Privacy Policy

Last modified on: 08-10-2021

INTRODUCTION

Caribou Health Travel Technologies Inc.
and our affiliates and subsidiaries including Caribou Health Technologies Inc. (”Company” or ”We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes how we collect, use, disclose, and protect the personal information of our customers and website users (“you”), describes the types of information we may collect from you or that you may provide when you visit the website caribouwealth.com, getcaribou.com, caribouadvisors.com (our “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

We collect Personal Information as defined by the CCPA, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include de-identified or aggregate information; publicly-available information that is lawfully made available from federal, state, or local government records; and information covered by certain sector-specific privacy laws.

This policy applies to information we collect, use, or disclose about our customers and Website users:

This policy does not apply to information collected by:

This Privacy Policy also does not apply to information collected from visitors who register and log-in ("Members") to the password-protected and secure portions of our Website ("Secure Platforms"). The Secure Platforms allow eligible Members to perform certain transactions and use the Company's services (such as telehealth and expert medical services). All information collected and stored by the Company or added by our Members into such Secure Platforms is considered Protected Health Information ("PHI") and/or medical information and is governed by applicable state and federal laws that apply to that information, for example the Health Insurance Portability and Accountability Act (HIPAA). How the Company uses and discloses such PHI is in accordance with the applicable Notice of Privacy Practices for the associated Secure Platform. For example, if you have consented to importing data from HealthKit into the Secure Platform, you should review our Notice of Privacy Practices to understand how we use and disclose such PHI. The Company will not use or disclose information received from advertising, marketing, or other use-based data mining purposes and will not combine it with other data and will not sell it.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

The information that we collect from our users is used only to facilitate the selection of desired travel destination and medical procedure. We do not sell your information to any third party at any time, and we will only share your information with your permission.

PRIVACY LEGISLATION

International Users
The Sites are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of our Sites may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.

Notice To California Residents
If you are a California resident, certain Personal Information that we collect about you is subject to the California Consumer Privacy Act (CCPA).Please note that the CCPA does not apply to, among other things,

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.

Information You Provide to Us
The information we collect directly from you on or through our Website may include:

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Links to Other Websites
The Website may include links to third-party websites, plug-ins, services, social networks, or applications that are not administered or controlled by the Company. Clicking on those links or enabling those connections may allow the third party to collect or share data about you.

If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Accordingly, we expressly disclaim any responsibility for the content of any other website and for the availability, accuracy, reliability, completeness, currency, quality, performance or suitability of the information, services and products available or advertised on or through third party websites.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page

The information we collect automatically is statistical data and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

The technologies we use for this automatic data collection may include:

Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Website so that you can enjoy free content.

You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

For any other purpose disclosed by us when you provide the information. With your consent. We may also disclose your personal information:

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (including but not limited to third party medical practitioners and service providers, as well as for the benefit of the Company, such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted using SSL technology.

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. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

PERSONS UNDER THE AGE OF 18

Our Website is not intended for persons under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from persons under 18. If you are under 18, do not [use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at info@getcaribou.com to request access to, correct, or delete any personal information that you have provided to us.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at  info@getcaribou.com. Please note that if you withdraw your consent we may not be able to provide you with a particular service. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at :Email:  info@getcaribou.com.

Phone: 1-877-836-1766

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact Mr. Cory Blumenfeld or Ms. Christine Simone using the contact information listed above.