Last revised: November 9th, 2024

Optimal Health Holdings Inc. is dedicated to safeguarding the confidentiality of your personal data and health-related information. We ask that all of our patients review this Privacy Policy thoroughly. This document outlines our systems for gathering, utilizing, managing, and sharing your personal information.

This Privacy Policy is applicable to any personal health information or other personal data we collect from you when you: (1) utilize the online patient portal (referred to as the "Portal"), (2) receive care at an Optimal Health Holdings Inc. facility or through our remote health services, (3) browse our websites where this Privacy Policy is displayed (the "Websites"), or (4) engage with us in any other manner.

TABLE OF CONTENTS

1. Acquisition and Utilization of Personal Information

2. Disclosure of Personal Information

3. Data Storage and Geographic Location

4. Information Regarding Our Websites

5. Protection Measures and Data Retention

6. Your Options

7. Information Access

8. Privacy Policy Updates

9. How to Reach Us

1. ACQUISITION AND UTILIZATION OF PERSONAL INFORMATION

We may gather and use your personal information, including health-related data, when you:

• Seek health care or wellness services at an Optimal Health Holdings Inc. facility or via our remote health services

• Establish an account to access and use the Portal

• Schedule an appointment

• Acquire a membership or service from Optimal Health Holdings Inc.

• Interact with us through our live messaging feature

• Opt to receive promotional emails about Optimal Health Holdings Inc. resources, services, offerings, and events

• Take part in an Optimal Health Holdings Inc. survey

• Agree to participate in research

• Submit a job application to Optimal Health Holdings Inc.

• Visit one of our clinics

• Get in touch with us

Health Care Services: 

We collect your personal health information to enable Optimal Health Holdings Inc. healthcare providers to deliver medical services when you visit our clinics, use our remote care services, access our Portal, or interact with us in other ways. We may also gather relevant health information about you from your other healthcare providers to facilitate our ability to provide you with our medical services. Your personal health information is stored in your medical record, which is accessible to healthcare providers, employees, and healthcare-related contractors in our clinics and through remote care technologies. 

While the nature of the personal health information you provide will be specific to your situation and healthcare needs, we generally may collect details such as your name, gender, birth date, health issues, personal and family medical history (e.g. information about diagnoses and treatments received by a family member), physician and medical referral appointment information, healthcare documents (including consultation reports, medical notes, and imaging results), health card number, and other pertinent health information. This data is collected for the purposes of providing healthcare services to you.

Remote Health Services: 

Optimal Health Holdings Inc. healthcare providers offer remote care services to deliver non-urgent, non-emergency healthcare remotely, either through real-time video or audio technology. If you opt to use our remote care services, Optimal Health Holdings Inc. may ask you to confirm your identity, such as by presenting a government-issued photo ID to the healthcare provider at the beginning of your remote care session. Remote care sessions are not recorded. If you and your healthcare provider exchange personal information via the messaging function during a remote care session, the transcript from the messaging interaction will be added to your medical record.

We strive to ensure that any information you provide during remote care visits remains private and secure. However, as with all online communications, there is a risk that your health information could be intercepted by an unauthorized party or inadvertently disclosed. To minimize this risk, you should be in a private setting and avoid using an employer's or someone else's computer/device. Instead, your personal device should be used. 

Patient Portal: 

As a patient, you will be offered the opportunity to create an online account to access and use the Portal for communicating with us, scheduling and viewing appointments, purchasing products and services, accessing test results, and using our remote care services. To create and manage your account and authenticate you, we will collect your full name, email address, date of birth, and a password of your choosing. 

We also collect your provincial health card number to provide you with provincially funded health resources and to accurately identify and connect to your health records from other sources of information. You will have the option to add information to your account profile, such as gender, address, preferred contact method, phone number, emergency contact information, marital status, employment status, workplace name, and role, which help us understand your needs and tailor our products, services, and pricing to you. 

You are responsible for keeping your username and password secure and not sharing them with anyone else. We will never ask for your password in any unsolicited communication (such as letters, phone calls, or email messages).

Appointment Scheduling: 

We collect personal information when you book an appointment with a healthcare provider through the Portal, by phone, text message, email, or in person. 

This information may include the type of visit you prefer (i.e., in-person, virtual, or by phone), name, reason for booking the visit, medical history, and emergency contact information. 

We use this information to schedule your appointment and provide the healthcare provider with the necessary information to deliver healthcare services to you. For certain products and services, we will request a credit card number at the time of booking as described below. You can manage some of your appointment bookings or view your past and upcoming appointment bookings through the Portal or by contacting us.

Payment: 

If you purchase a product, service, or membership from Optimal Health Holdings Inc., we (or our authorized third-party payment processor) will collect your full name, payment information (including billing address, credit card number, expiration date, and CVV code), or if applicable, your private health insurance information, to process the transaction and enable Optimal Health Holdings Inc. healthcare providers to deliver the health care services you've purchased.

Marketing Communications: 

Providing health information and educational material is a core component of the Optimal Health Holdings Inc. service offering. When you join Optimal Health Holdings Inc. (or if we otherwise have your consent), we will collect and use your full name, email address and/or your mobile phone number to send you marketing communications, including information about Optimal Health Holdings Inc. resources, services, offers, events, and promotions that may be tailored to your interests and interactions with Optimal Health Holdings Inc.

Email:

For marketing e-mails that are not essential communications (e.g. appointment reminders), you can unsubscribe at any time by clicking the "unsubscribe" link at the bottom of each email or by adjusting your preferences through your account profile in the Portal. 

Alternatively, you can opt out of receiving email marketing communications by contacting us using the information provided in the "How to Reach Us" section below. Please note that you may continue to receive transactional, informational, or account-related communications from us even if you unsubscribe from marketing communications.

Surveys: 

Periodically, we may offer you the opportunity to participate in one of our surveys. We may use the information we obtain through our surveys, which may include personal health information, to review and identify opportunities for improving our delivery of healthcare and wellness services to our clients and as otherwise explained to you at the time of the survey.

Research and Analytics: 

From time to time, Optimal Health Holdings Inc. may conduct internal medical research projects utilizing personal health information previously and/or prospectively collected for the purpose of continuously improving the health services at Optimal Health Holdings Inc. 

Please note that Optimal Health Holdings Inc. will not use or disclose your personal health information for these projects in a manner that can identify you without first obtaining your consent or in a manner consistent with applicable law, such as with the approval of a research ethics board.

Optimal Health Holdings Inc. may generate and analyze de-identified data to create statistical summary reports across patient groups in order to better understand health trends and to improve Optimal Health Holdings Inc.'s operations and healthcare services. 

Such de-identified statistical summary reports may be shared with third parties (such as investors) in order to provide insight into our operations and healthcare services.

Careers: 

If you apply for a job with Optimal Health Holdings Inc., you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application. 

Visit a Clinic: 

We may conduct video recording for security purposes via cameras located in public areas of our clinic, such as the reception area and the clinic entrance and exit area. In areas of our clinic where we conduct video recording, we will post signs to notify you.

Third party service providers:
Optimal Health Holdings Inc. uses third-party software and service providers for a variety of services, such technical, operational, healthcare, and marketing services.  

Your personal information may be transferred (or otherwise made available) to third parties that provide services to us or on our behalf. We use third parties to provide services to us such as laboratory testing, virtual care technology, printing, mail distribution, cloud storage services, and payment card processing. 

Our service providers are only provided with the information they need to perform their designated functions. 

We require them to have security measures in place that are appropriate for protecting the type of information that is exchanged or collected via the service (e.g. medical record information requires more security measures than scheduling information). 

Some of our service providers operate from outside of Canada, which means that information they use to provide their services to us will be subject to the laws of other jurisdictions and may be available to foreign government authorities under lawful orders and laws applicable in those jurisdictions.

For additional details about our third party service providers, please click here.

If you have any questions regarding Optimal's use of these service providers, or the contractual and technical security protections in place, please contact us at team@BeOptimal.ca.

Note that as we continue to develop our services, we may expand or modify our list of third party service providers. 

Contacting Us: 

You may get in touch with Optimal Health Holdings Inc., including by telephone, email, or by using the messaging functionality on our Portal or electronic medical record (Avaros). 

When you contact us with a comment, question, or concern, you may provide information that identifies you, such as your name, email, and phone number, along with additional information we need to help us promptly answer your question or respond to your comment. 

We may retain this information to assist you in the future.

2. DISCLOSURE OF PERSONAL INFORMATION

We do not sell, rent, or disclose your personal information to third parties without your consent, except as described in this agreement or as required or permitted by applicable law.

Other health care providers: 

We may share your personal information with your other health care providers and facilities (e.g., another physician or health care practitioner, an allied health professional or member of your clinical care team, a public hospital, pharmacy, laboratory, or ambulance service) for the purpose of providing healthcare services. We may also share your personal information if it is required for the purpose of contacting your family or a potential substitute decision maker.

Benefits Providers: 

We may disclose certain personal information to your benefits provider for the purposes of coordinating payment from them, including your name, date of service, and the service provided. We may also share certain personal information with provincial health plans for billing of publicly funded services. 

Legal and Compliance: 

We and our Canadian, U.S. and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. In this context, your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: 

We may transfer information we have about our clients as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Optimal Health Holdings Inc. or as part of a corporate reorganization or other change in corporate control.

3. STORAGE AND LOCATION OF PERSONAL INFORMATION

We use service providers who may access or store personal information or personal health information in the U.S., or other foreign jurisdictions in the course of providing services to us. 

Personal health information that forms part of your medical record is stored in Canada but may be transferred outside of Canada with your consent (for example, to specialists located outside of Canada for the purposes of providing health services to you).

4. INFORMATION ABOUT OUR WEBSITES

Visiting our Websites: 

Generally, you can browse our websites without identifying yourself or providing personal information through the act of logging in to the Portal. 

However, we collect various analytics such as the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system, and average time spent on our Websites. We use this information to help us understand our Website activity and to monitor and improve our Websites.

Cookies: 

Our Websites employ a technology called "cookies". A cookie is a small piece of data that our Websites send to a user's browser, which may then be stored on the user's hard drive so we can recognize the user's computer or device when they return. You may configure your browser to notify you when you receive a cookie or to decline certain cookies. However, if you choose not to accept cookies from our Websites, you may not be able to utilize all of the Websites' features.

Analytics: 

Our Websites utilize web analytics services such as Google Analytics and Mixpanel to assist us in gathering and analyzing information about user behavior and engagement. Google Analytics is used on our landing website for non-members, while Mixpanel is employed to track member user behavior in our frontend application.

These analytics tools help us evaluate and enhance the user experience by collecting data such as pages visited, time spent, search terms used, and other engagement metrics. You can also obtain additional information on Google Analytics' data privacy and security at: 

• Google Analytics Partner Sites

• Google Analytics Data Privacy and Security

For information about Mixpanel's data practices, please visit:

• Mixpanel Privacy Policy

Third Party Links: 

Our Websites may contain links to other websites that Optimal Health Holdings Inc. does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. 

This Privacy Policy does not apply to information collected by the linked websites. They have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, secure, and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

5. SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical, and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. The only Optimal Health Holdings Inc. employees and service providers who have access to our clients' personal information are those who "need-to-know" the information in order to carry out their job duties.

We retain personal information only for as long as necessary to fulfill the purposes discussed in this Privacy Policy or to meet our legal or business requirements. 

Personal health information that forms part of your medical record will be retained in accordance with provincial and territorial retention guidelines.

Optimal Health Holdings Inc. may also create and retain de-identified or anonymized personal information for internal research and analysis purposes, including to improve business operations.

6. YOUR OPTIONS

Marketing Communications: 

If you receive our email marketing communications, you can unsubscribe at any time by clicking the "unsubscribe" link included at the bottom of the email or by adjusting your preferences through your account profile in the Portal. 

Withdrawing your Consent: 

If you have provided consent to our collection, use or disclosure of personal information, you can withdraw your consent at any time (subject to our legal or contractual restrictions) by contacting us at the contact information set out below. If you withdraw your consent, we may not be able to provide certain products or services to you.

Closing your Account: 

You can also close your account on the Portal at any time. To close your account or request to delete the personal information contained within your account profile, please contact us at the contact information below. If you choose to close your account or delete personal information contained within your account profile, we may retain certain information (including your medical record) to meet our legal or regulatory obligations. For more information, review the "Safeguards and Retention" section above.

7. ACCESS TO AND UPDATING OF INFORMATION

Subject to limited exceptions under applicable law, you have the right to access, examine, update and ask to correct inaccuracies in your personal information and personal health information in our custody and control (and, in certain provinces, to authorize another person to receive a copy of your personal health information). You may make such requests by emailing or writing to us using the contact information set out below. You also have the ability to update your personal information through your account profile or by calling Optimal Health Holdings Inc. We may request certain personal information from you when you make such a request in order to verify your identity.

8. UPDATES TO THE PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. 

We will indicate at the top of this Privacy Policy when it was most recently updated.

9. HOW TO REACH US

If you have any questions, concerns or comments about this Privacy Policy or the manner in which we or our service providers handle your personal information, or wish to request access to or correction of your personal information in our records, please contact us at:

team@BeOptimal.ca

You may also bring your questions or concerns to the Information and Privacy Commissioner of Ontario by visiting www.ipc.on.ca.