Effective Date: January 15,2022

RapidScreen Services Inc., together with our affiliates and partners (“us”, “we”) respect your privacy and collect, use or disclose your Personal Information only in accordance with our Privacy Policy and federal and provincial privacy legislation applicable to us (“Privacy Laws”). 

This Privacy Policy (the “Privacy Policy”) describes how we collect Personal Information through the website(s), mobile application(s), platform and services of the Company (collectively, hereinafter referred to as the “Services“), as well as how we use Personal Information and the manner in which Personal Information may be disclosed or shared by us. The term "you" refers to the person or entity visiting the Services, browsing or otherwise using the Services, or receiving any services through the Services. 

The Services operate to be utilized in association with services that may include medical testing, and to otherwise provide information displayed by the Services. We will collect, process, store and otherwise use Personal Information and other data for the purposes of the Services in accordance with this Privacy Policy.

If you utilizing the Services on behalf of a company or organization, you hereby represent and warrant that you have the requisite authority to provide agreement and consents under this Privacy Policy on behalf of such company or organization to create a binding agreement, and any subsequent reference herein to “you” shall be understood by the parties to be a reference to the applicable company or organization, and all consents and agreements herein shall be provided by such company or organization and all of the Personal Information provided by such company or organization or by any of its employees or other persons affiliated therewith.

If you do not consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy, do not provide us with any Personal Information. Please note that some of the Services cannot be provided and/or will not function as intended without the provision of Personal Information. 

This Privacy Policy does not apply to the collection, use and disclosure of Personal Information by health care professionals or assistants thereof ("HCPs") in the course of facilitating any medical test. HCPs are subject to their own respective privacy laws and professional requirements that govern how they collect, use and disclose Personal Information. 

The Services may enable HCPs to receive your Personal Information through the Services to provide medical testing or other services to you. Your use of the Services neither establishes nor governs your relationship with the HCP. The services provided to you by any HCP form a bilateral contractual relationship between you and the HCP and this Privacy Policy does not extend to such contractual relationship. 

• Personal Information 
• For the purposes of this Privacy Policy, the term “Personal Information” means any information that is defined to be personal information under applicable privacy laws. Usually, personal information refers to any information about an identifiable individual or any information that can be used to identify an individual.

Personal Information may include, for example, your name and home address, your date of birth and gender, health information, payment information, your occupation, medical conditions or other health information, your personal financial records or credit information, certain video or images of you, or any personal identification numbers. 

In most circumstances, Personal Information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not Personal Information under this Privacy Policy.

• Consent for the collection, use and disclosure of Personal Information 

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

• Privacy legislation requires us to obtain the consent of an individual to the collection, use or disclosure of Personal Information in many circumstances.

By providing your Personal Information to us, you agree that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy and as otherwise permitted or required by law, and that we may access, process and store your Personal Information in Canada or another jurisdiction.

When we receive Personal Information from you for the purposes of providing you with our Services, or for other uses identified herein, you are providing us with consent as follows: 

• to allow us to deal with that Personal Information in a reasonable manner; 
• to allow us to provide your Personal Information to third parties we engage to provide or support the Services;
• to allow us to use and store your Personal Information for the purpose of providing you with the products and services you purchase from us and to utilize the Services; and
• 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 us. 

If you need to provide us with Personal Information about other individuals, you represent and warrant to us that, where required by law and prior to your disclosure to us, you will obtain the consent of each individual to the collection, use and disclosure by us for the specific purpose(s) that the disclosure is made by you, including all purposes set out herein.

Providing us with your Personal Information is always your choice. When you request, access or utilize Services, we ask that you provide information that enables us to respond to your request and/or provide you with our Services. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such Personal Information for these purposes.

If we sell our organization or merge with another party, you hereby consent to the transfer of your Personal Information and all information you provide to us, to our successor for the same purposes as set out in this Privacy Policy.

• 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 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 such as the Canada Revenue Agency, Human Rights Commission, Canadian Radio-television and Telecommunications Commission, and law enforcement, may have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.

• What Personal Information do we collect and use?

Generally, you may browse our websites without providing any Personal Information. You are under no obligation to provide us with Personal Information, with the caveat that your refusal to do so may prevent you from using certain portions of the Services. 

As set out above, HCPs are responsible for the collection, use and disclosure of Personal Information as it relates to the provision of their services and for ensuring that adequate safeguards are in place to protect that information. 

The following overview provides general information about how Personal Information is collected and used through the Services. 

User Accounts 

In order to use the Services you may be required to create a user account (the "User Account") through the Services and be issued a username and password login credentials ("User ID"). We collect information such as your name, email address, phone number, gender, date of birth and province or territory to create your User Account. If you are issued a User ID, you will be required to keep your User ID secure. 

HCP Services 

We may collect Personal Information from you on behalf of a HCP when you request certain Services, such as Services relating to certain medical tests, to facilitate the provision of related services by the HCP. HCPs may further access Personal Information that you have entered or uploaded to your profile through the Services. 

HCPs must comply with professional regulatory requirements, including as it relates to confidentiality and privacy and record keeping, as well as privacy laws. HCPs may create information such as laboratory test result reports, prescriptions, and other information relating to your interaction with them or relating to the services such HCPs provide to or for you. 

• How do we use your Personal Information?

We use your Personal Information for the purposes for which it was collected, as well as other purposes for which you have given consent. In addition to those purposes set out above, this includes, but is not limited to, the following purposes:

• Administration of your User Account
• Marketing: In accordance with anti-spam laws, we obtain your consent in order to send you commercial electronic messages. We do not share email addresses or other contact information with third parties without your permission. 
• Notifications: We will ask you if you wish to receive notifications about services that you request. If you agree, we will send you email or text messages to we notify you about the status of your consultations and other requests, such as prescription orders.
• Payments: You may be given the option to pay for Services via an electronic payment service. Such electronic payment service is facilitated by a third party service provider on your behalf. Any payment information you provide will therefore be provided to such third party service provider, and you here by provide consent for our disclosure of your payment information for that purpose.
• Uses set out in the Consent section herein.
• Uses in accordance with our Terms of Use. 

We also may use your Personal Information to comply with our legal obligations, resolve disputes, and enforce our agreements and as required and/or permitted by applicable privacy laws. 

• Disclosing Personal Information to third parties

We will not disclose, share, sell or rent your Personal Information with or to any third party, except as set out herein, or with your written consent, or as required or permitted by privacy laws. 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.

In some instances we may retain other companies and individuals to perform functions on our behalf, including, but not limited to website developers, service and technology providers, and payment service providers. Third parties may be provided with access to your Personal Information to perform the functions for which they have been retained. Our agreements with 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.

HCPs may disclose Personal Information about you, including to your emergency contact, if they believe that you are dealing with a medical emergency during a consultation and disclosure is necessary in order to eliminate or reduce the risk of serious harm. 

• Security Safeguards

We use physical, organizational and technical industry-standard security safeguards commensurate to the sensitivity of Personal Information and other 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 in our custody or under our control.

Notwithstanding the foregoing, in using the Services there are inherent risks to any technology however remote that could cause security protocols to fail or to be breached and which could result in the unauthorized collection, use or disclosure of your Personal Information .

• Retention of Personal Information 

We will retain your Personal Information on the Services until such time as we terminate your User Account. On termination, you will have an opportunity to print or make copies of any Personal Information held in the Services, provided that we have the appropriate authorization from any applicable HCP, if any. 

• How can I access or correct my Personal Information?

You can add, edit, or delete optional information appearing in your User Account at any time in your account settings. You can edit, but not remove, certain information (like an email address). 

• Children

We are committed to protecting the privacy of children. The Services are not intended or designed for children. We do not collect Personal Information from any person we actually know is a child. 

• Privacy and Our Services
• Each time the Services are utilized by a user, our web server or other tools may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on the Services. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. We may use this non-personal information to optimize the Services, and our products.

We may collect anonymous information as you navigate and/or interact with the Services. We may use anonymous information to operate and improve the Services. We may also use anonymous information to track what visitors to the Services are looking at most frequently so we can recognize and deliver more of the desired features, products, and Services.

We may collect information pertaining to you from third party sources, including but not limited to, for the purpose of generating your account for our Services. It is your responsibility to review such information in your account to ensure its accuracy.

By accessing and browsing the Services, or our products and/or service(s), you agree that we, or any third party we engage or that assists us, may collect, use and disclose any information collected about you through the Services, or HCP services, or that you provide to us through the Services.

• Cookies & Web Beacons

We may, from time to time, use “cookies” solely for security and authentication purposes. 

Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide information to the owners of the website. They help us to understand how users access our website so we can develop and improve the design, layout, content and function of the Services.

Cookies are small text files that a website saves on your computer or mobile device when you visit the site. They save and retrieve pieces of information about your visit to the website - for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can often give you tailored options based on the information it has stored about you on your last visit. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.

On our Services, cookies can be set by us (first party cookies) or by our partners (third party cookies).

We set cookies for the purposes set out below:

• analytics;
• collecting page views;
• viewing history; and
• session cookies – for keeping users logged in while browsing (for a duration of up to one hour).

We cannot provide the names and purposes of the third party cookies as we do not have access to that information, however they are necessary for us to provide our Services. These third parties face serious consequences if they are in breach of applicable privacy laws.

If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer. You can also delete any cookies that are already stored on your computer's hard drive. However, please be aware that if you do delete and block all cookies parts of our Services will not then work. This is because some of the cookies we use are essential for parts of our Services to operate. Likewise, you may not be able to use some products and services on other websites without cookies.

To find out more about cookies, including to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

If you do not wish to accept cookies from our Services, please leave the Services immediately and then delete and block all cookies from the Services.

We may use web beacons alone or in conjunction with cookies to compile information about you and your usage of the Services, as well as your interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. For example, we may use web beacons to operate and improve the Services and email communications. We may use information from web beacons in combination with personal information about you to provide you with information about us and our Services, products and services.

• Analytics and Interest-Based Advertising

Our third party vendors or service providers may also use cookies and web beacons, such as for the purpose of measuring the effectiveness of our ads and to determine the content and advertising to be offered to you based on your interests. To support these activities, we, our service providers, and business partners may use information about your visits to our Services. You may opt out of other third-party vendor's use of cookies by disabling cookies on your browser. Please note that even if you choose to disable cookies you will still see advertisements while browsing online. However, the advertisements may be less relevant to you and your interests.

We may also use third-party service providers to monitor and analyze the use of our Services. Google Analytics is a web analytics service offered by Google Inc. (“Google”) that tracks, monitors and reports traffic on our Services. Google tracks information such as: (i) your IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the Services that you visit; and (iv) other websites you may have visited before visiting our Services. 

Google may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf. You can opt-out of having your activity on the Services made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about a visitor’s activity. For more information on Google’s privacy practices, please visit: https://policies.google.com/technologies/partner-sites.

• Anti-spam

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message.

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

• Third- Party Sites

The Services 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 us and the operator of that website may have different privacy policies. We are not responsible for the individual privacy practices of those sites. We encourage you to investigate the privacy policies of these third-party operators.

• Information Accuracy 

While we collect the Personal Information that you supply, we do so with the understanding that any such information is as accurate. It is important to us that your Personal Information held by us is accurate and complete. Having accurate information about you enables us to provide you with the Services in a manner whereby the function as intended. You can help us keep Personal Information up-to-date by ensuring your Profile is accurate, only providing us with accurate information, and 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 our lack of accurate contact information for you, including any inaccuracy, malfunction or other deficiency of the Services. 

• Retention and Destruction of Personal Information 
• The amount of time we will retain Personal Information varies, depending on the Services we have provided and the nature of the Personal Information that we hold. We retain Personal Information for such period of time as is necessary for us to maintain sufficient information so we may respond to any issues that arise at a later date or as is required by law. 

When Personal Information is no longer required by us or by law, we will either convert it into an aggregated non-identifying form or we will appropriately destroy or erase the Personal Information in a manner that is in accordance with our current policies and procedures.

• Transfers of Personal Information 

We are responsible for your Personal Information which we process and store in accordance with the terms of this Privacy Policy and applicable Canadian laws. If you are not resident in Canada and/or are located of Canada, you bear all responsibility for ensuring that your use of our Services and any Pharmacy Services or Support Services is compliant with all applicable laws.

• Access and Correction 
• We recognize that you may have the right to access your Personal Information. Any access request must be made in writing to info@rapidscreen.ca
• We may charge a reasonable fee for providing information in response to an access request, and, upon request, we will provide an estimate of any such fee upon receiving a request to access information. We may require a deposit for all or part of the fee.

Where applicable or permitted, we will make the information available within 30 days or provide written notice when we require additional time to respond to a request for access to information.

In some situations, we may not be able to provide access to certain Personal Information as the right to access Personal Information is not absolute. If we do not provide you with the requested information, we will notify you in writing and explain our reason(s) for not fulfilling your request.

• Withdrawal of Consent: 
• You may, at any time, withdraw your consent to our collection, use and disclosure of your Personal Information, subject to reasonable notice and any legal and/or contractual restrictions.

Should you choose to withdraw your consent, we may be unable to provide, or continue to provide, the Services that can only be provided if we receive appropriate and required Personal Information.

• Sensitive Data 

We request that you do not send us any sensitive data, including but not limited to social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, heath information, biometrics or genetic data, criminal background or trade union membership information, unless we explicitly request such information. In accordance with applicable privacy laws, the sensitivity of data may be determined based upon context, or by other measures. If you do send us sensitive data then you are consenting to its processing in accordance with this Policy. 

• INDIVIDUALS LOCATED IN THE EUROPEAN ECONOMIC AREA (EEA)

Your personal information (which as referred to herein shall have the same meaning as “personal data” under the General Data Protection Regulation (“GDPR”) will be processed in accordance with this Privacy Policy and in compliance with Canadian federal and provincial and any other applicable privacy law. Canadian federal privacy law is considered an “adequate” jurisdiction for personal data transfers outside of the EEA. We will respect your rights to data access, correction, transfer, and deletion.

• Governing Law

All matters relating to your access or use of the Services shall be governed by the laws of the Province of Ontario and the laws of Canada applicable therein, without regard to principles of conflicts of law. You agree and hereby submit to the exclusive jurisdiction of the courts of the Province of Ontario with respect to all matters relating to your access and use of the Services, as well as any dispute that may arise therefrom.

• Contacting us

Should you have any questions or concerns about this Privacy Policy or our practices, you may contact us at info@rapidscreen.ca

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. 

• Changes to this Privacy Policy 
• This Privacy Policy is effective as of the date indicated herein. We reserve the right to change this Privacy Policy, and any of our policies and procedures concerning our practices for handling Personal Information, at any time and without any prior notice. Any changes that are made to this Privacy Policy will apply to both any Personal Information that we hold prior to the effective date of the amended Privacy Policy and any Personal Information that we collect on or after such effective date.

You should review this Privacy Policy and all policies regularly to make sure that you are aware of any changes. Your access to use of the Services, our products and services, and Pharmacy Services and Support Services on and after the date on which we post the revised terms constitutes your acceptance of the Privacy Policy as revised as well as of any revised policies.

• Successors and Assigns 
• Our successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this Privacy Policy.

© RapidScreen Services Inc., 2022.

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