Privacy Policy

How KEEP Labs Inc. collects, uses and protects your information.

This Privacy Policy explains:

  • The information we collect and use
  • What we do with your information
  • How we secure your information
  • Your choices regarding our use of your information
  • Your ability to review and correct your information

Please carefully review this Privacy Policy so that you understand your rights in relation to the personal information you provide to us or that we collect from you in connection with your use of any of our products or services.

Overview

KEEP Labs Inc. is a corporation, formed under the laws of the Province of Ontario ("KEEP", "we", "our" or "us"). Any inquiries related to this Privacy Policy (the "Privacy Policy") can be directed to privacy@keeplabs.com. For the purposes of the General Data Protection Regulation ("GDPR"), we are the data controller.

This Privacy Policy applies to each of our products and services, including, without limitation, any device, software, applications, additions, content, uploaded information, downloaded information and other services (each, a "Service" and collectively, the "Services"), provided or made available by us through our websites or mobile applications (each, a "KEEP Site" and collectively, the "KEEP Sites") or any KEEP device (each, a "KEEP Device" and collectively, the "KEEP Devices").

The Privacy Policy establishes how your personal information or information about how you use the Services that we collect from you or from your use of the Services, KEEP Sites or KEEP Devices will be collected, retrieved, accessed, used, disclosed, stored or disposed of. Notwithstanding the foregoing, we will always act, and the Services shall always be in compliance with applicable laws, including (as applicable), the Canada Consumer Privacy Protection Act, California Consumer Privacy Act and the GDPR.

Notwithstanding the foregoing, and except as otherwise set forth herein, this Privacy Policy does not apply to any information or data collected by any third party that occurs outside of your use of the KEEP Sites or our Services and does not govern the practices of any third parties that may interact with our KEEP Sites or our Services.

By using our Services, you acknowledge that you have read and understood our Privacy Policy and our Terms of Use and Conditions and accept our collection, retrieval, access, use, disclosure, storage or disposal of your information and data, and the other activities set forth herein. If you do not agree to the terms of this Privacy Policy, please do not use any of our Services.

Personal Information

Collection of Information

In order to create and operate your account, communicate and respond to you (including, without limitation, to communicate with respect to the Services or respond to your inquiries), or communicate with other stakeholders involved in your care, such as, but not limited to providers of patient support programs and HUB services, pharmacies, distributors, caregivers and other healthcare providers (each, a "Provider" and collectively, "Providers") (where permitted), we need to collect your information, including personal information.

For the purposes of this Privacy Policy, "personally identifiable information" or "personal information" means any information by which you, individually, can be identified, any characteristic that uniquely identifies you, or that you provide us, directly or indirectly, through your use of our Services or which you authorize third parties to provide through any of our Services, including our KEEP Site and any of the KEEP devices that connect with any of our Services, including some or all of the following: first name and last, date of birth, gender, e-mail address, user name, password, address, phone number(s), internet protocol (IP) address, photographic images, health and medical information and geo-location of your device.

Health Information

In addition to the above, in order to provide certain Services, we will collect your health information and you may need to transfer certain health information to us. We will also receive and transmit information provided by KEEP Devices that connect with our Services. Your Provider may give us information about you, including, without limitation, the following:

  • Personal Information – First and last name, date of birth and home address
  • Health Information – Your medical diagnoses, medications you take, prescription related information, the number of refills you have made, dosage related information, information related to your health insurance, such as claims data and your doctor's name

Use of Personal Information

Personal Information Needed to Properly Provide Services

In order for us to be able to perform or for you to operate the applicable Service as intended, we will need to use or process your personal information to:

  • Verify your identity
  • Properly provide the Service, including recording the actions you take in using the Service and potentially contacting you with regard to such use
  • Customizing how you use the Service
  • Sending information to third parties (if applicable), including any Providers
  • Communicating with you or providing you with promotional or marketing materials on behalf of us or third parties
  • Detecting or preventing any fraudulent or other illegal activities
  • Managing, protecting and servicing our IT systems
  • Help us improve the Service, including changing or updating the functions, layout or structure of the Service
  • Provide customer support, including to resolve disputes, and troubleshoot problems
  • Comply with applicable laws and regulations
  • Any other purpose disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy

Marketing and Promotions

If you choose to receive marketing or promotional communications from us or any third parties, based on your preferences and behaviour, we may provide you with marketing or promotional materials or communications via email, phone or any of the Services. We will need to process, use and analyze your personal information in order to send you such communications or materials that are specific to your preferences and behaviour.

Use of Anonymized Information and Aggregated Information

In accordance with applicable laws, we may de-identify and aggregate your personal information. Any such de-identified, aggregated or combined information will not contain any information that could be used to contact or identify you. We may analyze and/or combine all information we receive related to your health and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our partners and by third parties without restriction, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Services.

Cookies

What are cookies?

We use cookies and similar technologies to collect information about your use of our Services and to improve the quality of your experience. A cookie is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser.

What information is obtained through cookies?

We obtain information through cookies and other similar technologies, such information includes, without limitation, the IP address of your device, identifying information associated with your device, type of device connected to the Services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to the Services.

What cookies are used?

Below is a description of the cookies that we use in our Services.

  • Essential Cookies – These cookies are necessary to navigate our Services and use the functions associated therewith and thus cannot be disabled. These cookies help us collect certain information, such as your session ID and other server information.
  • Functional Cookies – We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. We do not use functional cookies to target you with online marketing.
  • Analytic Cookies – We use analytics cookies to understand how users navigate and use our Services. Such cookies help us to improve the performance of our Services.
  • Advertising Cookies – We use advertising cookies to serve certain types of marketing and promotional materials, including for products and services not available through KEEP and for certain advertisements relevant to your interests.

Your Choices

You can disable cookies from your web browser by selecting the appropriate settings. Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, how to disable or remove existing cookies and when cookies will expire. Please note, however, that without certain cookies, you may not be able to take full advantage of our Services.

Providing Personal Information to Third Parties

Healthcare Providers

In order to provide certain Services and receive the benefit thereof, you may elect to share your personal information or other information with your Provider. Such sharing may be enabled by sending a Provider an invitation through the Service or by accepting an invitation from a Provider. Such sharing of your information is at your discretion and is solely your responsibility.

Partners and Third Parties

We may also share your personal information with our partners and with third-party independent contractors, including our providers that deliver necessary hardware, software, networking, storage, transactional services and/or related technology required to run the Services.

We require these service providers to provide a comparable level of protection of your personal information as we provide, to only process your personal information for the specific purposes mentioned above, and to have access to the minimum amount of data they need to deliver a specific service.

Disclosure Required by Law or to Enforce Terms

We may also disclose your personal information to third parties in the following situations:

  • To prevent, protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity
  • To comply with a court order, subpoena, search warrant, or other legal process
  • To comply with legal, regulatory, or administrative requirements of any governmental authorities
  • To protect and defend us and our subsidiaries and affiliates in connection with any legal action, claim, or dispute
  • To prevent imminent physical harm
  • In the event that your actions violate any laws or our Terms of Use and Conditions
  • Any other use as permitted or required by applicable law

Transfer in a Merger, Acquisition or Sale

We reserve the right to transfer your personal information to a third party in the event of a merger, amalgamation, change of control, acquisition or other similar transaction related to KEEP or a sale or other transfer of all or a portion of our assets.

Text Messaging

Text messaging originator opt-in data and consent will not be shared with any third parties.

Interactions and Links to Third-Party Sites

Our KEEP Sites and Services may allow you to link to the web sites, software applications and other services of third parties. These third-party services and features may operate independently from us. The privacy practices of the relevant third parties is subject to the privacy policies of these parties, which we strongly suggest you review.

International Users and Visitors

Personal information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside of Canada, please note that data we collect about you may be transferred to, processed and stored in the United States, unless otherwise noted.

Additional Rights

Data protection laws in certain jurisdictions provide individuals with certain statutory rights with respect to their personal information. If you reside in the UK or the European Union, you may have the right to request to:

  • Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information
  • Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format
  • Request rectification of your personal information that is in our control
  • Request erasure of your personal information
  • Object to the processing of personal information by us
  • Request to restrict processing of your personal information by us
  • Lodge a complaint with a supervisory authority

You also may opt out of receiving promotional communications from us by using the "unsubscribe" button below each email we send you or by contacting us at privacy@keeplabs.com.

Data Retention

We will retain your information for as long as we are required in order to provide the Services to you, as required to fulfill our legal obligations, commitments we made to and on behalf of you or any of our customers in order to provide the Service to you, and as required to defend legal claims. After you have terminated your use of our Service, we may store your information in an anonymized format.

Security

We, and our third-party providers, employ organizational, technical and physical safeguards designed to protect against the loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.

California Privacy Rights

Under the California Consumer Privacy Act, California residents are entitled to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please contact us at privacy@keeplabs.com with "California Privacy Rights" as the subject line.

Nevada Privacy Rights

Nevada Revised Statutes §§ 603A.300-.360 permits Nevada residents who have supplied personal information to us to, under certain circumstances, request and opt-out of the sale of your personal information to third-parties for their direct marketing purposes. If you are a Nevada resident and would like to make such a request, please contact us at privacy@keeplabs.com with "Nevada Privacy Rights" as the subject line.

Children

Our Services, KEEP Sites and KEEP devices are intended for use by persons of legal age to form a binding contract in the applicable jurisdiction. If you are not the legal age to form a binding contract, you may use a Service only with the consent and under the supervision of a parent or legal guardian who consents to this Privacy Policy.

If you discover that your child has been using a Service without your consent, please contact us using the information below and we will take reasonable steps to delete the child's information from our active databases.

How to Contact Us

In the event that you have any questions, comments, requests or concerns related to this Privacy Policy, please contact us at:

KEEP Labs Inc.
1108 – 250 Consumers Road #750
North York, ON M2J 4V6

Email: privacy@keeplabs.com

You may also contact our Data Protection Officer: DPO@keeplabs.com

Revisions to this Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a notice on or through our KEEP Sites or Services to notify you of significant changes to this Privacy Policy and indicate at the top of the revised policy when it was most recently updated.

YOUR USE OR CONTINUED USE OF OUR SERVICES, ANY KEEP SITE, ANY KEEP DEVICE FOLLOWING OUR POSTING OF REVISED PRIVACY POLICY WILL CONSTITUTE BINDING ACCEPTANCE OF SUCH REVISED PRIVACY POLICY AND THE APPLICABLE CHANGES.