Privacy Policy

INTRODUCTION

Preluma and our affiliates and subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

How we collect, use, disclose, and protect the personal information of our customers and Site users (“you”).
Describes the types of information we may collect from you or that you may provide when you visit the Site preluma.health, our mobile application, and related infrastructure (the “Site”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This policy applies to information we collect, use, or disclose about you:

On this Site.
In email, text, and other electronic messages between you and this Site.
Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site.
When you interact with our advertising and applications on third-party Sites and services if those applications or advertising include links to this policy.

The Site may include links to third-party Sites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party Site or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party Sites, and we encourage you to read the privacy policy of every Site you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you indicate that you understand, accept, and consent to the practices described in this policy.

TERMS OF USE

This privacy policy as well as our Terms of Use found here: preluma.health (“Terms”) govern your access of the Site. Terms capitalized but not defined in this Privacy Policy have the meanings set out in the Terms of Use.

CHANGES TO THIS PRIVACY POLICY

This policy may change from time to time. Your continued use of this Site after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Site’s home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

CONTACT INFORMATION

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Dr. Lior Krimus, Privacy Officer

info@preluma.health

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and any other identifier we may use to contact you (“personal information”).

We provide an opportunity for any user to unsubscribe from our services or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails.

Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Site feature.
Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Site, and usage details.
Non-personal details about your Site interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

Information You Provide to Us

The information we collect directly from you on or through our Site may include:

Information that you provide by filling in forms on our Site. This includes information relating to your interactions with our Healthcare Providers (as defined below), and information provided at the time of registering to use our Site, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Site.
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.
Details of transactions you carry out through our Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Site.
Your search queries on the Site.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

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

Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Site according to your individual interests.
Speed up your searches.
Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
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. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.
Web Beacons. Pages of our Site and our e-mails 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 Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Site, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Sites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these Sites to learn more about online behavioural advertising and how to stop Sites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Use and Disclose Your Information” below.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To provide services to our Healthcare Providers.
To present our Site and its contents to you.
To enforce our Terms.
To provide you with information, products, or services that you request from us.
To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
To notify you about changes to our Site or any products or services we offer or provide though it.
To improve our Site, products or services, marketing, or customer relationships and experiences.
To allow you to participate in interactive features, social media, or similar features on our Site.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

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, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at info@preluma.health.

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our Healthcare Providers.
To our subsidiaries and affiliates.
In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other 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 customers and users is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures.
To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
To enforce or apply our Terms, Consent Form, and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, including of our customers, or others.
To provide emergency assistance in situations that may threaten the life, health, or physical safety of you or others, including by sharing relevant information with emergency responders, family members, or emergency contacts.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

PERSONAL HEALTH INFORMATION

In some circumstances, certain information that we collect, use, or disclose may constitute “personal health information” as defined under the Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”) and its regulations.

We do not provide medical diagnosis or treatment and we are not a health information custodian within the meaning of PHIPA. Any regulated healthcare services, where applicable, are delivered by independent healthcare providers and organizations (“Healthcare Providers”), who are responsible for their own professional judgment, record‑keeping, and legal compliance.

Where we handle personal health information in connection with services delivered by an independent Healthcare Provider who is a Health Information Custodian (“HIC”) under PHIPA, we do so solely for the limited purpose of supporting or facilitating those services, and only in accordance with the instructions and authorization of the applicable HIC. In these circumstances, we may act as a service provider or agent to the HIC within the meaning of PHIPA. We do not access, use, or disclose personal health information for our own purposes or for the purpose of providing medical treatment or clinical advice.

We have implemented reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information we handle, designed to protect the confidentiality, security, and integrity of personal health information and other personal information, and to prevent unauthorized access, use, or disclosure.

Where required or appropriate, we enter into written agreements with Healthcare Providers that address the scope of services we provide, information‑handling responsibilities, and applicable privacy and security obligations under PHIPA and other applicable laws.

In the event of a breach involving personal health information that we handle on behalf of a Healthcare Provider who is a HIC under PHIPA, we will notify the applicable Healthcare Provider promptly upon becoming aware of the breach, and will support that Healthcare Provider in fulfilling their notification obligations under PHIPA and its regulations.

Personal health information that we handle on behalf of a HIC is collected, used, disclosed, and retained only as necessary to perform the applicable services, and subject to the directions of the HIC and applicable legal requirements.

For more information regarding the collection, use, or disclosure of personal health information in connection with regulated healthcare services, individuals should review the applicable Healthcare Provider’s privacy policy and consent materials, which govern that provider’s obligations under PHIPA.

For more information about how we collect, use, and disclose your personal health information, see our Personal Health Information Consent Form.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Site, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

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:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Site. If you disable or refuse cookies, please note that some parts of this Site may not be accessible or may not function properly. For more information about tracking technologies, see “Information We Collect Through Cookies and Other Automatic Data Collection Technologies” above.
Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to the email address provided above.
Promotional Offers. If you have opted in to receive certain emails from us but no longer wish to have your email address used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to the email address provided above. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
SMS and Text Messages. By providing your telephone number, you consent to receive text messages from us, including appointment reminders, scheduling communications, and related administrative messages. Message and data rates may apply. You can opt out of text messages at any time by replying “STOP” to any text message we send, or by contacting us using the contact information provided above.

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. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these Sites to learn more about online behavioural advertising and how to stop Sites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted.

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 Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards, which any Site visitor can view.

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 Site. 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 Site.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

MINORS

Our Site and Services are intended for and directed to residents of Canada over the age of 16 years, consistent with our Terms and Conditions of Use. We do not knowingly collect personal information from individuals under the age of 16. If you are under the age of 16, please do not use or provide any information on or through the Site, including your name, address, telephone number, email address, or any other identifying information, without the involvement and consent of a parent or legal guardian.

If we learn that we have collected personal information from an individual under the age of 16 without the appropriate consent of a parent or legal guardian, we will take reasonable steps to delete that information. If you believe we might have collected personal information from someone under the age of 16 without appropriate consent, please contact us using the contact details provided above.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at info@preluma.health to request access to, correct, or delete 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. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

Information protected by solicitor-client privilege.
Information that is part of a formal dispute resolution process.
Information that is about another individual that would reveal their personal information or confidential commercial information.
Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer, Dr. Lior Krimus, at info@preluma.health.

COMPLAINTS

If you have a concern about our collection, use, or disclosure of your personal information, or about our compliance with this policy, please contact our Privacy Officer using the contact information provided above. If you are not satisfied with our response, you have the right to contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) and, with respect to personal health information handled in Ontario, the Information and Privacy Commissioner of Ontario (www.ipc.on.ca).

Privacy Policy.