Privacy Policy

Version: 1.0 –  Date: December 1, 2023

INTRODUCTION

Scrubs Health Inc. d/b/a Rosie Health (“we”, “us” or “our”) respects your privacy and we commit to protecting it through our compliance with this privacy policy (“Privacy Policy”). We have created this Privacy Policy to inform you of our policies regarding the collection, use and disclosure of personal information and the choices you have associated with that information.

This Privacy Policy applies to all personal information collected during any written, electronic or oral communication or collected online or offline (collectively, the “Services”), which include:

• The website located at rosiehealth.ca, and all corresponding webpages and websites that link to this Privacy Policy, including scrubshealth.com (“Site”);

• Any mobile, web, desktop or other application you download from this Site, the Apple Store, or Google Play (the “App”, and collectively with the “Site”, the “Portals”) which provide dedicated non-browser-based interaction between you and us.

• When you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy.

• Via our health care consultants or labs.

Before using our Services, please carefully read this Privacy Policy and our Terms of Use, which you may view at https://www.rosiehealth.ca/terms-use/. By using the Portals, you consent to the collection and use of the Personal Information in accordance with this Privacy Policy and our Terms of Use. If you do not feel comfortable with any part of this Policy or our Terms of Use, you should not use or access our Services.

We may modify this Privacy Policy at any time, without prior notice, and changes may apply to any personal information we hold about you, as well as any new personal information collected after the Privacy Policy is modified. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. We will provide you with advanced notice by email, and when you visit the website, if we make any material changes to how we collect, use or disclose your personal information or that impact your rights under this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you. If you continue to access or use our Services after receiving the notice of changes, you acknowledge your acceptance of the updated Privacy Policy.

We also may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your personal information.

The Portals are offered and available to users who are 18 years of age or older. We do not collect or maintain personal information from people we know are under 18 years old unless consent is provided on their behalf by a legal guardian. If we obtain knowledge that a user is under 18 years old, we will use our best efforts to remove that person’s information from our database. If you are not 18 years of age or older, you must not access or use our Services.

1. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT

We collect personal information when you use our Services. Personal information is any information that means any information that may be used to identify you personally or could be used to identify you including but not limited to: your name, home address, email address, telephone number, or any other information defined as protected health information under the Health Information Act.

The types of personal information that we may collect about you include but are not limited to the information you provide to us, information collected automatically about your use of our services, information from third parties, including our business partners.

Information You Voluntarily Provide to Us

The personal information we collect on or through our Services may include:

• Information that you provide by filling in forms on our Portals. This includes information provided at the time of registering, subscribing to or purchasing our services, posting material or requesting further services. We may also ask you for information when you report a problem with our Portals.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Uploaded lab requisitions or other forms containing health information.

• Details of transactions you carry out through our Portals and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Portals.

• The name and email address of individuals to whom you wish to refer our Services.

• Your search queries on the Portals.

You also may provide reviews to be published or displayed (hereinafter, “posted”) on public areas of the Portals or transmitted to other users of the Portals or third parties (collectively, “User Content”). Your User Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Services with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.

Information From Third Parties

When you interact with any of our pages or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service. When you access the Services through social media services or when you connect the Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

Information Collected Automatically

As you navigate through and interact with our Portals, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Portals, including, but not limited to, traffic data, location data, logs and other communication data and the resources that you access and use on the Portals.

• Information about your computer, phone or other hardware device and internet connection, including your IP address, operating system and browser type.

• Information about your preferences to make your use of the Portals more productive, via the use of cookies. For more information on cookies, please see Section 2.

2. COOKIES AND OTHER TRACKING TECHNOLOGY

We may use cookies, embedded scripts, and other similar tracking technologies (“Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services (“behavioral tracking”).

Cookies

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Services, to enhance your experience with the Services, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Services. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).

We do not control the types of information collected and stored by third-party cookies. You should check any third-party’s website for more information on how they use cookies. The following types of cookies are used on our Services:

• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some Services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.

• Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.

• Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies.

• Advertising or Targeting Cookies. Cookies used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

Analytics

We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

Other Tracking Technologies

We may also use Tracking Technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Services, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Services for the same purposes.

Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Your Choices

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Sites by taking the steps outlined below.

• First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.

• Flash Cookies. Certain features of our Site may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. If you do not want flash cookies stored on your computer, you can adjust the settings of your flash player to block flash cookies storage. Flash cookies are not managed by the same browser settings as are used for browser cookies, but may be managed here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

• Google Chrome

• Internet Explorer

• Mozilla Firefox

• Safari (Desktop)

• Safari (Mobile)

• Android Browser

• Opera (Desktop)

• Opera (Mobile)

Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

3. HOW WE USE YOUR INFORMATION

We will use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:

• Providing any services or products that you request or purchase in connection with the Services.

• Contacting you regarding the administration of any features or functions of the Services you have registered to use.

• Providing you with notices about your account, including expiration and renewal notices.

• Carrying out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• Notifying you about changes to our Portals, our policies, terms or any products or services we offer or provide though it.

• Sending you marketing and promotional emails.

• Responding to your questions or other requests.

• Allowing you to participate in the interactive features of the Services.

• Tailoring your experience on the Services and/or otherwise customizing what you see when you visit and use the Services.

• Saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services).

• Tracking your return visits to and use of the Services.

• Accumulating and reporting aggregate, statistical information in connection with the Services and user activity.

• Determining which features and services users like best to help us operate the Services, enhance and improve our services and the Services and display advertising and marketing information.

• Tailoring your experience on the Services and/or otherwise customizing what you see when you visit and use the Services.

• Keeping you secure and safe while using our Services, which requires us to process your Personal Information to combat spam, malware, malicious activities or security risks.

• Improving and enforcing our security measures.

• Maintaining legal and regulatory compliance.

• Enforcing compliance with our terms and conditions and policies.

• Protecting you, others and our business, including, without limitation, using information for fraud prevention.

• For any other purpose disclosed to you prior to you providing us your Personal Information or which are reasonably necessary to provide the Services or other related products and/or services requested.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please email us at  info@rosiehealth.ca to opt out.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We may share or disclose your personal information in the following circumstances:

• Service Providers. We may employ other companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform Service-related services or assist us in analyzing how our Services are used. The Service Providers have access to your personal information only to perform these tasks and are obligated not to disclose or use it for any other purpose. The Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• Within Our Corporate Organization. We may share your personal information with our subsidiaries and affiliates in order to provide you with the Services and take actions based on your request.

• Corporate Transactions. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Site users is among the assets transferred, and you agree to and do hereby consent to our assignment or transfer of rights to your personal information.

• Third Party Advertisers. In certain circumstances we may share your personal information with third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• We may disclose your personal information for any purpose with your consent.

• As Required by Law. Under certain circumstances your personal information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. We may be required to disclose personal information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or for public health purposes, including reporting HIV and other sexually transmitted disease results to state public health regulatory bodies. We will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that we may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce our Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect our rights, property, or personal safety or that of any of our employees, users or clients, or the public.

Please note that we may disclose, without restriction, aggregated or anonymized information about our users, which is information that does not identify any specific individual.

5. MARKETING COMMUNICATIONS

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

If you do not wish to have your email address or other contact information used by us to promote our own or third parties’ products or services, you can opt-out by logging into the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending an email stating your request to  info@rosiehealth.ca. You may also choose to stop receiving our promotional or marketing communications by following the “unsubscribe” instructions included in these messages. This opt out does not apply to information provided by us as a result of a product purchase, warranty registration, product service experience or other transactions.

Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

6. KEEPING YOUR PERSONAL INFORMATION ACCURATE AND DELETION

We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You can review and change your personal information by logging into the Portals and visiting your account profile page. You may also send us an email at info@rosiehealth.ca to request access to, or to correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you no longer wish to participate in our Services, or no longer wish to have your personal information processed, you may request to delete your account and the information in your account, subject to certain limitations, by emailing us at info@rosiehealth.ca. Once you submit your request, we will send an email to the email address linked to your account requesting that you confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated personal information is deleted.

If you delete your User Content from the Portals, copies of your User Content may remain viewable in cached and archived pages or might have been copied or stored by other Portal users. Proper access and use of information provided on the Portals, including User Content, is governed by our Terms of Use.

7. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third-party payment processors, who will use appropriate security procedures.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Portals, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Portal like message boards. The information you share in public areas may be viewed by any user of the Portals.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Portals. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Portals.

8. INTEGRATION OF THIRD-PARTY PLATFORMS AND SERVICES

The Services may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including Third-Party Services. The Services may also feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Services or for the privacy practices of third-party advertising companies. Once you leave this Services via a link, access a third-party service or click on an advertisement, you should check applicable privacy policies to determine, among other things, how related companies process Personal Information they may collect about you. This Privacy Policy applies solely to information collected by us.

9. CONTACT INFORMATION

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: info@rosiehealth.ca.