Summary

Workforce Wellness Inc. is committed to ensuring its compliance with British Columbia’s Personal Information Protection Act (PIPA), and other applicable legislation which protects the Personal Information that will be collected, used and disclosed by us when you use a Workforce Wellness Application (“App”). By using the App, you agree to our Privacy Notice (this document) and our Terms of Use. We care about the privacy and security of your data. This is a summary of our Privacy Notice.  If you do not want us to collect, use or disclose your Personal Information in the ways identified in the full Privacy Notice, you should not use the App.‬‬‬‬‬‬‬‬‬‬‬‬‬‬

Introduction

This Privacy Notice governs Workforce Wellness (“Company”, “WW”, “we”, “our” or “us”) collection, use and disclosure of Personal Information. In compliance with British Columbia’s Personal Information Protection Act (PIPA), and other applicable legislation, our Privacy Notice is designed to provide transparency regarding our privacy practices with respect to the use and disclosure of the Personal Information we collect from you when you use a Workforce Wellness Applications (mobile and web) (“App”) and related Services as defined in the Terms of Use (the “Terms”).

Please read this Privacy Notice carefully. By using the App, you consent to the collection, use and disclosure of Personal Information in accordance with the terms of this Privacy Notice. If you do not want us to collect, use or disclose your Personal Information in the ways identified in this Privacy Notice, you should not use the App. If the App is being used at the request of your Employer, you are responsible for informing your Employer of your decision to not use this App (if applicable).‬‬‬

We may amend this Privacy Notice from time to time and will post any changes to this Privacy Notice. Please refer to this Privacy Notice on a regular basis. Your continued use of the App following the posting of changes (found at www.workforcewellness.com/privacy) to this Privacy Notice will signify your acceptance of those changes.‬

1. Personal Information

We only collect the Personal Information required for the services, products, and functionalities for which you sign up and to improve our products and services.‬‬  You will have the opportunity to participate, if you consent, in optional research projects and to receive optional information about our products and services that may be of interest to you.  We may also collect and use your Personal Information for other purposes, though only with your consent. ‬‬‬‬‬‬‬

“Personal Information”is information about an identifiable individual and includes but is not limited to contact information (email address, phone number), personal health information, name, age, and biological sex. To the extent that this information is collected or provided through the App and can be used to identify an individual, we will treat it as Personal Information in accordance with this Privacy Notice.‬ ‬‬‬‬

We will use the Personal Information to provide you with the services, products, and functionalities for which you sign up, to improve our products and services, and only if you consent for research purposes in limited circumstances and to send you information on our products or services that may be of interest to you.

When using the App, you will be asked to provide certain Personal Information including age, biological sex and a description of your health symptoms. (“Services Information”).

We may also collect and use your Personal Information for other purposes, with your consent. Unless the purposes for collecting Personal Information are obvious and you voluntarily provide your Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected before or at the time of collection. ‬‬‬‬‬‬‬

You may refuse to supply Personal Information but be aware that this can prevent you from engaging in certain activities in relation to the App.‬‬‬‬‬‬‬

2. Other Information

We may remove personal identifiers from your information and maintain and use it in an anonymized form that may be combined with other information to generate aggregated information.  Other information includes but is not limited to technical information about the device, system and application software, and peripherals. We will ask for your consent before sharing this anonymized information with a third party, such as for research purposes. We may use this anonymized information for any purpose internally, especially to improve our products and services and perform statistical analyses and generate data related to how users use our App.

3. Consent

By giving us Personal Information when you use our App, you consent to your information being collected, used, disclosed and stored by us, only as described in this Privacy Notice.  You have control over how your Personal Information is used and can withdraw your consent at any time and without penalty.‬ ‬‬‬‬‬‬

By giving us Personal Information when you use our App, you consent to your information being collected, used, disclosed and stored by us, only as described in this Privacy Notice.‬ ‬‬‬‬

At any time and without penalty, you can withdraw your consent to the use and disclosure of your information and delete your account.  To delete your account, send an email to privacy@workforcewellness.com. We will let you know by email within 10 business days when your account has been removed. If your use of this App is affiliated with your Employer, we will notify your Employer that you have requested the deletion of your account (if applicable).

We may also collect, use and/or disclose Personal Information for other purposes with your consent, or to the extent necessary for the purposes of meeting relevant regulatory, legal, insurance, audit, security and processing requirements, or to the extent permitted or required by applicable law.‬‬‬‬‬‬‬‬‬‬‬‬‬‬ We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users.

4. Using and Disclosing Personal Information

With your consent, your Personal Information may be disclosed to a third party for the purposes identified in this Privacy Notice. If in the future we are acquired by another company, your anonymized Personal Information may be shared with them. We do not sell your Personal Information. Your Personal Information will never be shared with third parties for their marketing purposes. We will use your Personal Information for the purposes described above. We may also use Personal Information to:

Assist you with technical support issues. Most technical issues can be resolved without our support team viewing your Personal Information.

Comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect ourselves and other individuals from harm.

Conduct auditing, data analysis, and research to improve our products, services, and customer communications.

With your consent, the Services Information may be disclosed to a third party for the purposes identified in this Privacy Policy or for a purpose reasonably related to those purposes. ‬‬‬‬‬‬‬

We will not use or disclose your Personal Information for any additional purpose unless we obtain your consent to do so.

We do not sell your Personal Information, and personal information will never be shared with third parties for their marketing purposes.

We may disclose your anonymized information to other third parties in relation to a merger, acquisition, or any form of sale of some or all of our assets or business. Your anonymized information may be provided to the entities and advisors involved, for the purposes of determining whether to proceed with the transaction and, where applicable, to conclude the transaction. Your anonymized information may be transferred to a successor business as part of the process of assigning all or part of our assets to the successor business.  The successor business may use and disclose the information for the purposes described in this Privacy Notice.‬ ‬‬‬‬‬‬

5. Retaining Personal Information

We keep your Personal Information for as long as necessary to fulfill these purposes, or until you ask us to delete it.

We will retain Personal Information only as long as necessary to fulfill the identified purposes or as permitted or required by law. Because one purpose is to assist you with the management of your Personal Information, including the personal health information that you provide when using our App, we will keep your Personal Information until you delete your account or let us know that you no longer require our assistance.

6. Ensuring Accuracy of Personal Information

You are responsible for keeping your Personal Information up to date and accurate.

We rely on you to ensure that the Personal Information you provide while using the App or a related Service is accurate, complete and up-to-date. You are welcome to make changes or corrections to Personal Information (not including health indicator history) at any time by updating your profile data.

7. Safeguards

We use security best practices and take reasonable steps to protect your Personal Information. We train our team to follow privacy and security best practices.‬ ‬‬‬‬‬‬

We maintain appropriate storage and processing practices and security measures to protect your Personal Information from unauthorized access, collection, use, disclosure, copying, modification or disposal or destruction. We train our team to follow privacy and security practices.‬ ‬‬‬‬‬‬

Using contracts, we ensure that any third party acting on our behalf in respect of your Personal Information maintains reasonable and appropriate safeguards.‬ ‬‬‬‬‬‬

We will use appropriate security measures when destroying Personal Information such as deleting electronically stored information.

We will review and update our security policies and controls as technology changes to ensure ongoing Personal Information security, however, please bear in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you share with us.

It’s important to guard your privacy when you are online. If our Apps or related Services contain links to other websites, this Privacy Notice does not govern those websites. Whether we have posted those links, or other organizations or individuals have, you should read their privacy policies and make an informed decision about whether you want to use those websites or their services.‬ ‬‬

8. Location of Technology Services

Your personal health information is stored and processed in Canada or the US, depending on where your organization is located. We may use a small number of services based in the US or Canada to control user accounts and to send communications to you; these require your e-mail address or mobile phone number.

9. Individual Access

At any time and without penalty, you can request access to your Personal Information (subject to limited exceptions) or delete your account by contacting us at privacy@workforcewellness.com

You may request access to, make corrections to, or delete the Personal Information we hold about you at any time, subject to limited exceptions. Upon written request, we will also provide you with a list of individuals or entities (e.g. third-party service providers) to whom we have disclosed your Personal Information, if applicable. Please contact our Privacy Officer at privacy@workforcewellness.com for additional information.‬ ‬‬‬‬‬‬

10. Changes to this Privacy Notice

We may update this notice to reflect changes to our information practices. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification if appropriate).

11. Questions and Complaints

You may send your privacy-related questions, concerns or complaints to our Privacy Officer who is responsible for ensuring our compliance with this notice and with the appropriate privacy legislation.‬ ‬‬‬‬‬If you have questions regarding this Privacy Notice, please contact us at:

privacy@workforcewellness.com, or by mail at 2900 – 550 Burrard Street, Vancouver, BC V6C 0A3.

Last Updated: December 8, 2022