Privacy Policy

Your Privacy, Your Care

At Phoenix Digital Health, we believe that protecting your personal information and providing exceptional healthcare go hand in hand.

This summary, which is qualified in its entirety by the detailed Privacy Notice below, explains how we use your personal information to deliver seamless, continuous care through our digital health platform.

What is Continuity of Care?

Continuity of care means that your healthcare journey is connected, coordinated and consistent – from your first interaction with a healthcare professional on our platform through every follow-up and treatment adjustment. Our platform is designed to support this by connecting you with healthcare professionals who have access to the information they need to safely evaluate, treat and monitor your progress over time.

How We Use Your Information to Support Your Care

Your personal information enables our healthcare professionals to provide you with ongoing, high-quality care. Specifically, your personal information is used to:

a. Communicate with you about your health. Our healthcare professionals communicate with you to help you better understand your adherence to treatment plans and to track symptom progression or side effects. This ongoing communication is essential for effective care management.

b. Provide and coordinate services. Healthcare professionals may contact you through your approved communication channels to discuss your evaluations and related treatments, check in on your adherence to prescribed treatment plans, monitor how you are responding to care, confirm or clarify treatment details and share relevant treatment information.

c. Enhance your care. We leverage the latest advancements in artificial intelligence to provide you with the best service possible, subject to appropriate safeguards including the limitation of clinical decisions to our healthcare professionals.

What Information Do We Collect?

We primarily collect personal information as necessary to provide safe and effective care. This includes:

a. Personal Health Information. Depending on the services you use, we may collect information about your medical history, symptoms, ailments, allergies, prescriptions, medical examinations, tests, surgeries, diagnostic imaging and laboratory results. Our healthcare professionals use this information to provide the healthcare services you request and ensure continuity of care.

b. Identification and Contact Information. Your name, date of birth, gender, email address, mailing address, and telephone number help us manage your account, properly identify you, and keep you informed about your care.

How We Protect Your Information

We take your privacy seriously and have implemented robust safeguards to protect your personal information. These include:

• Active monitoring of access to your personal information through activity logs and regular audits.
• Secure storage with reputable cloud storage providers.
• Network security controls to protect against unauthorized access.
• Staff training on proper handling of your personal information and the imposition of contractual confidentiality obligations.

We will never rent or sell any of your personal information that we collect directly from you or as part of our services.

Your Rights and Services

You have meaningful control over your personal information. Subject to applicable law, you may:

a. Withdraw consent for future processing of your information (though you cannot withdraw consent for processing that has already occurred).

b. Update your personal information directly in your account to ensure it remains accurate and up to date.

c. Request access to your records, including your account and medical records.

d. Request deletion of your personal information in our possession.

e. Manage your communication and privacy preferences through the settings tab in your account, including opting out of marketing communications and AI personalization settings.

This Privacy Notice applies to the website at phoenix.ca and any other website, web or mobile app offered by Phoenix Digital Health Inc. (“Phoenix DH”, “we”, “our” and “us”) on which this Privacy Notice is posted (the “Platform”).

Detailed Privacy Notice

This Privacy Notice applies to all Personal Information and Personal Health Information (both as defined below) that Phoenix DH collects from visitors to the Platform and users of our Services (“Users”, “you” and “your”).

Phoenix DH and its affiliates provide a subscription-based, telehealth Platform that connects individuals with licensed independent physicians, pharmacists, nurse practitioners and other regulated healthcare professionals (“Healthcare Professionals”) to receive virtual health and wellness services and products to facilitate continuity of care, including but not limited to:

a. healthcare evaluations, prescriptions and other prescribed treatment, treatment monitoring, adherence tracking, care coordination, and preventive health services provided by Healthcare Professionals;

b. diagnostics, lab testing and related services provided by qualified third-party labs and other service providers; and

c. pharmaceutical and compounding prescription services provided by licensed pharmacists to fulfill prescriptions provided by licensed Healthcare Professionals after completing healthcare evaluations (collectively or individually, the “Healthcare Services”).

In addition to the above Healthcare Services, Phoenix DH may provide other health or wellness services or products, including connected devices, that are offered directly via the Platform or through our affiliates from time to time (collectively, with the Healthcare Services, the “Services”).

By interacting with the Platform, you acknowledge that the collection, use and disclosure of your Personal Information and Personal Health Information will be governed by this Privacy Notice.

This Privacy Notice is divided into the following sections:

1. Accountability

2. Limiting Collection: What Information Do We Collect and How?

3. Limiting Use: How Do We Use Your Personal Information and PHI?

4. Sharing: When Do We Share Your Personal Information and PHI with Others?

5. Personalized Marketing, Communication and AI Tools

6. AI and Automated Decision-Making

7. Safeguards: How Do We Protect Your Personal Information and PHI?

8. Data Retention: How Long Do We Keep Your Personal Information and PHI?

9. Data Storage and Transfer

10. Third-Party Services and Links

11. Your Privacy Rights

12. Your Privacy Preferences

13. Information About Our Privacy Governance Policies and Practices

14. Changes to This Privacy Notice

15. Contact Us

Definitions

Capitalized terms used but not otherwise defined below or throughout this Privacy Notice have the meaning assigned to them in Phoenix DH’s Terms of Use.

“De-identified Information” is information that cannot, either alone or with other information, reasonably identify an individual. Any De-identified Information within our control will not be used by us, either alone or in combination with other information, to identify a specific individual and is not considered to be Personal Information or Personal Health Information.

“Medical Record” means any User PHI that is used for the facilitation of healthcare evaluations and Healthcare Services.

“Personal Information” means information that identifies you or could be used in combination with other information to identify you, or as otherwise defined in applicable privacy and data protection statutes.

“Personal Health Information” or “PHI” means information about you, while living or deceased, that relates to your physical or mental health and/or the provision of health care to you, or as otherwise defined in applicable health privacy and data protection statutes.

“Pseudonymized Information” is information from which all direct personal identifiers have been removed but retains some indirect identifiers. We treat all Pseudonymized Information as Personal Information or Personal Health Information (as applicable) and safeguard such information in accordance with this Privacy Notice.

1. Accountability

Phoenix DH takes the privacy of your Personal Information and PHI seriously and is committed to safeguarding it. We have developed and implemented policies, practices and procedures to protect Personal Information and PHI and we train our staff in our Personal Information and PHI handling practices. To the extent Personal Information and/or PHI is shared with Healthcare Professionals or third-party service providers who assist us in providing our Services, those Healthcare Professionals and service providers must adhere to contractual requirements that restrict their use and disclosure of such information to only as needed for the provision of Services. In certain provinces, the Healthcare Professionals will be directly accountable to you for the handling of your PHI.

We commit not to rent or sell any of your Personal Information or PHI we collect directly from you or as part of our Services.

We comply, and require Healthcare Professionals and service providers that work with us to comply, with applicable laws, including privacy and data protection legislation such as the Personal Information Protection and Electronic Documents Act (Canada) and substantially similar provincial privacy legislation; provincial legislation relating to PHI; anti-spam and telemarketing laws; and the rules and regulations of regulatory authorities having jurisdiction over Healthcare Professionals.

2. Limiting Collection: What Information Do We Collect and How?

The ways we collect Personal Information and PHI can be broadly categorized as follows.

Information you provide to us directly: When you visit or use parts of our Platform, depending on whether or how you use our Services, we may ask you to provide the following Personal Information or PHI to us, Healthcare Professionals who work with us, or our third-party service providers:

a. Identification and Contact Information: Your full name, date of birth, gender, email address, home mailing address, and telephone number when you create an account to use our Services. This information is used to manage your account, properly identify you, contact you, provide you with our Services, and process credit card payments for your subscription to our Services. We do not collect payment details, which are collected directly by our third-party payment processor, as described below.

b. Personal Health Information (PHI): The types of PHI collected depend on the nature of your use of the Services and your particular circumstances, and may include your provincial health card number, the medical treatment you are interested in and why, your medical history, symptoms, ailments, allergies, prescriptions, health or medical services you receive, medical examinations, tests and surgeries including diagnostic imaging and laboratory results, whether you donated any organs or fluids, and other information you choose to provide. We and the Healthcare Professionals who assist us in providing our Services collect this information in order to provide you with the Healthcare Services you request and ensure continuity of care.

c. Identity Verification Information: Your name, date of birth, any email addresses or phone numbers and copies of government-issued photo identification, such as a driver’s licence or passport, to verify your identity. This information is collected by our third-party service provider, Trulioo. While we do not obtain copies of your photo identification, we do receive pertinent information abstracted from the identification. For more information, please refer to Trulioo’s privacy policy at: https://www.trulioo.com/services-privacy-policy#2

d. Payment Information: Credit card information and any information related to your payment transactions are collected by our third-party payment processor and is governed by our payment processor’s privacy policy. This information is not shared with or accessed by Phoenix DH. Please see our third-party payment processor’s privacy policy for more information about its handling of your information.

e. Mailing List Information: Your name and email address if you sign up to our mailing list. This information is used to send you promotional and informational material. You can choose to unsubscribe at any time.

f. Inquiry Information: Your name, email address, residential address and any other Personal Information you choose to provide to us if you contact us with a query. This information is used to respond to you.

If you do not wish to provide us with all or some of the Personal Information or PHI required to open an account and to receive the Services you do not have to, but it might mean you cannot receive our Services or might otherwise affect our ability to provide our Services.

Information collected in the course of, or related to, providing Healthcare Services to you:

Depending on the nature of the Services being requested, we may collect the Personal Information and/or PHI noted above when you complete a questionnaire, request a healthcare evaluation and/or through asynchronous chat. We may also collect this information in connection with:

a. Healthcare Professionals conducting an evaluation or communicating with you.

b. your use of diagnostic or other pharmaceutical services.

c. Healthcare Professionals generating PHI about you in the Platform, such as prescriptions and healthcare evaluation notes.

d. information being generated from digital diagnostic or artificial intelligence (“AI”) triage tools.

Information from other sources: We may receive Personal Information about you from other sources. For example, we will receive Personal Information from our payment processor regarding whether the credit card details you entered have been accepted or declined.

Information we collect automatically: We may automatically collect some technical information when you visit our Platform that platforms like Google Analytics may collect about your interaction with our Platform.

This includes your Internet protocol address (“IP address”), the geographic location of your IP address, device type, what pages you looked at, what links you clicked on, your browser type and configuration, the date and time of use, language preferences, your interactions with the Platform, and cookie data. We use this information to detect problems, improve the navigation of our Platform so it is easier to use and to determine which aspects of our Services may interest you. IP addresses are treated as Personal Information and if we use any technical information alone or in combination with other information to identify you, we will also treat it as Personal Information in accordance with this Privacy Notice.

a. If you consented to receive promotional electronic messages from us, we may track whether you opened certain types of promotional messages, whether you looked for information about a particular topic or service, and responses to our communications including email, telephone or text to make inferences about other products and services in which you might be interested, or to provide consistent experiences across devices.

b. We may collect information from cookies, SDKs, device IDs, and pixels to provide consistent experiences across devices. Users may adjust settings in our Privacy Center.

The technologies we use for this automatic data collection may include:

a. Cookies (or mobile cookies). Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. You can choose to disable or block cookies on your browser, as described below under the heading “Your Privacy Preferences”.

b. Log files. Log files track actions occurring on the Platform, and collect data including your IP address, MAC address, browser type, Internet service provider, referring/exit pages, and date/timestamps.

c. Web beacons. Small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) permit us, for example, to count users who have visited certain pages and other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

d. Analytics and Interest-based advertising: We use Google Analytics to provide statistics about the visitors to our Platform and Google Ads to collect advertising-related data and serve tailored ads to you across the Internet. These technologies track and analyze information, including, without limitation, search engine use, display advertising, pay-per-click networks, email marketing and digital collateral such as links within PDF documents. More information about Google Analytics and Google Ads is available here.

3. Limiting Use: How Do We Use Your Personal Information and PHI?

We use Personal Information and PHI for the following purposes:

a. To communicate with you: We may use your Personal Information and PHI in connection with: (i) providing you with continuity of care, including to better understand your adherence to treatment plans and symptom progression or side effects; (ii) providing you with information you requested from us or information we must send to you; (iii) operational communications, like information regarding your account, or your subscription to our Services; (iv) changes to our Platform, or changes to this Privacy Notice or our Terms of Use; (v) any questions, reminders, notifications related to your account or your use of your account or addressing customer service issues and troubleshooting problems with your account; (vi) to notify and alert you about data breaches, actual or potential fraud, identity theft and other fraud or security-related activities; (vii) updates or disclosures required by law; (viii) with your consent, to contact you through email, text, in-app messaging, and phone outreach; and (ix) to honour your communication preferences, including by maintaining an unsubscribe list and an internal do not call list.

b. To provide Services: We may use your (i) Personal Information and PHI to provide the Services, and (ii) Personal Information to manage our business operations such as to register your account, to authenticate you when you log into your account, to deliver the Services, and to protect the security or integrity of our Platform, our Services, and our business. This may include Healthcare Professionals contacting you through your approved communication channels to discuss your healthcare evaluations and related treatments, check in on your adherence to the prescribed treatment plan, and monitor your symptom progression or side effects, including telephone outreach to confirm or clarify your treatment or with other relevant treatment information.

c. To improve our Platform and Services and develop new ones: We may use your Personal Information to monitor how you use the Platform and the Services, and we may use automated systems and AI to analyze usage patterns and feedback to enhance features and design new offerings.

d. To personalize and market our Services to you: We may use your Personal Information with AI and automated systems to support healthcare evaluations, analyze your interactions, preferences and cohort trends to tailor our Services, Content and recommendations across email, text, telephone, and other communication channels you enable from time to time, and to conduct retention modeling.

e. To detect and prevent any fraudulent or malicious activity: We may use your Personal Information to detect and prevent fraudulent or malicious activity and to make sure that our Platform, Content and Services are used fairly and according to our Terms of Use.

f. To send you targeted advertisements, personalized notices and promotional messages, and news about us: With your consent, where required by applicable law, we may use your Personal Information to send you targeted advertisements, personalized notices and promotional messages and news about us across the communication channels you select in the Settings tab of your account.

g. To create De-identified Information and/or Pseudonymized Information: We may use your Personal Information to create De-identified Information and Pseudonymized Information. We will not attempt to re-identify De-identified Information.

h. For analytics, research, algorithm training, AI model training and evaluation: We may use De-identified Information to improve our Services, develop new features, perform analytics, train AI systems and measure marketing effectiveness.

i. To comply with any laws and regulations: We may use your Personal Information and PHI to comply with any laws and regulations, including by maintaining any unsubscribe lists or “do not call” lists as required under applicable anti-spam and telemarketing laws.

4. Sharing: When Do We Share Your Personal Information and PHI with Others?

Service Providers and Affiliates: We may share your Personal Information and PHI with our service providers and our affiliates that help us with our business operations, including payment processors, customer engagement platforms, email/text message service providers and website hosts.

Healthcare Professionals: We may share your Personal Information and PHI with Healthcare Professionals that help us provide our Services. Information accessible by Healthcare Professionals may include, but is not limited to, your name, email address, phone number, gender, date of birth, province of residence, medical history, symptoms, ailments, prescriptions (as applicable).

Other Healthcare Professionals: When diagnostic, laboratory or pharmaceutical services are required prior to or in connection with Healthcare Services, we may share Personal Information or PHI with other healthcare professionals, including a laboratory or pharmacy, at your direction and as necessary to facilitate the delivery of the Healthcare Services you request, including: (i) first and last name, (ii) date of birth, (iii) address, (iv) telephone number, and (v) the PHI specifically related to the applicable requisition or service.

Legal Processes: We may share your Personal Information or PHI, as applicable, without your explicit consent and without notice to you:

a. To collect a debt from you or to prevent or investigate fraudulent or illegal activity on your account.

b. To comply with an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or government body with competent jurisdiction to compel disclosure of your Personal Information or PHI, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities, including to meet national security or law enforcement requirements, to prevent, investigate, or take action against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, this Privacy Notice, or as otherwise required by law.

c. To establish or defend our legal rights. Where possible and appropriate, we will notify you.

d. To an actual or potential buyer of Phoenix DH (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business, in accordance with applicable laws.

e. To protect the security of the Platform, our Services, and your account.

5. Personalized Marketing, Communication and AI Tools

Phoenix may use automated systems, including AI-based tools, to analyze your interactions and preferences to deliver tailored offers, reminders and health-related information through communications channels such as email, text message, phone, or other digital platforms, in accordance with applicable law. Phoenix or its authorized service providers may contact you by phone to confirm your communication preferences, obtain consent to contact you and to check in/follow up on your treatment, and never for promotional calls without express consent. You may withdraw your consent at any time as described in Section 12 – “Your Privacy Preferences” below.

6. AI and Automated Decision-Making

We may use internal tools and third-party software using AI tools and machine learning to support the delivery of our Services, both operationally (including generating content, materials and responses intended to assist with operational, educational and engagement needs, communications, personalization, sending automated responses, categorizing inquiries and providing general information about your care and services) and clinically (diagnostic support, triage and symptom intake and to recommend Healthcare Services). These systems may analyze your Pseudonymized Information to support us and our service providers in delivering our Services.

Where AI tools or any other automated systems are used for clinical purposes, all significant medical or legal decisions are reviewed by Healthcare Professionals. We do not use AI to independently render clinical diagnoses or treatment decisions.

7. Safeguards: How Do We Protect Your Personal Information and PHI?

We take administrative, technical and physical precautions to safeguard your Personal Information and PHI against theft, loss, and unauthorized access, use, disclosure, copying, modification or disclosure (a “Data Breach”). Although we cannot guarantee that Data Breaches will never occur, we try to minimize these risks by:

a. Active monitoring: We monitor access to your Personal Information and PHI through activity logs and regular audits to ensure that no unauthorized access attempts have been made.

b. Secure storage: We store your Personal Information and PHI over which we have custody or control with reputable cloud storage providers.

c. Network security: We have controls in place to protect against unauthorized access, including segregating our internal systems from our publicly-accessible systems.

d. Training: Our policies and procedures address and train our staff on the handling of Personal Information and PHI. All our staff members and contractors are legally bound to confidentiality.

We require our affiliates and service providers to protect your Personal Information and PHI that we share with them or that they collect from you directly.

The safety and security of your Personal Information also depends on you. You are responsible for keeping your account username and password confidential. Please do not share your username and/or password with anyone.

8. Data Retention: How Long Do We Keep Your Personal Information and PHI?

We keep your Personal Information and PHI that is in our custody or control if we have a legal or legitimate business need to keep it, for example, to provide you the Services to which you subscribe or to comply with information retention requirements set out in applicable laws. Once our relationship ends, we may retain archived copies of your Personal Information and PHI in our custody or control for legitimate business purposes, such as to defend a contractual claim, for audit purposes, and to comply with applicable law. We maintain a records retention and destruction policy to destroy information when we no longer have a business need for it and are not required by law to keep it.

We and our service providers may continue to store and use De-identified Information to improve our respective products and services. Among other things, De-identified information may be retained and used for analytics, research, AI training and evaluation, and service improvements, and will not be used to attempt to identify you.

Without limiting the foregoing, Phoenix DH retains PHI so that the Healthcare Professionals who provide Healthcare Services through us can comply with the minimum data retention periods established by their governing bodies.

9. Data Storage and Transfer

The PHI we or our service providers collect from you will be processed and stored in Canada. However, some of your Personal Information may be processed, stored or transferred by us or our service providers outside of Canada or the province in which you reside (which may include transfer outside of Quebec for Quebec residents), including to the United States. If your Personal Information is processed, stored or transferred outside Canada, it may be subject to the laws of the country in which it is processed or stored and may be accessible without notice to you by the courts, law enforcement and national security authorities of such jurisdiction. You can obtain more information about our policies and practices with respect to the use of non-Canadian service providers by contacting us at support@phoenix.ca.

10. Third-Party Services and Links

You may access third-party websites through links available on our Platform. These links are provided for convenience only. Once you leave our Platform and you are redirected to a third-party website or application, you are no longer governed by this Privacy Notice or our Terms of Use. We have no control over those third-party websites, and you access them at your own risk. We recommend that you read the privacy policies of these third-party providers so you can understand how they handle your Personal Information and PHI. You acknowledge that these links may lead you to third parties that may operate outside of Canada. If you provide your Personal Information or PHI to these entities, then your information may become subject to the laws of the jurisdiction(s) in which that site operates or where its facilities are located.

11. Your Privacy Rights

Only individuals who are the age of majority or older in their jurisdiction of residence may subscribe to our Services and access the Platform. Therefore, we do not knowingly collect Personal Information or PHI of minors. If it comes to our attention that we have unknowingly collected such information, we will delete it.

Your Privacy Rights: Depending on the jurisdiction in which you reside, you may have certain rights (including those described below) with respect to your Personal Information and PHI that we collect, use, and disclose. To exercise any of your privacy rights, please contact us at support@phoenix.ca. Prior to responding to your request, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws.

a. Withdrawal of Consent: You can withdraw your consent to our collection, use, and disclosure of your Personal Information or PHI but you cannot withdraw your consent for our collection, use, and disclosure of your Personal Information or PHI that began before the date on which you withdrew your consent. You will also not be able to withdraw your consent where our use or disclosure of your Personal Information or PHI is authorized or required by law. Please visit the Settings tab in your account or contact us as set out above if you wish to withdraw your consent.

b. Updating Your Personal Information: We want to ensure that the Personal Information and the PHI we collect from you and that is in our custody or control is accurate, complete, and up-to-date for the purpose for which it is to be used. You may update certain Personal Information directly in your account.

c. Access to and Rectification of your Information: You may request access to your Personal Information and PHI and correction of incomplete or inaccurate information. We will strive to address any correction requests promptly. If we dispute a correction request, we will note the disagreement and explain our reasons.

d. Access to Your Medical Records: Users can request access to their Medical Record at any time within the outlined Medical Record Retention Schedule set out above. Medical Records may be disclosed to you or to another individual/location based on your consent. We will never disclose your Medical Record to an external Healthcare Professional without collecting the required consent from you.

e. Deletion of Your Personal Information and PHI: You may be entitled to the deletion of your Personal Information and PHI that is in our possession or control in certain circumstances and in accordance with applicable law. To close your account or to request that the Personal Information or PHI we have about you be deleted, please contact us as set out above.

In some instances, your privacy rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

If you believe that we have not adhered to this Privacy Notice you may challenge our compliance with this Privacy Notice and applicable privacy laws. Please notify our Chief Privacy Officer of your complaint by emailing at support@phoenix.ca. We pledge to address your complaint promptly.

12. Your Privacy Preferences

You can exercise the following privacy preferences at any time:

a. Opt-in to marketing communications: When you register your account, you can choose to provide your consent to receive marketing and promotional electronic messages.

b. Opt-out of marketing communications: Marketing and promotional electronic messages are sent in accordance with applicable anti-spam laws. You can manage subscriptions, preferences regarding the means by which we communicate with you and AI personalization settings in your account settings. You can also unsubscribe from promotional electronic messages by clicking the “unsubscribe” link in emails or by replying “STOP” to text messages. You can ask to be added to our internal “do not call” list if you do not wish to receive unsolicited telemarketing calls from us. Even if you unsubscribe from promotional electronic messages and/or ask to be added to our internal do not call list, in accordance with applicable law, we may still contact you via these communication channels in order to provide Services you have requested or regarding transactional issues related to your account or subscription.

c. Limit online tracking: There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

a. Blocking cookies in your browser: You can disable or block cookies by following the instructions on your web browser. While you do not need to enable cookies to visit our Platform, certain features of our Platform depend on the use of cookies. Accordingly, if you choose to block cookies you may not be able to use those features or may lose preferences based on those cookies.

b. Using privacy plug-ins or browsers: You can block our Platform from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger or Ghostery and configuring them to block third-party cookies/trackers.

c. Google Analytics opt-out: You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

d. Advertising industry opt-out tools: If you prefer not to receive targeted advertising, you can opt out of some network advertising programs that use your information. For example, the Digital Advertising Alliance opt-out tool for Canada (https://youradchoices.ca/) identifies its member companies that have cookies on your browser and provides links to those companies’ pages where you can opt out of receiving targeted advertisements from those companies. In addition, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. Please note that even if you choose to opt out of targeted advertising, you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you and your interests.

13. Information About Our Privacy Governance Policies and Practices

We are committed to protecting Personal Information and PHI and have implemented a comprehensive set of policies and practices that govern our treatment of Personal Information and PHI. This includes, among other things:

• Policies and procedures to protect Personal Information and PHI in our custody and control from unauthorized access, use or disclosure.
• Processes to respond to data subject requests and complaints in a timely and effective manner.
• A framework for the retention and destruction of Personal Information and PHI to ensure compliance with legal obligations, and to securely destroy Personal Information and PHI once no longer required.
• A framework that defines the roles and responsibilities for our employees with respect to the treatment of Personal Information and PHI throughout the lifecycle of the information.

14. Changes to This Privacy Notice

We may change or update this Privacy Notice from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, services or products.

When we make changes to this Privacy Notice, we will revise the “Last Updated” date at the top of the policy. We will also display a notice on the Platform prompting Users with accounts and/or subscriptions to review and accept the changes to the Privacy Notice. If you do not accept the changes, you will not be able to use the Services and must terminate your subscription. Visitors to the Platform will become subject to the version of the Privacy Notice then in effect and should review this page periodically.

If we make substantive changes to this Privacy Notice, then in addition to displaying a notice on the Platform, we may also notify Users by email at the email address associated with your account. The changes to the Privacy Notice will take effect on the date on which they were made or on the date provided in the notice.

15. Contact Us

We have appointed a Chief Privacy Officer accountable for our Personal Information and PHI handling practices.

If you would like to exercise your privacy rights or if you have any questions or complaints about this Privacy Notice, or the manner in which your Personal Information and/or PHI has been collected or handled by us, please contact our Chief Privacy Officer at support@phoenix.ca.