Updated as of: March 21, 2024

Tabiat Research Inc. and its affiliates (collectively, “we”, “our” or “us”) recognize the importance of privacy.  The purpose of this privacy statement (“Privacy Statement”) is to inform you about our privacy practices, including how we collect, use and disclose your Personal Information.

This Privacy Statement applies to all of our operations in Canada or operations in connection with Canada, unless we have provided you with a separate privacy statement for a particular product, service or activity.

Privacy Statement Updates

This Privacy Statement is current as of the “updated” date which appears at the top of this page.  We may make changes to this Privacy Statement from time to time, which will become immediately effective when published in a revised Privacy Statement posted on our website unless otherwise noted.  We may also communicate the changes through our services or by other means. 

Please review this Privacy Statement carefully.  By submitting your Personal Information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your Personal Information as set out in this Privacy Statement, as revised from time to time.

What’s in this Privacy Statement?

This Privacy Policy covers the following topics:

• Meaning of Personal Information
• Your Consent to Collection, Use and Disclosure
• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Opting Out of Communications
• Retention of Personal Information
• Information Security
• Accessing and Updating Your Personal Information
• Third Party Websites and Services
• Children’s Personal Information
• How to Contact Us

Meaning of Personal Information

“Personal Information” means information about an identifiable individual as described under Canadian privacy laws, which may include, but is not limited to, your name, e-mail address, telephone number, address, health card and personal health information (including your device readings and measurements, wellness data, medical history, name of primary care providers, and health care programs and services you receive from us or healthcare providers that have invited you to register to use our products and services).

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, or work e-mail address.

Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected.  If you choose to provide Personal Information to us, we assume that you consent to the collection, use and disclosure of that Personal Information as outlined in this Privacy Statement.

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.  In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

Information We Collect

Products and Services.  For individuals located in Canada, we may collect information from you or from your use of our products or services.

• For clinics and physicians that use our dashboard, we collect Personal Information that you submit through your use of our products and services, such as your name, phone number, and clinic address
• For individuals who use our mobile platform to record and monitor their health and wellness, we collect Personal Information that you submit through your use of our products or services, such as:
  • your name, e-mail address, medical report number (MRN), social security number (for billing claims related to your health insurance coverage), device readings, and other information you provide upon activating your account;
  • health information, such as your health history, health questionnaire responses, health measurements recorded by your health monitoring devices, such as your oximeter and spirometer, that you upload by way of our products or services; and
  • information collected from your mobile device or other hardware used to provide our services, such as information provided by your device’s accelerometer, location data, heart rate monitor, gyroscope and other sensors;
• We may automatically collect usage data that is identifiable with you when you use our products and services, including location data, including GPS data and information relating to the addresses at which our products are deployed, such as latitude and longitude.
• We will aggregate and anonymize certain data collected in connection with your use of our products and services, which may be stored and used separately from the data and Personal Information referred to above.

Website.  For individuals located in Canada who visit our websites located at www.tabiat.ca, www.tabiat.care or any of our related websites (collectively, “our website”), we may collect information from you or from your activities on the site.

• Like most websites and other Internet services, we may collect certain technical and device information about your use of our website, which may include your Internet protocol address, information about your device, browser and operating system, and the date and time of your visit, as well as the region or general location where your device is accessing the internet, and other information about the usage of our website, including a history of the pages you view.
• We may also use “cookies” or enlist third party services which use cookies to track your preferences and activities on our website.  Cookies may store a variety of information, including the number of times that you access a site, your language preferences and the number of times that you view a particular page or other item on the site. 
• If you enter information in the “Contact Us” section, we collect your name, email address, company you represent and details of your inquiry to enable us to respond to a general/business inquiry made by you on behalf of your company.

Other Interactions.  For individuals located in Canada who otherwise interact with us, whether in person, by phone or e-mail, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address and other information you choose to provide us through these interactions.

How We Use Your Personal Information

We may use your Personal Information for purposes such as:

• providing you with our products and services and supporting your use of our products and services;
• preparing reports or sharing your Personal Information with the healthcare providers associated with your use of our products and services, or other healthcare practitioners within your “circle of care”;
• contacting you relating to our products and services;
• monitoring the usage of our products and services to support their proper functioning and further improvement;
• analyzing the needs and activities of our customers and users to help us better serve them;
• generating de-identified data to conduct research and analysis related to our business, products and services;
• responding to inquiries and other requests;
• collecting opinions and comments about our products and services;
• developing marketing materials;
• providing you with information that we think may interest you, including information about our products and services (where we have consent to do so);
• investigating legal claims; and
• for such other purposes as you may otherwise consent from time to time.

We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable Canadian privacy laws. We will process collect, use, and disclose information received through our website only to pursue our legitimate business interests in keeping you updated on our services and products, respond to your queries, establish communication with you and your company, and to enhance user experience by analyzing your use of our website.

How We Share Your Personal Information

For our users that are patients of clinics that are our customers, we disclose your Personal Information to your health care providers, and may provide your Personal Information to other health care providers, such as pharmacists, physicians, nurses, naturopaths or lab technicians, to facilitate the provision of your healthcare. This helps to coordinate care and ensure that everyone involved in your healthcare has the right information to meet your healthcare needs.

We rely on third party services providers to perform a variety of services on our behalf, such as data storage and processing service providers, technical support providers, processing service providers, communication service providers, and research and analytics providers.

If we provide information to service providers, we require that the service providers keep your Personal Information secure, and only handle it for limited purposes.  We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes. 

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain. 

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving emails by clicking the “unsubscribe” link at the bottom of any email you receive from us.  You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request.  Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your Personal Information only for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by Canadian privacy laws.

If your Personal Information was collected in connection with your use of our products and services, upon request by you within thirty (30) days after the effective date of termination or expiration of the applicable term for such product or service, we will make any Personal Information related to those products or services for which such term has expired or been terminated, available to you. After such 30-day period, we will have no obligation to maintain, provide or make available such Personal Information, and we may thereafter delete or destroy all copies of the Personal Information in our systems or otherwise in its possession or control, unless legally prohibited from doing so.

International Transfer and Storage of Information

Your Personal Information may be stored and processed at our offices in Canada or at the offices of our third party service providers, Amazon Web Services, in Canada and the United States. Other jurisdictions may have different data protection rules than Canada.  While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located.  Those laws may require disclosure of your Personal Information to authorities in that country. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Information Officer at the email address below.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your Personal Information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification.  We have taken steps to ensure that the only personnel who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security.  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 using the contact information in the “How to Contact Us” section below.

We may also require that you assist us in safeguarding your Personal Information. For example, if you activate an account through a link, you should use a unique and strong passwords and not share your password with others. 

If you have reason to believe that your Personal Information is no longer secure, please contact us immediately using the contact information in the “How to Contact Us” section below.

Accessing and Updating Your Personal Information

We expect you, from time to time, 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 written 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.  You may also challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.

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.

If you object to how we handle your request, you may have the right to make a complaint to the Information and Privacy Commissioner of Ontario in relation to health privacy matters or, if the complaint relates to other privacy matters, to the Privacy Commissioner of Canada.

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, including the practices of your primary care physician who referred you to using our products and services. We do not assume responsibility for the privacy practices of these third parties and we encourage you to review all third-party privacy statements prior to using third-party websites, products, or services.

Children’s Personal Information

Our products and services are not intended for children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. Children under the age of 13 should not use our products and services and should not provide us with their personal information.

How to Contact Us

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be sent to our Privacy Officer as follows:

Address:	Attention: Privacy Officer, Tabiat Research Inc. Schwartz Reisman Innovation Campus  108 College Street, Suite W754 Toronto, ON, M5G 0C6 Canada
By e-mail:	privacy@tabiat.care