Privacy

Perkk Digital Services Privacy Statement

Perkk Digital Services is committed to quality, trust, integrity, and strong relationship-building with our clients and end users. This includes protecting the privacy of all personal information we receive including what we collect through digital channels like our Website and mobile application (“App”).

The purpose of this document is to keep you informed about privacy protection practices at Perkk Digital Services. In addition to this privacy statement, we have a New Online Privacy Statement that describes our practices for protecting your personal information when you use our website and web application. This privacy statement was last updated in November 2023. Our Privacy Statement may be updated from time to time, but you will always find the most current version here. Your continuing relationship with us shall be deemed as acceptance of and agreement to any such modifications.

1. Personal Information We Collect

In this Privacy Statement, “personal information” means any information that is related to an identifiable individual, or as otherwise defined under applicable privacy law.

Personal information you provide directly to us

We collect personal information from you directly when you sign up to use Perkk Check, when you use the app, when you contact or communicate with us online, by phone or in person and when managing our business relationship with you. The categories of personal information we may collect from you directly include:

• Contact information such as your full name, address, telephone number, email address;
• Demographic information such as your birth date and gender at birth or other identifying information;

• Identification information such as an ID number, username and password;

• Medical information such as height, weight, diagnoses (diabetes type), if you take blood pressure medication, if you smoke, facial blood flow, survey responses; and

• Business contact information such as company name, business email address, and business phone number, position title or professional designation.

Information we collect automatically

Depending on the device you use or the method you use to interact with us, we may automatically collect digital information about your device, your location and your use of our site. Please see our Online Privacy Statement for more information about how we collect, store and use information electronically, including through our website and our web app.

Personal information we collect from other sources

We may also collect personal information about you from other sources, including:

• Your health care practitioners; and

• Other third parties you allow to share information with us;

We do not collect any images, video, or audio/sound. The data uploaded from your device and used to predict your health and wellness scores contains only signals generated from light reflected by specific regions of your face during the time taken for the measurement, as well as your medical profile (height, weight, diagnoses (diabetes type), if you take blood pressure medication, if you smoke, facial blood flow, survey responses). Data is de-identified during processing and is deleted immediately after processing your results.

2. How we use your personal information

Perkk Check uses Personal Information for the purposes of account registration, to verify your identity when you log in, for the administration and use of Perkk Check app (e.g., during the assessment, the app will require demographic and medical information for the artificial intelligence and machine learning models to calculate measurements and derive results). In particular, artificial intelligence and machine learning models are used to calculate your measurements and derive health and wellness results from the data you provide.

This Personal Information may also be used or disclosed:

• In order to track unauthorized access to Perkk Check; and

• Understanding your preferences for engaging with us (e.g., via email, telephone, etc.);

Determining if there are other suitable products or services you might be interested in and sending you details about them. You can ask to be removed from our marketing lists at any time. We may also use your personal information for other purposes that you have consented to or for other purposes that are authorized by law. For example, we may use your personal information for:

• Protecting you and us from errors, misrepresentations, fraud and/or contravention of laws or criminal activity;
• Fulfilling contractual obligations imposed by service/program providers;
• Helping us make decisions to improve the products and services we offer; and

• Providing customer services (such as troubleshooting) related to Perkk Check.

3. Consent

With some exceptions, we require your consent to collect, use and disclose your personal information. We do not require additional consent to use your personal information for providing or delivering a product or service you use or apply for. Other exceptions are determined by law and can include legal, medical or security reasons that make receiving your consent impossible or impractical such as fraud prevention and detection or assessing or improving security measures.

Your consent may be given in writing, verbally, electronically or through authorized representatives. It may also be implied (such as if a health care provider uses the information to help them provide care for you).

You may withhold or withdraw your consent for us to collect, use or disclose your personal information if there are no legal or contractual requirements that prevent it. Please note that by withdrawing your consent, we will not be able to provide you with certain products or services that may be useful to you.

For information of how to withdraw your consent, please contact us or delete your account.

4. Disclosing your personal information

We may disclose your personal information for the purposes we collected it or for another purpose to which you have consented, or which is permitted or required by law.

We may disclose selected Personal Information to the following in connection with your use of Perkk Check:

• Any person or organization you give consent to;
• A health care provider at the organization where you were enrolled and will be used to help them provide care for you;
• People, organizations, and investigative bodies who work to prevent, detect, or investigate suspected fraud, breaches of agreement, or contravention of the law;
• Other people or organizations who are legally authorized to view your personal information;

• Government and regulatory authorities in an emergency situation or where required by law; or

• Other third parties, on a confidential basis, when required to administer Perkk Check or related services. Perkk Digital Services may procure the services of external service providers in order to effectively operate, administer and audit the use of Perkk Check.  In some cases, we provide your personal information to authorized employees, people, organizations, and service providers in other provinces or jurisdictions than where it was collected. These parties may be subject to the laws of those provinces or jurisdictions. If you are a Quebec resident, this means your personal information may be disclosed or transferred outside Quebec including to service providers outside of Quebec.

When we share personal information with our service providers, we ensure by contractual means that they protect it in ways that are consistent with our privacy policies and practices.

We do not sell your personal information.

5. How long we retain your personal information

We keep your information for one of the following time periods, whichever is longer:

• As long as we are required by law and guidelines; and
• As long as we need to for managing the products and services we provide you.

The types of products and services we offer may require us to keep your information for extended periods of time. Personal information that is no longer required is destroyed, deleted, or made anonymous.

6. How we protect your personal information

Perkk Digital Service’s information security has been developed and continually enhanced to protect your personal information from unauthorized disclosure, access and use. Physical, organizational, and technological safeguards are in place to protect this information, based on its nature and sensitivity.

All Perkk Digital Service employees – including full, part-time and contract employees – receive privacy training, sign confidentiality agreements and must follow our corporate privacy policies, as a condition of their employment.

All employees who are authorized to handle personal information as part of their duties work to ensure that the information is handled with the appropriate level of care and protected at all times.

7. Your Rights

Rights of access

You may submit a written request at any time to Perkk Check Digital’s Chief Privacy Officer to obtain a copy of your personal information we hold about you. We will also inform you, upon written request, of any of the following information:

• The existence and nature of any personal information we hold about you, the purposes for which we collected it, how we collected it, or the sources of the personal information;
• The names of the individuals or categories of third parties with whom it is necessary for us to communicate your personal information;
• The categories of Perkk Digital Services employees who have access to the information; and
• The length of time your personal information will be kept.

Any personal information you request will be provided in writing, with certain exceptions allowed by law. Please understand that, depending on specific circumstances, we might not be able to provide all of the information you request. There may also be a fee for such information; you will be notified after your request is evaluated.

Right of correction

Perkk Digital Services strives to ensure that any personal information we collect, use or disclose is as accurate and up-to-date as possible in order to meet the needs for which it is used. We encourage you to use our Perkk Check App or access your account online to update your personal information. You may also contact us if your information needs to be updated, allowing us to best meet your needs in the future.

If we inform you about the existence of or provide you with a copy of your personal information and you believe that it is inaccurate, incomplete or ambiguous you can request that we correct the information. If you believe that the collection, disclosure or retention of your personal information is not authorized by law, you may ask us to rectify the matter.

We will require that you prove your identity before we process your request for access to, or correction of your personal information. A request will also be considered if it is made by a person acting as the representative, heir or successor of the person concerned, liquidator of the estate, beneficiary of life insurance or death benefit, or holder of parental authority. In all cases, this person will have to establish their capacity and identity. Such requests must be made in writing.

We will respond to your access or correction request within 30 days of the date of receipt.

To ensure Perkk Digital Services is able to provide you with the best possible service, it is important that the Personal Information we use is accurate and up to date. Should you become aware of errors in our information about you, please contact our customer service personnel and we will ensure the data is corrected.

Please contact Perkk Check Digital’s Chief Privacy Officer at the mailing address or email address provided below to make an access or correction request.

8. Contact us with your privacy questions, concerns or complaints

You may submit a written request to Perkk Digital Service’s Privacy Officer on any aspect of our personal information governance and procedures, including:

• Questions about privacy policies and practices and/or to obtain additional information;
• To exercise your rights (including the right of access to and correction of your personal information and the right to withdraw consent), as described in this Privacy Statement; or
• To voice a concern or make a privacy-related complaint. We have established an internal privacy complaint review process. We will investigate all complaints and we endeavor to respond to all privacy-related complaints and address any concerns as quickly and thoroughly as possible. If a complaint is found to be justified, we will take appropriate measures to correct the situation.

If you require further information on our privacy policy, please address your questions, concerns or complaints in writing to:

Chief Privacy Officer

Perkk Digital Services

644 Main Street

PO Box 220

Moncton, NB E1C 8L3

or

Privacy@perkkcheck.ca

If the issue is not resolved to your satisfaction, you may file a complaint in writing to:

Office of the Privacy Commissioner of Canada

30 Victoria Street

1st Floor

Gatineau, QC

K1A 1H3

Website: www.priv.gc.ca

Effective November 2, 2023.