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NiaHealth Privacy Policy

Last updated: February 17, 2024

15459354 CANADA INC., doing business as NiaHealth, (“NiaHealth”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information when you visit our website located at https://www.niahealth.co/ (the “Website”), use our health, wellness and longevity services, or otherwise interact with us.

TABLE OF CONTENTS
● Accountability
● Collection and Use of Personal Information
● Sharing of Personal Information
● Information about Our Website
● Interest-Based Advertising
● Safeguards and Retention
● Your Choices
● Updates to the Privacy Policy
● Contact Us

ACCOUNTABILITY
NiaHealth’s services include consultations with healthcare practitioners and other trained personnel. In most jurisdictions, NiaHealth has overall responsibility for protecting your personal information, including personal health information, and we are directly accountable to you.In Alberta, your healthcare practitioners have overall responsibility for the privacy of your personal information, including personal health information, and NiaHealth assists them with that responsibility. More precisely, in Alberta, NiaHealth collects, uses, and discloses personal health information on behalf of healthcare practitioners who are ‘custodians’, as defined in theAlberta Health Information Act.For all other personal information collected through our services, including through your use of services that are not delivered by healthcare practitioners, such as dietician services in Alberta, NiaHealth has overall responsibility across Canada.

COLLECTION AND USE OF PERSONAL INFORMATION
We may collect personal information when you:
‍● Register for and use our services
● Pay for our services
● Sign up to receive marketing emails such as newsletters and updates
● Enter a contest or participate in a promotion
● Participate in a NiaHealth survey
● Consent to participate in research
● Attend one of our events
● Apply for a job at NiaHealth
● Contact us

Registration and Use of our Services:
When you sign up to use our use our health, wellness and longevity services, we will collect your name, age, address, phone number, email address, gender, ethnicity, health history, information about your current health, wellbeing and lifestyle habits, medication information and blood sample. Our healthcare practitioners and our third party laboratory service providers use this information to analyze biomarkers in your blood sample and generate a personalized report that summarizes our analysis and offers recommendations in respect of your health, wellness and longevity.

Consultations with healthcare practitioners: If you have a consultation with one of our healthcare practitioners to review your health report with them, the practitioner will use your personal information to deliver this service. Our consultations are offered remotely, either through real-time video or audio technology. If you choose to use these services, you may be asked to verify your identity. We do our best to make sure that any information you give to us during virtual care visits is private and secure; however, there may be circumstances in which your communications with us, including the transmission of certain sensitive personal health information, will be through unencrypted e-communication. As with all online communications, there is a risk that your personal information may be intercepted or unintentionally accessed or disclosed, and this risk is increased when unencrypted e-communication is used. To help mitigate this risk, you should be in a private setting when receiving virtual care and should not use an employer’s or someone else’s computer or device.

Payment: If you purchase a service from NiaHealth, we (or our authorized third-party payment processor) will collect your full name and payment information (including billing address, credit card number, expiry date and CVV code) in order to process the transaction and enable NiaHealth to provide you with the services you have purchased.

Marketing Communications: If you sign up to receive email or text updates or marketing communications from us, we will collect your email address and/or telephone number in order to send you newsletters and updates that may be tailored to your interests and preferences. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or by replying “STOP” to any of our text messages. Alternatively, you can opt-out of receiving communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.We may use services provided by third-party platforms (such as social media and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt out of the use of your information for such purposes, please send a request using any of the methods set forth in the Contact Us section below.Contests and

Promotions: When you enter a contest or participate in a promotion, we may collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you, or that you otherwise provide, including your social media handle, profile picture and public posts or comments you make about our contest on social media networks. We use this information to administer the contest or promotion. As part of a contest or promotion, we may also share or other wise publish the content you submit.

Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys on an optional basis. We use the information collected through our surveys to help us understand our customers’ needs and interests and to develop and improve our services and theWebsite.Research: From time to time, NiaHealth may participate in medical research projects. We will not use or disclose your personal information, including personal health information, for these projects in a manner that can identify you without obtaining your consent in a manner consistent with applicable law.

Events: If you attend one of our events or webinars, we may collect your full name, email address, city, province, postal code, country, phone number, and any other information you may provide us in connection with the event or webinar. We collect this information so that we can communicate with you about the event and contact you about future events.

Employment: In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Contact Us: When you contact us with a comment, question or complaint through email, telephone or our contact form, you may be asked for information that identifies you, such as your name, email address, address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our services. In addition, we may monitor and record our telephone conversations with you for documentation, training, and quality assurance purposes.

Non-Identifiable Information:
We may modify or aggregate your personal information such that it cannot reasonably be associated with you to conduct research and/or analytics with the goal of improving our services and developing new services. We may share such non-identifiable information or insights with certain third parties to assist in research, analytics, planning, or service development.

SHARING OF PERSONAL INFORMATION
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

Service Providers:
Your personal information will be transferred (or otherwise made available)to certain third parties that provide services on our behalf. We use service providers to provide services such as laboratory testing services, hosting the Website, processing payments, and providing analytics, advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We and our service providers may access, store and otherwise process personal information outside ofCanada, including in the United States, United Kingdom or other foreign jurisdictions where we or our service providers are located.

Legal and Compliance:
We and our Canadian, U.S. and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, financing, or sale (including transfers made aspart of insolvency or bankruptcy proceedings) involving all or part of NiaHealth or as part of a corporate reorganization or other change in corporate control.

INFORMATION ABOUT OUR WEBSITE

Visiting our Website:
In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information, such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand website activity and to monitor and improve our Website.
Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of theWebsite’s features.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent,4search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data(including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
● https://policies.google.com/technologies/partner-sites and
● https://support.google.com/analytics/topic/2919631

Third-Party Links: Our Website may contain links to other websites that NiaHealth does no town or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked website. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

INTEREST-BASED ADVERTISING
We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting Out of Interest-Based Advertising:
For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website athttp://youradchoices.ca/choices.

Please note that even if you opt out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes, including analytics, and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again.

SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out in this privacy policy or as otherwise required to meet legal or business requirements.

YOUR CHOICES

Marketing Communications

As indicated above, if you have signed up to receive our email or text communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or by replying “STOP” to any of our text messages. Alternatively, you can opt out of receiving our communications by contacting us using the contact information under “Contact Us” below.

Exercising Your Privacy Rights

Subject to applicable law, you have the right to access, update and correct inaccuracies in, and withdraw consent to our collection, use and disclosure of, your personal information in our custody or control. You may make such a request or withdraw your consent by emailing or writing to us using the contact information set out below. We may request certain personal information for the purpose of verifying your identity.To opt out of interest-based advertising, see the “Interest-Based Advertising” section above.

UPDATES TO THE PRIVACY POLICY

We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated. CONTACT USIf you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to exercise any rights in respect of your personal information, please contact us at:

Privacy Officer
mike@niahealth.co