Internet Privacy Statement

Innovation Health Group Inc.

SUMMARY INTERNET PRIVACY STATEMENT Effective Date — April 18, 2019

THIS NOTICE DESCRIBES HOW YOUR PERSONAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW CAREFULLY.

This Privacy Statement applies to customers using Innovation Health Group Inc’s affiliated website to order and/or receive medical reports.

A Note to Non-U.S. Users

You expressly consent to the processing of your personal information in the United States in accordance with this Full Privacy Statement with respect to certain laboratory tests.  Details can be provided upon request as laboratory providers can vary from time to time.

A Note to Non-Canadian Users

You expressly consent to the processing of your personal information in Canada in accordance with this Full Privacy Statement with respect to certain laboratory tests.  Details can be provided upon request as laboratory providers can vary from time to time.

SCOPE

The Full Privacy Statement that follows tells you how Innovation Health Group Inc. (IHG) collects, protects, uses, and shares the information you provide us and the choices you have regarding our use of, and your ability to correct, that information. The Summary Privacy Statement is intended to introduce the Full Privacy Statement, not replace it. Later, it also serves as a quick reference guide to key information. By using our services, you acknowledge that you have reviewed and agree to the terms of the Consent, Full Privacy Statement and the Terms of Service.

INFORMATION WE COLLECT

By accessing or using this website or other services, purchasing a sample collection kit, or establishing a IHG account or submitting a sample, we will collect and store your personal information. This information identifies you or can be linked to your identity and Account Information. The following describes the types of personal information that we collect and store:

  • Account Information (contact and payment information, personal information for testing (e.g., date of birth, gender, ethnicity, weight, height, etc.) and information in Personal Settings)
  • Survey-Based Information (Health Survey and Other Surveys)
    • Sample and DNA Extract
    • Type of Genetic and Lab Report(s)
    • Health Information
      • Full Health (health conditions, carrier status, drug response)
      • Health Conditions (at risk diseases and complex health conditions)
      • Drug (Medicine) Response
      • FIT (diet and exercise)
    • Genetic Counseling Information
  • Other Customer Provided Information Online Profile Information (computer IP address and non-personal information, such as browser types, web page views)
    • Friend’s Name and Email
    • Customer Service Notes
  • Aggregate Information (summarized information unlinked to name or Account Information) When you visit our site, use our services, or view our online advertisements, we use cookies and other technologies to collect Online Profile Information about you.

HOW WE USE YOUR INFORMATION AND YOUR CHOICES

  • IHG collects and uses your Account Information, Genetic and Laboratory Information, Survey-Based Information, Other Customer Provided Information, and Online Profile Information to provide you our services.
  • IHG’s Comprehensive Genotype Testing process collects more Genetic (genotype) Information than is used to complete your genetic report that was ordered.
  • Third Party Service Providers may have access to and use Account Information, Survey-Based Information, and Other Customer Provided Information to deliver these services to you on our behalf. IHG-authorized physicians, health counselors and their agents may also have access to Genetic and Laboratory Information and other personal information to fulfill their responsibilities.
  • You cannot opt-out from transactional communications that are essential to delivering our services to you, unless a marketing message or advertisement is included.
  • We analyze and use Aggregate Information (unlinked from your name or Account Information, and Online Profile Information (your computer IP address and non-personal information) to track and monitor aggregate usage of our website and to improve the quality and features of our website and services. You can delete cookies as described in Cookies, under the Online Profile Information section of Information We Collect in the Full Privacy Statement.
  • We use your Account Information, Genetic and Laboratory Information, and Survey-Based Information to offer the right products and services from IHG and Trusted Partners to you. In this case, we maintain control of your personal information. You can opt-out from receiving each of these marketing communications (see the “How To Exercise Your Choices” section that follows). You can also delete cookies as described in Cookies, under the Online Profile Information section of Information We Collect in the Full Privacy Statement.

HOW WE SHARE YOUR INFORMATION AND YOUR CHOICES

  • IHG will NOT share your Genetic Information or any other personal information with your employer or health insurance issuer.
  • Your genetic testing results will be disclosed to the ordering physician, who determines at his/her discretion whether to release the results to you, and IHG will not release your report to anyone else unless required by law.
  • Any reseller of our products or services should not collect personal information from you without your consent.
  • We may contact and give you the opportunity to opt-in or refuse before any personal information is shared for any secondary purpose outside IHG’s immediate control, including published scientific research. We also may pass on to you a research collaborator’s request that you volunteer additional information or participate in a study. No name or Account Information is shared with a research collaborator without your express consent.
  • If you are a customer as a result of participating in your employee wellness program, IHG only provides your employer Aggregate Information unlinked to your name or Account Information.
  • We may disclose or report your personal information when we believe in good faith that the disclosure is required or permitted by law or regulation, a court order or other judicial or legal process or proceeding, or to cooperate with regulators or law enforcement authorities to resolve consumer disputes.
  • If IHG enters into a business transaction, such as a merger, acquisition by another company, selling some or all of its assets, or bankruptcy, your personal information will, in most instances, be part of the assets transferred. We will require the acquiring company to comply with the material provisions of the Full Privacy Statement upon entering into such business transaction.

HOW TO EXERCISE YOUR CHOICES

  • Opt-outs – To the extent you are permitted, you may exercise your right to opt-out by either a) clicking the unsubscribe link in the footer of any Pathway’s email or replying with unsubscribe in the subject line, or b) writing to us at the address in the Contact Us section at the end of this Privacy Statement.
  • Opt-ins – You may exercise your right to opt-in when expressly presented with this choice prior to the indicated personal information being shared.

ACCESSING, CORRECTING, UPDATING, OR DEACTIVATING YOUR INFORMATION

  • IHG will not be responsible for any liability caused by you sharing your personal information with others.
  • If your Account Information changes (such as email address, street address, or phone number), you can log into your account and change the appropriate information.

HOW WE STORE AND PROTECT YOUR INFORMATION

IHG has adopted administrative, physical and technical security measures to protect your personal information. However no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we use commercially reasonable and appropriate means to protect your personal information, we cannot guarantee its absolute security.

POLICY ON MINORS

  • For orders authorized by your personal physician, we may collect personal information from minors. However parent or guardian consent should be obtained and maintained by your physician.
  • In any event, we will not knowingly market products or services to children under 18

HOW TO CONTACT US FOR PRIVACY COMPLAINTS, QUESTIONS OR COMMENTS

If you have questions or comments regarding our privacy practices or have a complaint about our use or disclosure of your personal information or our privacy practices, you may contact us either by mail, or phone as follows:

Chief Privacy Officer, Innovation Health Group Inc. 4120 Yonge Street, Suite #306, Toronto, Canada. M2P 2B8.  Tel: 416-222-5800