These websites are separate and distinct from AwareMD and WELL and have their own separate privacy policies. We are not responsible in any way for how any website collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies before providing your personal information to them.

9. Direct marketing

You may sign up to receive marketing or promotional communications from WELL. Where you have expressly consented, we may use your personal information to inform you about us and our products and our services, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

• using the unsubscribe feature found in our emails and other electronic communications, or
• contacting us via email at marketing@well.company.

We remove your contact information from our distribution list as soon as you unsubscribe.

10. Your rights

You also have the right to:

• make a written request to access your personal information,
• request us to restrict our use or disclosure of your personal information,
• object to our use or disclosure of your personal information,
• request that we edit, but not remove, certain information (like an e-mail address),
• request that we transfer to another organization the personal information you have provided us,
• request us to delete the personal information we hold about you, and
• request we delete your account.

Contact us at cerebrumsupport@awaremd.com.com to exercise any of these rights. In order to confirm your identity, we may require you to answer some security questions or provide proof of identity. We will respond within 30 days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons. Please note, any requests with respect to your personal health information will be redirected to the relevant HCP.

We will address all requests with equal attention.

11. Contacting us

Accountability with respect to your personal information is important to AwareMD and WELL. In the event that you have any questions (including how personal information is managed by AwareMD or WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer: Brandon Rasula at brandon.rasula@well.company .

If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.