Genetics Adviser Privacy Policy 

This Privacy Policy describes the collection, use and disclosure policies and procedures that govern your information in connection with your interactions with GENETIC ADVISER INC., (“GAI” or “We or “Us”). Such interactions include but are not limited to your use of any applications, websites found and published at https://www.geneticsadviser.com/ and https://www.mygeneticsadviser.com and such other locations on the internet as made available from time to time by us (collectively referred to as the “Website”), and any communication between you and our representatives (unless specifically excluded herein) whether via the Website, facsimile, electronic correspondence, verbally, using telecommunications technology and information technologies such as video conference, telephone and instant messaging (collectively, the “Information Technology”) or in-person (collectively, the “Interactions”). When engaging in any of the Interactions regardless of whether you have requested or received any of the services offered which includes genetic testing education, counselling, consent and result disclosure and management (collectively, the “Genetics Services”), you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you reside in or create information from, your information may be used by us in Canada. The Interactions and Genetics Services are collectively defined herein as the “Services”.

This Privacy Policy is in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), as amended by the Digital Privacy Act (“DPA”), the federal privacy law for private- sector organizations. We will ensure compliance with PIPEDA, as amended by the DPA as well as with the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3, Sched. A, as amended, enacted or replaced from time to time (“PHIPA”), where applicable. In the event of a conflict between any provision of this Privacy Policy and the governing statutes noted above, the governing statutes will govern for such provision.

1. Definitions

“Personal Information” means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address) or information readily available to the public. This includes, but is NOT limited to, fitness progress photos, name, date of birth, contact information, email address, payment information, if applicable, Personal Health Information, and emergency contact information.

“Personal Health Information” is as defined in the PHIPA, which includes but is not limited to identifying information about an individual in oral or recorded form, if the information (a) relates to the individual’s physical or mental health, including their health history of their family or (b) relates to the providing of healthcare to an individual including but not limited to identification of a person as a provider of healthcare to the individual.

2. Collection of Personal Information

Any Interaction may result in our collection of Personal Information. We collect Personal Information directly from you, or indirectly from third party sources as otherwise permitted by applicable law.

a) Third Party Service Providers: When providing our Genetics Services, we may refer you to third party providers such as Zoom and FaceTime or you may find a website or service linked from the Website. You agree that we are not responsible and do not have control over any third

parties that you authorize to access your Personal Information including but not limited to allowing your Personal Information to be transmitted via such provider. You hereby acknowledge that your Personal Information is subject to the third party’s respective privacy policies and we are not responsible for the practices, information and content of their websites and applications. PLEASE ENSURE TO READ THEM CAREFULLY PRIOR TO USE. If you are using a third-party website or service to transmit Personal Information or you allow them to access your Personal Information, you do so at your own risk.

1. b)  Account: When you create an Account on the Website (the “Account”), you provide some Personal Information such as your name, contact information, phone number, email address, medical history, progress photos, and information related to the Genetic Services. We will provide you with tools to modify and update some of such information via your Account. Accounts are restricted to persons of the age of 18 years and older.

2. c)  Log Data: Our servers automatically record information (“Log Data”) related to your actions on the Website. Log Data may include information such as your IP address, browser type, internet service provider, date/time stamps, the referring domain, pages visited, products viewed and search terms. Other actions, such as interactions with the Website may be also included in Log Data. Log Data may also be recorded by third party websites.

3. d)  Links: The Website may keep track of how you interact with links by redirecting clicks or through other means. We do this to help improve our Services, and to be able to share aggregate click statistics such as how many times a particular link was clicked on. The Website may also use tracking technologies such as web beacons, tags and pixels to record information about how you browse the Website.

4. e)  Cookies: Like many websites, we use “cookie” technology to collect additional Website usage data and to improve our Services, but we do not require cookies for many parts of the Website. A cookie is a small data file that is transferred to your computer’s hard disk. The Website may use both session cookies and persistent cookies to better understand how you interact with our Website, to monitor aggregate usage by our users and web traffic routing, and to improve our Services. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, keep in mind that this may disrupt the Services being provided to you.

5. f)  Device Identifiers: When you use a mobile device like a tablet or cell phone to access our Website, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to your device.

6. g)  Text and Email: You may decide to send us Personal Information in an email or text message which may lead to further discussions that create modify or add to such Personal Information.

7. h)  Website Analytical Services: We use a variety of services hosted by third parties to help provide

   our Services, and to help us understand the use of our Website, such as Google Analytics. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request.

8. i)  Personal Information generated during Interactions: We may, create or compile information such as notes and progress photos in relation to any Interaction with you (collectively the “Notes”). While providing you with the requested Genetics Services which may involve the use of Information Technology, we may also collect additional Personal Information about you. We will have access to all Personal Information on your Account and any that you transmitted during any Interaction. Such Personal Information may include but is not limited to: details you provided during the Interactions, documents you upload to your Account, information you/we entered on your Account, Notes created by us and added to your Account, and emergency contact information

(please note that you are responsible for notifying your emergency contact that you are providing their information to GAI and for obtaining their consent). We may also print copies of your Personal Information as necessary to provide the requested Genetics Services and to comply with applicable laws.

3. How We Use Your Information

In addition to some of the specific uses of Personal Information we describe in this Privacy Policy, we may use such information or share such information to:

1. a)  confirm your eligibility to use the Website, create an Account for you, authenticate you when you log onto the Website and personalize your experience on the Website.

2. b)  determine your eligibility for any requested Genetics Services;

3. c)  disclose the Personal Information to third parties to the extent necessary to facilitate the requested

   Genetics Services such as for facilitating laboratory analysis;

4. d)  help you efficiently access your Personal Information after you sign in to your Account;

5. e)  remember information so you will not have to re-enter it during your visit or the next time you visit

   the Website;

6. f)  establish, maintain and manage client relations with you so that we may provide you with the

   requested Services;

7. g)  provide personalized content and information to you and others, which could include online ads or

   other forms of marketing (you can choose not to receive any electronic marketing communications from us by clicking the Unsubscribe” function contained in all of our electronic communications or by emailing info@letsplanu.ca

8. h)  Provide, improve, test, and monitor the effectiveness of the Website;

9. i)  receive your feedback and provide ongoing customer service to you;

10. j)  develop and test new products or services and features and improve our level of service;

11. k)  provide information about the Website including updates and notifications;

12. l)  monitor metrics such as total number of visitors, users, traffic, and demographic patterns;

13. m)  process payments for the Genetics Services;

14. n)  diagnose or fix technology problems;

15. o)  meet legal and regulatory requirements; and

16. p)  such other purposes consistent with these objectives and as may be permitted or required by

    applicable law.

Information about you and your use of the Services may be aggregated with other information in ways that do not personally identify you (the “Aggregated Information”) or constitute Personal Information. This type of aggregated or statistical information may be used by us to improve the quality of the Services or for other purposes that we may deem appropriate.

4. Information Sharing and Disclosure

Our use of Personal Information is limited to the purposes described in this Privacy Policy and we do not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information that we have obtained. We will not share your Personal Information with any third party except we may disclose your Private Information in the limited circumstances described herein.

a) Your Consent: We may share or disclose your information with your consent. Consent can be either express (verbally, in writing or electronically) or implied, where permitted under applicable law. In determining the appropriate form of consent, we will consider the sensitivity of the information. When you provide your Personal Information voluntarily on the Website or during an Interaction with GAI,

you imply that you have consented to the collection, use and disclosure of such information. You may change or withdraw your/their consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us at Info@geneticsadviser.com. Please note that in some circumstances, a change in or withdrawal of consent may severely limit our ability to provide the requested services.

1. b)  Without Consent: Please note that there are circumstances where the use and/or disclosure of your Personal Information may be justified or permitted or where we are obliged to disclose information WITHOUT consent. Such circumstances are consistent with PIPEDA and the DPA and may include, but are not limited to the following: if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property.

2. c)  Non-Personal Information: We may share or disclose Aggregated Information derived from your information or your non-Personal Information.

3. d)  Service Providers: We may share Personal Information with your emergency contacts, our employees, contractors and business partners and medical laboratories to the extent required for them to provide the Services you have requested or for the purposes described in this Privacy Policy. We engage certain trusted third parties to perform functions and provide services to us such as website hosting companies, payment processing companies and other third-party service providers. We may share Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to obligations mirroring the protections of this Privacy Policy.

4. e)  Business Transfers: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be disclosed or transferred as part of that transaction. The promises and exceptions in this Privacy Policy will apply to your Personal Information as transferred to the new entity with the same exceptions herein.

5. f)  Governmental: We may share Personal Information with government agencies and law enforcement officials, when required to do so to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.

6. g)  Payor of Genetics Services: If you authorize a third party to pay the fees for your Genetics Services, you: (i) consent to us using the email address provided to us by the third party to communicate with you regarding the Website and Genetics Services; (ii) disclosing the specifics of your requested Genetics Services to the third party to the extent necessary to permit GAI to process payment for such services; and (iii) notifying the third party of any changes or termination of your access to your Account.

5. Accessing, Modifying and Disposing of Personal Information
Non-Account Personal Information: We endeavour to ensure that your Personal Information is accurate, current and complete as possible to fulfill the purposes for which the information has been collected, used, retained and disclosed. For any Personal Information you are not able to view or modify on your Account (the “Non-Account Personal Information”), you may email us at Info@geneticsadviser.com to request access to review, challenge the accuracy of or request deletion of the Non-Account Personal Information held by us and to request corrections and we will respond within a reasonable time. To guard against fraudulent requests, we may require sufficient information to allow us to confirm that the person making

the request is authorized to do so before granting access or modifying any Non-Account Personal Information. We may also deny your request if permitted or required by law and if so, provide you with the reasons for the denial.

If you successfully demonstrate the inaccuracy or incompleteness of any of the Non-Account Personal Information, we will amend or delete such information as required. If we do not agree on the resolution to your satisfaction, we will document the substance of the unresolved challenge.

Where appropriate, we will transmit the amended information or the existence of the unresolved challenge, as the case may be, to third parties having access to the information in question so that they may modify their records accordingly. We are however, not responsible nor liable for the failure of such third parties to update their records.

Protection of Personal Information and Disclaimer

We endeavor to maintain appropriate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to the disposal or destruction of Personal Information. We further protect your Personal Information and any financial or payment information by restricting its access to those employees and contractors who need to have knowledge of that information in order for us to provide our Services, as determined by our management. While we continue to work hard to protect your Personal Information, no data transmission over the internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any information you transmit to us via the Website or otherwise; any transmission is at your own risk.

6. Information Retention
Account Personal Information: We will retain the Personal Information in your Account on your behalf for as long as your Account exists subject to legal requirements and our notice to you.

If you would like your Account and your Personal Information within deleted, please contact us at Info@geneticsadviser.com and we will let you know the procedure once your Account is terminated and you have had the opportunity to print or make copies of your Personal Information, and, subject to any retention requests as required by law, GAI will destroy the Personal Information associated with your Account.

7. Changes to this Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of Personal Information and will be located on this page unless we notify you otherwise. If we make a change to this policy that, in our sole discretion, is material, we will notify you via email if known. Please check this page periodically for updates. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. Contact Us

If you have any questions, concerns, complains, requests or comments regarding your Personal Information or our Privacy Policy, please contact us at Info@geneticsadviser.com.

Last Updated: Dev 19th, 2023