Privacy Policy

This Privacy Policy is designed to inform End-users of the Privacy Policy for the Jevitty mobile application (the “Application”) and related services (collectively, the “Service”). “Jevitty” in this document refers to the Jevitty Life Science Corp. (“Jevitty”, “Us”, “us”, “our”, “Our”, “We” and “we”). This Privacy Policy covers how Jevitty treats your Personally Identifiable Information (“PII”), Protected Health Information (“PHI”), and other data that you may share when you use the Service (“Data”) (your PII, PHI, and data is collectively referred to hereafter as “Personal Information”). The purpose of this Privacy Policy is to inform users of the Service about the collection, use and disclosure of information retained in the Service.

READ THIS PRIVACY POLICY CAREFULLY BEFORE DOWNLOADING, INSTALLING OR MAKING ANY USE OF THE SERVICE. BY USING THE SERVICE OR BY CLICKING “I AGREE”, OR BY REGISTERING FOR AN ACCOUNT, YOU ARE SUBMITTING YOUR ACCEPTANCE AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT MAKE ANY USE OF THE SERVICE.

Minors’ Information

The Service is not directed or intended for children under the age of majority. Unless otherwise disclosed, by using the Service, you represent that you have reached the legal age of majority in your jurisdiction of residence. Unless otherwise disclosed during collection and with parent or guardian consent, Jevitty does not knowingly collect Personal Information from children under the age of majority.

Changes to this Privacy Policy

We may, at any time and from time to time at its sole discretion, update, revise, supplement, replace, and/or otherwise modify this Privacy Policy from time to time, by posting a new version online to our website, to the Application or by Jevitty otherwise making them available to You (as the case may be). You should check this page occasionally to review any changes. Such updates, revisions, supplements, replacements, modifications, and additional policies, terms, and conditions will be effective immediately upon being posted to our website, to the Application or by Jevitty otherwise making them available to You (as the case may be).

If we make material changes to the Privacy Policy affecting you, as determined by Jevitty, we will notify you by posting the revised Privacy Policy on our website and, if you are a registered user of our platform, by providing notice through the Jevitty Application or by email. This helps you always be aware of what Personal Information we collect, how we use it, and under what circumstances, if any, it may be disclosed. Your continued use of the Service and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

Questions and Suggestions

If you have any questions or suggestions about this Privacy Policy, or if you wish to correct your Personal Information, please contact us by email at privacy@jevitty.com.

Types of Information Collected

Jevitty collects Personal Information when you register for the Service or when you use the Service. Depending on how you use the Service, we collect different kinds of information about you. This information may include:

Personal Health Information (PHI)

Any information that identifies you as a patient of a health care provider or any other information regarding your health may be PHI. We will only use or disclose PHI as permitted or required under Canadian law and the Personal Information Protection and Electronic Documents Act (S.C. 2000, c.5).

PHI is collected in the Application via your mobile device, using Apple’s Health Kit functionality, and other means. This PHI is securely stored and processed for display in the Jevitty Application and used to provide you with feedback on your health, provide recommendations, information and product information aimed at informing your decisions about a healthier lifestyle.

Personally Identifiable Information (PII)

PII is any information that can individually identify you, and includes your name, and contact information, such as e-mail address, telephone number, or postal address. This may be provided by you to us, at the time of sign up and user account creation.

Non-Personally Identifiable Information

Non-personally identifiable information includes information that does not personally identify you, but it may be linkable to you. If non-personally identifiable information is directly linked to PII, it will be considered PII while it is so linked to PII. Aggregated and de-identified information is not considered PII, because it is not possible to identify you from such aggregated and de-identified information.

Personal Data

The Service may collect the following kinds of Personal Data from you, by itself or through third parties: geographic position, general activity data, movement activity, mobile device and mobile application usage data, first name, last name, email address, body measurements & indexes, sleeping activity, phone number and picture. 

Personal Data may be freely provided by the user of the Service, or, in case of mobile device and mobile application usage data, collected automatically by your device. Such Personal Data is considered to be Personal Information and is treated as Personal Information for the purposes of this Privacy Policy.

Failure to provide the requested Personal Data may limit Jevitty’s ability to provide its Service to you. In cases where the Service specifically states that some Data is not mandatory, you are free to withhold this Data, but accept any resulting loss in the quality and/or availability of the Service or certain functionalities of the Service. 

Collection and Combination of Information from Other Sources

We also may collect Personal Information about you that we may receive from other sources or from our offline interactions with you to, which among other things, enable us to verify or update the information contained in our records and to better customize the Service for you. We may combine Personal Information gathered from multiple parts of the Service, or Jevitty’s other systems and services, into a single record.

Information Collection 

Jevitty may collect the following Personal Information from you:

  • Personally Identifiable Information: We may collect PII you provide, such as your name, phone number, address, city, and email address, if you visit or use our website or Application, or register or apply for one of our products or services. Such PII may also be provided in connection with creating and maintaining an account with us;

  • Personal Health Information: self-reported health information, name and contact information of physician or care provider, information about conditions and symptoms you may be experiencing or medications you may be taking, and diagnostic health information such as heart rate and blood pressure; and

  • Personal Data: geographic location, movement, change in altitude, data about surroundings and geographic position data, customer support data, usage data, your device’s unique identifier, and files that record your interactions with the Service (System logs) or other Personal Data (such as IP address).

The above list is representative of the type of PI that the Service may collect at the time you sign up for the service, and is not exhaustive. The design of the Service may change without notice and additional PI may be collected in order to provide the service.  

Information Use

Jevitty may use Personal Information in the following ways in order to provide the Service:

  1. Registration – When you register for the Service, we collect your Personal Information as part of the registration process and may use such Personal Information to manage and customize your account and communicate with you.

  2. Personalization – We collect information such as your picture in order to personalize the Service and your account with the Service.

  3. Notifications – Registered users of the Jevitty platform may receive push notifications according to their user settings.

  4. Self-Reported Health Information – We collect the information that you enter while using the Service, such as information regarding your health and related behaviours, to provide the Service, and analyze and process the health information that you provide.

  5. Automatically Tracked Health-Related Information – For registered users of our platform, the Service may use Apple HealthKit data to provide these features. HealthKit is an activity data handling service provided by Apple Inc. that enables Jevitty to access or store activity and health data.  Apple HealthKit’s privacy policy is set by Apple Inc., and your personal information that you provide to Apple HealthKit is governed by that privacy policy.

  6. Customer support – We may use your contact information to send you information about our Service, your account, or information relating to your health, to respond to technical support inquiries, or to help prevent spam, fraud or abuse. When you enter Personal Information into an inquiry or contact form in any portion of the Service, Jevitty uses the information provided to reply to the applicable inquiries, requests for information or other requests.

  7. Contact and sending messages – We may collect your email address, phone number and other contact information to communicate with you, to manage contacts and communications, and to send you messages relating to your account and the Service.  Your Personal Information allows us to contact you by various methods, including mail, email, SMS message, Application push notification, and telephone at the contact points you have provided to us.

  8. System maintenance – For operation and maintenance purposes for the Service, we will record your interactions with the Service to ensure suitability and security of the Service.

  9. Analytics – Jevitty may collect and use your device’s unique identifier for analytics purposes, to store your user preferences or to monitor and analyze user behaviour. Advertising and marketing. We may use your Personal Information to provide you with offers, advertising and marketing. Elements of your Personal Information may be used to determine your suitability, or to directly communicate with you, for targeted advertising, marketing, promotions, rewards programs, research or contests.

  10. Research – Information collected by Jevitty in conjunction with your use of the Service will not be used for research purposes by third parties, without your explicit consent. In such an event, the use of your information will be subject to additional terms of informed consent and/or other authorizations from you, which we will separately obtain from you. Any research undertaken by a third party will be subject to applicable organizational governance and/or ethics review.

Information Sharing and Disclosure

Jevitty does not rent, sell or share your Personal Information with other people or non-affiliated companies, except as set out in this Privacy Policy, including to provide products or services you have requested. We may provide information to companies or consultants working on behalf of or with us under confidentiality agreements as described below (“Third Party Agents”). These companies and consultants do not have any independent right to share your Personal Information.  We may also disclose aggregated data for our business purposes. When you engage with other companies directly, or contact us through their platforms, their use of the Personal Information they collect from you is subject to the terms of their privacy policies.

We limit use, disclosure and retention of Personal Information to the purposes we identify, and as required by applicable laws. We do not sell or rent customer lists or Personal Information to others. We may share your Personal Information with regulators, courts or other institutions as required by law.

Third-Party Agents

We have third-party agents and service providers that perform functions on our behalf, including, but not limited to hosting services, content syndication, content management, technical integration, marketing, analytics, customer service, and fraud protection. These entities may have access to aggregated or non-aggregated Personal Information if needed to perform their functions. If such access is required, we will limit disclosure of Personal Information to only that Personal Information that those third parties require, and the third parties will be contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, or distributing this data in any way other than to provide the requested services to the Service or as required by law.

Business Purposes

We may disclose de-identified versions of your Personal Information and other data (“De-Identified Information”) in aggregate forms with partners, investors and contractors for any purposes related to our business practices. Permitted uses of your De-Identified Information may include but are not limited to, product development, marketing and disclosures required by law, for example, to securities regulatory bodies and their reporting requirements under applicable laws. We may, at any time, sell, transfer, or assign any or all of our rights to our Canadian business, including our interests, rights or obligations regarding your accounts with us. If we do so, we may share your Personal Information with prospective purchasers, transferees or assignees. In such transactions, customer information shall be treated as a transferred business asset. In the event that Jevitty (or all, or substantially all, of its assets) is acquired by a third party, Jevitty’s customer information will be considered a transferred business asset.

Consent

If you apply for a product or service, communicate with us, or provide Personal Information to us in any way, you acknowledge your consent to the collection, use and disclosure of such Personal Information as you provide to us or that we otherwise collect as set out in this Privacy Policy and applicable laws. If we want to use your Personal Information for a purpose that was not disclosed at the time of initial consent, consent will be sought at the time of this new purpose.

Updating consent. Subject to legal and contractual restrictions, you can, with reasonable notice to us, withdraw your consent to the collection, use, and disclosure of your Personal Information. To opt out of our email marketing list after you have opted in, you may use the unsubscribe link provided in any email marketing material you receive. To update your privacy preferences outside of email marketing, you may do so by updating your privacy preferences associated with your account, or by emailing privacy@jevitty.com and with the subject line *Email-Opt Out.

Confidentiality and Security

We have taken a variety of reasonable and necessary steps to ensure that all Personal Information collected will remain secure, and protected against loss, theft and unauthorized access. These steps include physical, electronic, and administrative procedures to safeguard and help prevent unauthorized access or disclosure, maintain data security and correctly use the Personal Information that we collect.

The processing of the Personal Information we collect is carried out using computers and/or IT-enabled tools, following organizational procedures and modes appropriate and necessary for providing the Service. Personal Information is stored and processed in Canada and is subject to applicable Canadian privacy laws. Data stored by the end-user outside of Canada and shared with the Service is not considered to be in the care and control of Jevitty, and is not subject to this Privacy Policy.

It is important that you help protect the privacy of your own information. We strongly recommend that you take precautions to protect the security of any Personal Information that you transmit by using device security features, encryption and other techniques to prevent unauthorized interception of your Personal Information. When you communicate online or by email, you should be aware that sending information over the internet is inherently insecure, as it can be intercepted or manipulated and retransmitted. You are responsible for the security of your information when using unencrypted, public or otherwise unsecured networks.

Accessing, Correcting and Deleting Your Information

We take steps to ensure that your personal information is as accurate, complete and up to date as is necessary for the purposes for which it is to be used. If you are a registered user of Jevitty, you may review and change some of your Personal Information that you have provided to us, by logging into your account and editing your profile. You can also request access, changes or deletions to your Personal Information by contacting us at privacy@jevitty.com. Be advised that we may not be able to delete your Personal Information without also deleting your user account.

If you move, change your phone number, or change your email address, you are required to update your Personal Information with us.

You will not be permitted to examine the Personal Information of any other person or entity without appropriate authorization. Our security procedures mean that we may request proof of identity before we disclose Personal Information to you. We may not accommodate a request to change or delete Personal Information if we believe doing so would violate any law or legal requirement.

Jevitty will retain your information for a period of 25 years in accordance with current laws.  Data on inactive accounts will not be retained after 25 years of inactivity.

Legal Action

Your Personal Information may be used for legal purposes by Jevitty, in Court or in the stages leading to possible legal action arising from improper use of the Service. By using the Service, you declare to be aware that we may be required to reveal Personal Information upon request of public authorities and under applicable laws or legal authority.

Openness and Challenging Compliance

You can write to Jevitty to request access to the Personal Information we have on file for you. We will provide you with the Personal Information we have, subject to certain considerations specified by law.

Jevitty welcomes your comments regarding this Privacy Policy. If you would like more information on this Privacy Policy or Jevitty’s organizational privacy policies, or if believe that Jevitty has not adhered to the terms of this Privacy Policy, please contact Jevitty’s designated Privacy Officer at privacy@jevitty.com. We will use commercially reasonable efforts to promptly identify and remedy any failure by Jevitty to adhere to the terms of this Privacy Policy.

This Privacy Policy was last updated on November 25th, 2021.