Insig Corporation (“Insig” or “we”), and our parent company WELL Health Technologies Corp. (“WELL” or “we”) is proud to offer the YourCare website (“Site”) and the YourCare Patient Portal (the “Portal”, collectively “YourCare”). We are committed to protecting your personal information. This Privacy Policy tells you how we do so.

The Portal enables users to access and view their personal health information maintained by OSCAR Pro and Insig Health on behalf of healthcare providers. The Portal may also provides certain services with respect to facilitating healthcare delivery. To do so, we collect the personal information as set out below.

We update this Privacy Policy as needed. Please check it regularly.

1. What information do we collect?

To use the Site and Portal, we collect the personal information as set out below.

Site and Portal Access

Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Site or Portal, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings, language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for online interactions.

These Cookies helps us understand how you use the Site or Portal in order to make improvements. We also use these Cookies to promote our services through marketing and advertising.

You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of the Site’s or Portal’s features, and may prevent us from providing you with the information and services you have requested.

Portal Account

When you register to create a user account to use the Portal, we will collect your name, gender, address and date of birth (to identify you and verify your identity), as well as your mobile phone number and email address (to communicate with you and authenticate your account). For all users under the age of 18, the holder of the account must be the user’s parent or legal guardian. Your child’s name, gender, address and date of birth will be collected to verify their identity and register them to your account.

Direct Marketing

If you sign up to receive direct marketing or promotional communications from WELL and/or YourCare, we will collect your name and e-mail to inform you about the products and services offered by WELL and/or YourCare.

2. Why do we use personal information?

We use your personal information to:

• manage our relationship with you and administer your account,
• provide you the services you request, such as providing access to your personal health information or communicating with healthcare providers,
• to protect our business, and
• to maintain appropriate records for internal administrative purposes.

There are a number of optional services that may be provided through the Portal. We may use your personal information to provide you with services that you request us to perform on your behalf, such as booking an appointment with a healthcare provider.

3. Who do we share your personal information with?

YourCare

We only share your personal information with our service providers, including WELL and its affiliates and subsidiaries, in order to offer you YourCare, including:

• for fraud prevention,
• payment processing,
• providing requested services,
• operating the Portal, and
• customer service.

We only use service providers that ensure a comparable level of protection for your personal information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information for the services requested.

Exceptionally, as allowed or required by law, we may have to disclose your personal information to law enforcement agencies where they demonstrate they have the legal authority to request it.

If we merge with another business, we will inform you of any impact on your personal information.

Healthcare Providers

To use the Portal, you must have an account or be a patient with a healthcare provider who uses OSCAR Pro and Insig Health software. As a result, your use of the Portal is also subject to your healthcare provider’s privacy policy, which would cover the collection, use and disclosure of your personal information and your personal health information. While connected or attempting to connect to a healthcare organization’s system, the healthcare provider may collect, store, process, maintain, upload, sync, transmit, share, disclose, and use certain data and related information, including information or data regarding the characteristics or usage of your device, system and application software, and peripherals as well as your personal information, location data, and other content.

Please read your healthcare provider’s privacy policy if you have any questions about their policies or terms of use.

Apple Health

The Portal supports connectivity to Apple’s Health Records on iPhone, which means that you can choose to use your Portal account to securely download some of your personal health information from participating healthcare providers and organizations.

For more information on how Apple protects user’s privacy when they use Health Records, please visit: https://support.apple.com/en-ca/HT209519.

4. How long do we keep personal information?

We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with industry best-practices and applicable legal and regulatory requirements.

5. How do we keep personal information accurate?

We take reasonable steps to ensure that any personal information in our custody is accurate and up-to-date but we mostly rely on you to notify us of any changes to personal information you provided us.

6. How do we protect your personal information?

We use reasonable and appropriate physical, administrative and technical measures designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with Insig or WELL is prohibited and constitutes grounds for disciplinary action.

The Portal is secured through encryption technologies and only you and your healthcare provider have the ability to view your personal health information. We use physical, organizational and technical industry-standard security safeguards commensurate to the sensitivity of data being displayed on the Portal, such as encryption in transit and at rest.

Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee no breach will ever occur.

7. Where do we store personal information?

All personal information we collect is stored on secure servers in Canada; however, personal information processed by our third-party service providers may be done outside of Canada.

While outside of Canada, personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.

For more information on our service providers or where we store personal information, contact us at privacy@well.company.

8. Links to third-party sites

Our Site may lead you to third party websites, including websites advertising other products or services. Those organizations are separate and distinct from WELL and have their own separate privacy policies. We are not responsible in any way for how any third party collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies of these websites before providing your personal information to them.

9. Direct marketing

You may sign-up to receive marketing or promotional communications from Insig or WELL. Where you have expressly consented, we may share your personal information with WELL so they can inform you about WELL and related products and services, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from Insig or WELL, you can opt-out at any time by:

• using the unsubscribe feature found in our emails and other electronic communications, or
• contacting us via email at marketing@well.company.

We destroy your personal information as soon as you unsubscribe.

10. Your Rights

You also have the right to:

• make a written request to access your personal information,
• request us to restrict our use or disclosure of your personal information,
• object to our use or disclosure of your personal information,
• request that we edit, but not remove, certain information (like an e-mail address),
• request that we transfer to another organization the personal information you have provided us, and
• request us to delete the personal information we hold about you.

Contact us at privacy@well.company to exercise any of these rights. We will respond within 30 days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons. All requests with respect to the editing or removal of personal health information should be directed to your healthcare provider.

We will address all requests with equal attention.

11. Contacting us

Accountability with respect to your personal information is important to both Insig and WELL. In the event that you have any questions (including how personal information is managed by Insig or WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company.

If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.