Rhea Health Inc. (“Rhea,” or “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
- on our Website and any and all sub-domains of such Website
- on our Platform and App;
- in email and other electronic messages between you and our Website, Platform, and App;
- when you contact us by telephone or email; and
- when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.
This policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website, Platform, or App.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services.
Rhea can be used by health professionals in connection with their provision of services to their patients. Rhea is not a medical diagnostic device and does not provide medical treatment. Rhea provides movement exercise information and instructive videos for general information purposes only. You should always seek the advice of your qualified health care professionals with any questions or concerns you may have regarding your individual needs and any medical conditions. All information provided by Rhea, or in connection with any communications supported by Rhea, is intended to be for general information purposes only, and is in no way intended to create a provider-patient relationship. Your Provider, and not Rhea, is responsible for the quality and appropriateness of the care they render to you and for safeguarding any personal or health information they collect from you.
1. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect different types of information about you, including information that may directly identify you, and information that is about you but individually does not personally identify you. This includes information that we collect directly from you or through automated collection technologies (see “Information We Collect Through Automatic Data Collection Technologies, Interest-Based Advertising” below).
For purposes of this Policy, the term “Personal Information” means information about an identifiable individual that is provided through the Services, such as name, contact information, date of birth, and any associated health information, including information relating to physical or mental health, health history, and current health status.
What Personal Information does the Website Collect?
The Website may collect Personal Information such as your name, address, phone number or email address, as well as Website usage information.
What Personal Information does the Platform and App Collect?
Through the Platform and the App, you may provide us with a variety of Personal Information about you such as:
- your name, postal address, billing address, e-mail address, numbers, credit or debit card information (for payment purposes only);
- your date of birth and demographic information (gender, education, health, family and lifestyle information, etc.,);
- your state of health and health history;
- your assessment report and information related to your assessment and suitability for services through the Platform, and records relating to your progress through the Active Recovery Program;
- if you have chosen to link peripheral devices to the Services, heart rate and sleep data from those peripheral devices;
- your responses to request for information and/or health status questions at follow-up intervals after you have completed the Active Recovery Program;
- details of transactions you carry out through our Platform or through the App and of the fulfilment of your orders (you may be required to provide financial information before placing an order through our Platform or App); and
- Platform or App usage information.
2. HOW IS PERSONAL INFORMATION USED?
We will use your Personal Information to:
- Deliver and administer Active Recovery Program and related services to you;
- Communicate with you to provide you with information about possible services and resources, and to provide other reminders, prompts and feedback about your progress through the Active Recovery Program; and/or
- Provide you with ongoing service and support and to help us better understand your needs.
- Market and promote our services to you, including through interest-based advertising.
We may also use your information for such other purposes as you may consent, or when we believe such use is permitted, necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.
Your Personal Information may be de-identified and/or aggregated, and thereafter used for the purposes of improving and developing new assessment processes or other related product or service offerings, research, including academic and non-academic research, machine learning, artificial intelligence and other types of analytics, quality assurance, performance reporting, customer reports, promotion and advertisement, and business development.
3. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES, INTEREST-BASED ADVERTISING
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
- details of your visits to our Website, Platform or App, such as traffic data, general location (e.g., country, province), logs, referring/exit pages, date and time of your visit to our Website or use of our Platform or App, error information, clickstream data, and other communication data and the resources that you access and use on the Website or in the Platform or App; and
- information about your computer, mobile device, and Internet connection, specifically your internet protocol address, operating system, browser type, and App version information.
We may associate the information we collect automatically with Personal Information provided by you or received from third parties.
It helps us to improve our Website, Platform, and App to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Services according to your individual interests;
- recognize you when you use our Services.
The technologies we use for this automatic data collection may include:
- Tracking Pixels. Pages of a Website, Platform, or our e-mails, may contain small electronic files known as tracking pixels (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 e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links:
https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631
We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. Interest-based advertising (also known as targeted or behavioral advertising) means that your preferences and interests are collected through cookies or similar means, and then used to serve you advertising and marketing materials that are relevant to you (based on those preferences and interests). Without interest-based advertising, you would still be getting ads when browsing the Internet. However, these ads would not be personalized based on your preferences and interests – and so, they would be less relevant to you, and less effective for us.
From time to time, we may use other web analytics services to collect certain information relating to your use of the website.
You can manage your cookie preferences through your browser, such as by uninstalling and blocking certain cookies. Click on your browser below to obtain instructions.
You can install the Google Analytics opt-out browser add-on mentioned above.
To know more about why you are seeing an ad, how to control and/or opt-out of marketing cookies and tracking technologies for interest-based advertising, please visit the Digital Advertising Alliance of Canada website for more information on the AdChoices Tools. You can also consult Google Ads.
Some of the cookies that we use are essential or recommended for the use of the Services, and you may not be able to access and use all the Services without these cookies.
4. HOW WE SHARE YOUR INFORMATION
We may transfer your Personal Information to service providers we use to support our business. The services provided by these organizations include providing information technology and infrastructure support services, and ordering, advertising, marketing, and payment processing services. It is our policy to require that these service providers keep your Personal Information conﬁdential, to restrict use or disclosure to permitted purposes, and to comply with all applicable laws.
For example, we have engaged Stripe to process any of your online credit card transactions. For more information about Stripe’s privacy practices, see https://stripe.com/en-ca/privacy
We may disclose your Personal Information on your direction or for such purposes as you may consent, or when we believe such disclosure is permitted, necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may also disclose your Personal Information 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 Rhea about our Website, Platform, and App users are among the assets transferred;
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
5. YOUR RIGHTS REGARDING YOUR INFORMATION, AND ACCESSING AND CORRECTING YOUR INFORMATION
You have the right to access and correct your Personal Information, and may have the right to withdraw or modify your consent to our use and sharing of your Personal Information – in each case pursuant to applicable law.
You can review and change your Personal Information by logging into and using our Platform or App.
You may also review and change your Personal Information, or modify your consent to our use and sharing of your Personal Information (subject to applicable law), by contacting us through the Contact Information below.
Please notify us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible.
6. OUR SECURITY MEASURES
We are committed to protecting the security of your Personal Information. We have put in place commercially reasonable physical, electronic, and administrative measures in an effort to safeguard and help prevent unauthorized access to your Personal Information. We apply security safeguards appropriate to the sensitivity of the Personal Information, such as retaining information in secure facilities and making Personal Information accessible only to authorized individuals on a need-to-know basis.
The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
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 Website or on or through our Platform or App. Any transmission of Personal Information is at your own risk.
7. RETENTION OF PERSONAL INFORMATION AND STORAGE
We will retain your Personal Information for as long as necessary to fulfil the purposes for which that Personal Information was collected and as permitted or required by law.
8. CONTACT INFORMATION
How to Contact Us:
Attention: Privacy Officer
Rhea Health Inc.
333 Bay Street, Suite 2400
Toronto ON M5H 2T6