Privacy Policy


Effective Date: October 19, 2022

12043262 Canada Inc. (the “Company”, “we”, “us”) respects your privacy and will only collect, use or disclose your personally identifiable information (personal information) in accordance with our Privacy Policy and applicable privacy laws.  This Privacy Policy describes what personal information we collect through our website(s), our mobile applications and related services (collectively, the “Sites”), how we use personal information, and the manner in which personal information may be disclosed or shared by the Company.  

For the purpose of this Privacy Policy, personal information means any information that, by itself or in combination with other information, identifies or can reasonably be used to identify an individual.  It may include, for example, your name, email address, telephone number, address, date of birth, financial information and health information.  Personal information does not include information that is anonymized or publicly available information that has not been combined with non-public personal information.  

Consent for the collection, use and disclosure of personal information

When you sign up for or use the Sites, we ask you to confirm that you've read and agree to our Privacy Policy.  By submitting your personal information through the Sites, you consent to the collection, use, and disclosure of such information as set out in this Privacy Policy.  

What personal information do we collect?

Generally, you may browse our Sites without providing any personal information.  You are under no obligation to provide personal information, with the caveat that your refusal to do so may prevent you from using certain portions of the Sites.    

The Company collects your personal information when you use the following applications and services:

Information you store on your Profile

We collect personal information you provide when you create an account for any Site, including your name, email address, and date of birth. You can provide optional health information when using any Site, or to your account profile ("Profile"), for example, health goals, medications, conditions, and other personal information which helps to personalize your Site experience.  You choose what personal information to add to your Profile or to upload to any Site.

Information to purchase the Company packages and services

If you decide to sign up for any services offered for a Site, we, or any third party assisting with such Site (each a “Provider”, collectively the “Providers”), may ask you to provide additional information, including payment information.  For more information, please consult our Terms of Use.  

Why do we ask you for certain types of information?

When using the Sites, you have access to general health information, answers and tips, and expert content.  Certain health conditions and appropriate actions vary depending on your age group, medical history, geography, and gender.  Personal information that you add to your Profile may allow the Company to provide you with a more personalized online experience, and personal information that you provide to any Site may allow you to engage with other users relating to various topics.  Personal information that you add to your is not visible to other users through the Sites, but information that you provide to any Site for posting on a message board or otherwise sharing with one or more other users may be visible to other users and Providers.    

How do we use your information?

We use your personal information for the purpose for which it was collected, as well as other purposes for which you have given consent.  

By accepting this Privacy Policy you are giving consent for use of your personal information by the Company and Providers for the following purposes:

  • to allow us to deal with your personal information in a reasonable manner;  
  • to allow us to provide your personal information to Providers and other third parties we engage to provide or support the Sites;
  • to allow us to use and store your personal information for the purpose of providing you with the Sites;  
  • to allow us to use the personal information in your Profile and your health and wellness goals to help you better utilize the Sites and to present you with relevant information via the Sites;  
  • to create, log into, and manage the Profile and any account(s) you set-up for the Site(s);
  • to receive and process your comments about the Sites;
  • to comply with our legal obligations and regulatory requirements;
  • to develop and manage our business and operations, including but not limited to for billing, accounting, and debt collection services relating to any Sites;
  • to establish, maintain, and manage our relationships with users of the Sites;
  • to detect and protect the Company, Providers, and other third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with our insurers, and to otherwise communicate with our insurers;
  • to review potential fraud and as required in the course of activities to achieve credit risk reduction;
  • to generate analytics and statistical data;
  • to allow us to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your personal information by the Company, and by any third party service provider that controls the server where such personal information is stored, processed, or otherwise used, as required for such storage, processing and for all uses by the Company and Providers thereof;  
  • to comply with our legal obligations, resolve disputes, and enforce our agreements and as required and/or permitted by applicable privacy laws; and
  • to provide you with information you have requested from us, for example, we may, from time-to-time, use your personal information to contact you about changes or enhancements related to the Company or any Sites.

We further may use conduct marketing and provide notifications in accordance with the following:

Marketing: In accordance with anti-spam laws, we obtain your consent in order to send you commercial electronic messages. You may subscribe or unsubscribe to receive marketing communications from us, such as announcements of new features. We do not share email addresses or other contact information with third parties, other than Providers as necessary for the Sites, without your permission.  

Notifications: We will ask you if you want to receive notifications when you open an account with the Company or during your use of the Sites. If you agree, the Company may send you email, SMS, or mobile push notices, providing you with account-related reminders or updates, or letting you know that you have a message on Sites.

Cross-Border Transfer

The collection, use and disclosure of your personal information through the Sites or related services is governed by applicable Canadian laws and this Privacy Policy.  

The Company may transfer your personal information outside Canada to its affiliates, Providers or other third party service providers with operations in other countries, which are subject to laws of a foreign jurisdiction.  By accepting this Privacy Policy, using the Sites or providing us with your personal information you acknowledge and consent to your personal information being processed by third parties on the Company’s behalf and transferred, accessed and/or stored in countries outside Canada.  

Consent Exceptions

There are legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if we must comply with a court order or governmental order.

We use may use personal information without your knowledge or consent in limited circumstances whereby we are required to provide personal information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance we may have a legal duty or right to disclose personal information without your knowledge or consent. Various government agencies and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.

Automated decision making and profiling

We use may use relevant information in your Profile to generate better responses to your questions, including health questions. For example, we may use the personal information you provide about any medical conditions to better direct you to information or service providers with relevant knowledge or expertise, or to relevant message threads from other users. Your experience on the Sites may be tailored to you based on the information you provide in your Profile. The personal information you provide is not used for advertising.


We do not actively or knowingly collect personal information from children or anyone below the age majority in their applicable jurisdiction. We are committed to protecting the privacy of children. If personal information has been collected inadvertently from a child, the guardian of the child may contact us for the purpose of deleting this information. If we believe any person under the age of majority in his or her jurisdiction of residence is using the Sites we will not process any personal information of that person.


While we, or our Providers, collect the personal information that you supply, we do so with the understanding that any such information that you supply is accurate. It is important to us that your personal information that you provide is accurate and complete. Having accurate information about you enables us to provide you with better products and services. You can help us keep personal information up-to-date by keeping us informed of any changes, such as a change of address, telephone number or any other circumstances. We will not be able to provide you with any notices if we do not have accurate contact information for you and we will bear no responsibility for any action or omission as a result of the lack of accurate contact information or personal information for you.  

Disclosing personal information to third parties

With whom do we share your personal information?

In some instances we may retain Providers or other companies or individuals to perform functions on our behalf, including, but not limited to, website developers, service and technology providers., payment processors, data hosting providers.  Providers and other third parties may be provided with access to your personal information to perform the functions for which they have been retained.  Our agreements with Providers and other third parties will not permit them to use your personal information for any other purposes and commit them to comply with applicable data privacy standards.  

We may disclose your personal information as we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request.

Who else can see your personal information?

Personal information is stored securely in your Profile, which is not visible to other users through the Sites.  

Should you upload any personal information to any message board or through any message to any one or more other users, other people may be able to access such personal information, and the personal information may be used by us, other people, Providers or other third parties.  


We use physical, organizational and technical industry-standard security safeguards commensurate to the sensitivity of data collected, used or disclosed such as encryption in transit and at rest.  We use a variety of technologies and procedures to help protect the security of your personal information from unauthorized access, use, or disclosure.  

We have implemented and maintain reasonable and appropriate security measures, procedures and practices to protect against the loss and unauthorized access, use, modification, destruction or disclosure of your personal information while it is our custody or under our control.  

Public Content

Some content on the Sites is publicly visible by logged in or logged out users ("Public Content"). Any information provided in Public Content might be read, collected, and used by others who access them. Should you post any personal information as Public Content to the Sites we cannot control how such Public Content is seen or used.  

How can I access or correct my data?

You can add, edit, or delete optional information appearing in your Profile at any time in your account settings ("Settings"). You can edit, but not remove, certain information (like an email address) required for login and to use the Sites.  

Cookies and Analytics

For more information about how the Company uses cookies, please see its Cookie Policy.  A "cookie" is a data element that a website can send to your browser, which may then be stored on your system.  The Sites use different kinds of cookies and/or uses services which use “cookies”, for example,  

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the Sites.    

To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, visit:

Links to Third Party Sites

The Sites may contain links to other third party sites. When you click on one of these links you are visiting a website operated by someone other than the Company, and the operator of that website may have different privacy policies and terms of use. We are not responsible for the individual privacy practices of those third party sites. We encourage you to investigate the privacy policies and terms of use of these third party operators.

Third Party Service Providers

We may engage Providers and other third party service providers to assist with the provision of Sites and services incorporated in or linked to from the Sites (the “Service Providers”). For example, third party service providers may store personal information and other information, may provide Site content or services via their platforms, and if we obtain your credit card information, we may employ third party payment processors to process payments.  

We shall not be responsible for the activities of any such Service Providers and such Service Providers may require you to agree and comply with their terms, conditions and policies. You bear all responsibility and liability relating to such term, conditions and policies and your compliance therewith. We further do not bear any responsibility or liability for any personal information or other information you provide to such Service Providers.


While we will take steps to protect your personal information, the Company cannot guarantee the security of any information you transmit to us. We will not be responsible whatsoever for the inadvertent disclosure of your personal information or theft of your personal information, or any handling, processing or other use of your personal information or other information by any Provider, third party sites, or Service Providers.  

Consequently, the Company, its affiliates, related companies and arm's length companies and any directors, officers, employees, agents do not provide any representation, warranty or guarantee that your personal information will be protected against misuse, loss or modification. We do not accept and do not bear any liability for the security of your, or any other user's personal information.

Non-personal Information & Anonymization

We may also collect non-personal information, being information that does not identify an individual. Examples of non-personal information we may collect include, but are not limited to, your web browser version or your operating system. We also may obtain information about which website you have come from or that you visit next after using any Site. Other non-personal information is collected or derived by us in the course of operating the Sites. Non-personal information which is provided through your browser, or stored on a “Cookie”, occurs when you choose to visit some Sites, such as our websites.  

We may also generate anonymized data. Anonymized data will not include any information that specifically identifies an individual. We may further generate aggregated data, including, but not limited to, the number of visitors and average time spent on any Sites.

Retention of your personal information

Your personal information will be stored as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or as long as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.  When we no longer are required to retain the information, we will destroy, erase, or de-identify the information.  

Contacting us

Should you have any questions or concerns about this Privacy Policy or the Company’s practices, you may reach the Company here, or  


500-30 Wellington Street West

Box 129, Commerce Court

Toronto, ON, Canada

M5L 1E2

You may also contact the Office of the Privacy Commissioner of Canada or provincial Information and Privacy Commissioner (as applicable) with any questions or concerns.  

Revisions to this Privacy Policy

We reserve the right to change this Privacy Policy at any time and such modifications shall be effective immediately, as of the date indicated as the effective date herein.


Successors and Assigns  

You hereby consent to the successors and assigns of the Company collecting, using and disclosing your personal information for substantially similar purposes as described in this Privacy Policy.

© 12043262 Canada Inc., 2022