Healthspan Labs Inc. (“MyHealthspan”, “we”, “us”, “our”), doing business as MyHealthspan is committed to collecting, using, and disclosing personal information responsibly. Personal information is any information about a specific, identifiable individual, including name, address, telephone number, and personal history. Personal information includes personal health information, which means diagnostic, treatment and care information relating to a specific individual and any other information about an individual that would fall within the definition of personal health information as found in provincial health sector privacy legislation.We value privacy and are committed to protecting the privacy, confidentiality and security of our customers’ personal information, including personal health information in our custody or under our control.By accessing MyHealthspan’s Website (the “Website) or using any of MyHealthspan’s Services (each a “Service” and collectively the “Services”), you agree to be bound by the terms of this Privacy Policy. We last updated this policy on January 22, 2024.  Your use of our Website and Services is also subject to our Terms and Conditions Agreement.

Collection, Use and Disclosure of Personal Information

MyHealthspan and our third-party partners may collect, use or disclose personal information for the purposes of providing the Services, auditing, training, and quality improvement, and as otherwise required or permitted by federal and provincial law. We may collect personal information from you directly, or from other third parties if you provide us with consent to do so or if we are authorized to do so by law. MyHealthspan and our third-party partners will only collect the personal information we need to provide you with Services. For example, we may collect your name, gender, date of birth, address, email address, phone number, payment card information, the results of applicable health testing Services (the “MyHealthspan Metrics Services”), and other relevant information as required.

In the course of providing the Services, your personal information may be shared with health information custodians involved in your care (e.g., your medical doctor or health care practitioner, a MyHealthspan partner who has referred you to MyHealthspan through an affiliate link, or member of your clinical care team) unless instructed otherwise by you. For example, if you provide express consent then MyHealthspan can share your MyHealthspan Metrics Services results with your primary care provider or referring MyHealthspan partner; this may include providing your primary care provider or referring MyHealthspan partner with direct access to your electronic MyHealthspan results Dashboard with your permission.

MyHealthspan and our third-party partners may share your personal information for the purposes of contacting your emergency contact or emergency services if we feel it is necessary for your safety. As part of routine practice, MyHealthspan personnel may occasionally consult with professional colleagues regarding practices, and that when this is done, it is for the purpose of benefiting customers and personal information is kept confidential.

Consent

Unless the purposes for collecting personal information are obvious and you voluntarily provide your personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. The way we collect your consent may vary depending on the purpose for the consent.

If you do not wish for your personal information to be used or shared, you have the right to refuse to provide all or part of the information to us at the time we request the information or anytime afterwards. We may not be able to fulfill your wishes if they impact our ability to deliver Services to you or if we are legislated to use or disclose the information to which you object. In these cases we will discuss the impact of your objection with you. If we find it necessary to disclose your information for purposes other than providing the Services, we will notify you of the purpose for the disclosure and ask you for consent to disclose the information.

Personnel Access

MyHealthspan only permits MyHealthspan personnel (“Personnel” which includes our employees, contractors and subcontractors) to access personal information to the extent necessary to perform their designated functions. We require Personnel to commit to protecting personal information by complying with our policies, procedures, and applicable privacy laws.

More generally, we have in place appropriate physical, technological, and organizational safeguards including access controls to protect personal information against loss, theft, and unauthorized access, use and disclosure. Notwithstanding the safeguards we employ and our commitment to protecting personal information, we cannot guarantee the security or error-free transmission or storage of personal information. There are risks inherent in the use of electronic means to transmit and hold information in electronic format. These risks can be minimized, but not eliminated by the use of appropriate security measures, such as the measures MyHealthspan employs. These risks include interception, loss, corruption, unauthorized access to, use and disclosure of personal information, and delay in the availability of personal information.

You play an important role in protecting your privacy and your personal information and for that purpose, we ask you to password-protect your device(s), email account, and MyHealthspan account(s) with strong and unique passwords. Do not share these passwords with anyone.

Payment

We may collect, use and disclose your personal information for the purposes of facilitating and/or collecting payment for our services or to determine any entitlement to insurance coverage or other benefits.

Research

MyHealthspan may conduct or participate in research and analysis in which case your personal information, including personal health information, may be analyzed in de-identified form. The results of this research and analysis will not be disclosed or otherwise published in a manner that could identify an individual. Any additional testing for research or analysis purposes that involves the collection, use or disclosure of information that could identify an individual will involve a separate informed consent process.

Internal Operations

We may collect, use and disclose personal information for the purposes of risk management, training, security or otherwise to improve the quality of MyHealthspan services, including the evaluation and monitoring of those services, such as for auditing and quality assurance purposes.

Legal & Compliance

We may disclose your personal information where required or permitted by law including to respond to a subpoena, order, or similar obligation to produce information, establish or exercise MyHealthspan’s legal rights including defend against legal claims, detect, investigate, suppress, prevent or take action regarding illegal or prohibited activities, including without limitation suspected fraud and threats to the reputation or safety of any person. We may transfer any information we have about you in connection with a proposed or completed merger or sale involving all or part of MyHealthspan or as part of a corporate reorganization or other change in corporate control.

Electronic Communication

MyHealthspan Services involve electronic communication, including via the Website with a personal account feature, telephone, email, and video. The laws that protect your privacy and the confidentiality of your personal information also apply to electronic communication.

Electronic Communication

While MyHealthspan and its associated professionals will attempt to review and respond in a timely fashion to your electronic communication, we cannot guarantee that all electronic communications will be reviewed and responded to within any specific period of time. MyHealthspan Services will not be used for medical emergencies or other time-sensitive matters.

If your electronic communication requires or invites a response from MyHealthspan or its associated professionals or third-party partners and you have not received a response within a reasonable time period, it is your responsibility to follow up to determine whether the intended recipient received the electronic communication and when the recipient will respond.  You are responsible for following up on the electronic communication received from MyHealthspan and its associated professionals or third-party partners and for scheduling appointments where warranted.

MyHealthspan and its associated professionals will not forward electronic communications to third parties, including family members, without your prior written consent, except as authorised or required by law. MyHealthspan and its associated professionals are not responsible for information loss due to technical failures associated with your software or internet service provider. You agree to inform MyHealthspan of any types of information you do not want sent via the MyHealthspan Services by notifying MyHealthspan in writing.

Risks of Using Electronic Communication

We are careful to take reasonable means to safeguard your data when using electronic communication and through our Website; however, just like social media and online shopping, use of electronic communication and online websites have some inherent privacy and security risks that your personal information may be intercepted or unintentionally disclosed, which cannot be completely protected against.

MyHealthspan and its associated professionals and third-party partners cannot guarantee the security and confidentiality of electronic communications because of the risks outlined below:

• Use of electronic communications to discuss sensitive information can increase the risk of such information being disclosed to third parties.
• Despite reasonable efforts to protect the privacy and security of electronic communication, it is not possible to completely secure the information.
• Employers and online services may have a legal right to inspect and keep electronic communications that pass through their system.
• Electronic communications can introduce malware into a computer system, and potentially damage or disrupt the computer, networks, and security settings.
• Electronic communications can be forwarded, intercepted, circulated, stored, or even changed without your knowledge or permission.
• Even after the sender and recipient have deleted copies of electronic communications, back-up copies may exist on a computer system.
• Electronic communications may be disclosed in accordance with a duty to report or a court order.  Video-conferencing may be open to interception
• Electronic communication, such as email, can be misdirected, resulting in increased risk of being received by unintended and unknown recipients.
• Electronic communication can be easier to falsify than handwritten or signed hard copies. It is not feasible to verify the true identity of the sender, or to ensure that only the recipient can read the message once it has been sent.

Instructions for Communication Using the Services

To communicate using MyHealthspan’s Services, you must:

• Reasonably limit or avoid using an employer’s or other third party’s computer.
• Inform MyHealthspan of any changes in your email address, mobile phone number, or other account information necessary to communicate.
• Take precautions to preserve the confidentiality of electronic communications, such as using screen savers and safeguarding computer passwords.
• Withdraw consent only by email or written communication to MyHealthspan.

Storage of Personal Information

Our third-party partners may collect and store personal information as a result of providing services in partnership with MyHealthspan. We use third-party partners for the following testing:

• Blood testing
• VO2 max testing
• Genetic testing for cancer and cardiac conditions risk screens
• Genetic testing for ApoE phenotype
• Genetic testing for DNA methylation

MyHealthspan is the custodian of all customer records that are collected through the Website and provided to MyHealthspan from our partners. MyHealthspan stores your personal information in electronic format using computer systems with restricted access. MyHealthspan also uses third-party software and service providers for a variety of services including, but not limited to technical, operational and other business services. Some of our service providers operate from outside of Canada, which means that personal information they use on or behalf for their services may be subject to the law of the country or state in which they operate. MyHealthspan contractually requires these providers to abide by rules set forth by their applicable privacy laws. For specific privacy policies of MyHealthspan’s partner companies, please visit their websites or contact MyHealthspan directly.

When we transfer personal information, we take reasonable steps to ensure that your personal information is protected from loss, theft or unauthorized access, use, modification and disclosure. Our Website may also contain links to third party sites that are not owned or controlled by MyHealthspan.  Please be aware that we are not responsible for the privacy practices of such other sites.  We encourage you to be aware when you leave our Website and to read the privacy statements of each and every Website that collects personal information.

Unless we notify you otherwise, we will retain your personal information in our custody for a period of ten (10) years from the last date of service.  After this time, your information will be deleted. When personal information is deleted, it is permanently removed from our active databases and destroyed.

No Information from Children Under Age 18

This Website and MyHealthspan services are intended for use by individuals 18 years of age and older. If you are under the age of 18, please do not attempt to register with us at this Website or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information.

Access, Correction, and Complaints

You may make a formal written request to see and/or obtain a copy of your personal information with MyHealthspan. In extremely limited circumstances, we may deny or restrict your access to your personal information (e.g., if a provincial or federal act prohibits disclosure).

If you believe your MyHealthspan record to be inaccurate or incomplete, you may make a request in writing that the record be corrected. We will make the correction if you demonstrate that the information is inaccurate or incomplete for the purposes for which the information is being used. We may not correct the record if it was not originally created at MyHealthspan and we do not have sufficient knowledge, expertise or authority to correct it; or if the record consists of a professional opinion or observation made in good faith about you. We will, however, note the request for correction and the fact that we did not make any changes based on one of these reasons in the record.

Changes to this Privacy Policy

We reserve the right to amend the Policy at any time to account for changes to our practices and to comply with federal and provincial privacy legislation as they may each apply. Please check to see if we have amended the Policy since you last used the MyHealthspan Website to ensure you are aware of (and agree to) our current privacy practices. You may request a copy of the Privacy Policy currently in effect at any time by contacting us.

Questions or Comments

For any questions, concerns, suggestions, or comments, please contact us at connect@MyHealthspan.com. Please include your name and contact information if you would like us to respond to you.

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