Privacy Policy

WELLSTAR Technologies Corp. (“WELLSTAR” or “we“) is committed to protecting your personal information. This Privacy Policy tells you how we do so.

This Privacy Policy applies to the YourCare mobile application (the “App“) and the services made available through the App.

We will update this Privacy Policy as necessary. Please check it regularly.

App Store Privacy Policy Availability

This Privacy Policy is intended to be made available: (a) on the YourCare website at https://yourcare.health/privacy-policy, (b) within the App in an easily accessible manner, and (c) via the privacy policy link provided in the applicable app store listing/console fields.

What information do we collect?

To use the App, we collect the personal information as set out below.

App Access

Unless you opt out where applicable, our App uses automatic data collection technologies and (where required) obtains your consent to collect certain device and usage information whenever you visit or interact with the App, including unique identifiers and preference information such as IP address, technical usage, time zone settings, language preferences, operating system, unique device identifiers, SDK identifiers, app performance and diagnostic data (such as crash logs), app version, device model, session duration, screens viewed within the App, and interactions within the App.

These technologies help us understand how you use the App and its content in order to make improvements.

You can opt-out through your device settings and/or in-App settings (where available). However, opting-out may disable some of the App’s features and may prevent us from providing you with the services you have requested.

Account and Profile

When you create or use an account in the App, we collect information such as your name, email address, phone number, authentication information, and other account details you provide. We may collect and display information to support appointment coordination, such as your primary care provider/most responsible provider (MRP) and pharmacy information. Where enabled, pharmacy information you submit may be transmitted to and recorded in your clinic’s EMR.

Appointments, Intake Forms, and Check-In

When you use the App to discover clinics, request or manage appointments, complete intake or consent forms, or check in (including queue-related features), we collect the information you submit for those purposes.

Why do we use personal information?

We use personal information to:

• manage our relationship with you and provide you with the information or services you request,
• conduct research and evaluate research and development, including analyzing testing data to improve our services,
• communicate with you regarding inquiries for information or customer service requests,
• detect, prevent or investigate security breaches,
• protect our business, and
• maintain appropriate records for internal administrative purposes.

WELLSTAR reserves the right to aggregate and anonymize personal information (or other information) stored on its system and use such aggregated information as it sees fit.

We use identifiable personal health information only as necessary to provide the services you request through the App and as otherwise described in this Privacy Policy. Where feasible, we use aggregated or anonymized information for analytics and service improvement.

We do not disclose identifiable personal health information for product improvement purposes except to service providers acting on our behalf under confidentiality and security obligations.

Who do we share the personal information with?

We share your personal information with service providers and subcontractors in order to operate the App and provide you with the services you request, and with clinics/providers you choose to connect with through the App. This includes sharing your personal information for:

• fraud prevention,
• payment processing (if applicable),
• providing requested services or information,
• operating the App, 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.

Where you use the App to interact with a clinic or healthcare provider (for example, for bookings, intake, messaging, or records access where enabled), we share information with that clinic or provider as needed to provide the services you request, including sharing profile details (and transmitting information to their EMR where enabled) to support appointment coordination and related services.

Clinics/providers are responsible for the healthcare services you receive and their own privacy practices, including any clinical records they create or maintain in the course of providing care. WELLSTAR is responsible for operating the App and will collect, use, and disclose information (including personal health information, where applicable) to provide the App features and services described in this Privacy Policy and to comply with applicable law. Your appointments may be managed using tools used by your clinic and YourCare may ingest and display appointment information to support appointment coordination.

If you have questions about a Provider’s records, corrections to clinical records, or the Provider’s privacy practices, you may need to contact the Provider directly. For questions about the App or WELLSTAR’s handling of information for App operations, contact WELLSTAR at privacy@well.company.

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.

Consent, prominent disclosures, and your choices

A. Consent (general)

We collect, use, store and disclose personal information (including personal health information, where applicable) to provide the services you request through the App and to operate the App, as described in this Privacy Policy. Where required by applicable law, we will obtain your consent before collecting, using or disclosing your personal information.

B. Prominent in-app disclosures and affirmative consent

Where required (for example, when accessing sensitive data or using sensitive device permissions), we will provide a prominent, in-app disclosure describing what data is accessed, collected, used and/or shared and for what purpose. Such disclosure will not be provided only in a privacy policy or terms of service. Where consent is required, we will obtain affirmative user action (for example, tap to accept or tick a check-box) before proceeding.

C. Device permissions and controls

The App may request access to certain device permissions (for example, notifications, camera, photos, microphone, location or other permissions) to enable specific features. You can enable or disable permissions at any time in your device settings. If you disable a permission, related features may not function.

D. Withdrawing consent

You may withdraw your consent where applicable, subject to legal or contractual restrictions and reasonable notice. You can withdraw consent by: (i) adjusting your device permissions/settings, and/or (ii) contacting our Privacy Officer at privacy@well.company. Where consent is collected through an in-app form, you may also withdraw consent by following the instructions provided in the App or by contacting our Privacy Officer. Withdrawing consent may limit our ability to provide some or all App features or services you request.

E. Requests to access or delete information

You may request access to, correction of, or deletion of your personal information as described in “Your rights” below. You may submit requests by contacting privacy@well.company. We may retain certain information as required or permitted by law.

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 applicable legal and regulatory requirements.

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.

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. Access to personal health information is restricted to authorized personnel and service providers on a need-to-know basis, consistent with their roles.

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.

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 accessed by parties 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.

Links to third-party sites

Our App may lead you to third-party websites or services. Those organizations are separate and distinct and have their own separate privacy policies. We are not responsible in any way for how any third-party collects, uses, protects 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.

Direct marketing

If you sign up to receive marketing or promotional communications from WELLSTAR, we will collect your name and email to inform you about WELLSTAR and our products and services.

If you no longer wish to receive marketing or promotional communications from us, 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.

Your rights

You also have the right to:

• rescind or withdraw your consent to the use or disclosure of personal information,
• request to access your personal information, including your personal health 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. If you request access to your personal health information, we may refer your request to the relevant healthcare provider to comply with your request. We will respond within 30 days. If we cannot grant your request, we will give reasons.

We will address all requests with equal attention.

You may request deletion of your YourCare account by contacting privacy@well.company, or by using the in-app account deletion feature (go to Account → Settings → Delete account, then confirm account deletion). Upon account deletion, WELLSTAR will take steps to delete (or where applicable, de-identify) information associated with your account to the extent required by applicable law and subject to our retention obligations. If you delete your account in-app, your account enters a 60 business day reactivation period, during which you may request reactivation by contacting support@yourcare.health. After that period, YourCare profile and appointment data are permanently deleted, and active sessions are revoked. Account deletion does not affect medical records, appointment records, or other health information retained by clinics/providers in accordance with their own policies and legal requirements.

Contacting us

Accountability with respect to your personal information is important to WELLSTAR. In the event that you have any questions (including how personal information is managed by WELLSTAR), 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 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.