Privacy Policy

Effective Date: January 26, 2022 Last modified: January 23 rd 2023

Introduction.

This Privacy Policy describes Eleu Health Technology Inc.’s practices (the “Company”, “Eleu Health,” “we”, “us” or “our”) regarding the collection, use, and disclosure of “your” personal information.

Personal information is any information about an individual that can be identified directly or indirectly. It is information about you. At Eleu Health we believe that individuals should have control over their personal information and with whom and how information about your health is shared. We comply with applicable privacy laws and data security standards and this Policy whenever we collect, use, or disclose and protect your information. We will only handle your information with your consent and as described in this Policy, or as permitted or required by law. By providing us with your information and agreeing to this Privacy Policy, you acknowledge and agree that have read and understand this Policy and the information collection, use, and disclosure practices described herein. If you do not agree with our Policy, please do not provide us with your information. This Privacy Policy covers personal information that we collect from individuals through the registration or use of our software application (the “App”) or our website (the ”Website”) (collectively, our “Services” or “Eleu”) or in other interactions with you. If you have questions or complaints regarding our Privacy Policy or these practices, please contact our privacy officer whose contacts details are in the ‘Contact Information’ section below. PLEASE NOTE: Eleu Health does not provide any medical advice or counselling services via the App, Services or otherwise. Our Services provide you with an easy way to store and control medical and other information as well as providing you with tools to monitor and track your well- being. We may also recommend some tools and exercises to help decrease stress levels and improve your feeling of well-being, but please note that the information presented on the App is educational in nature. The content has not been created nor is it being delivered by healthcare professionals. It is not medical or psychological advice nor should it be viewed as treatment for a medical or psychological ailment, and it should never be used as a substitute for seeking advice or treatment from a healthcare professional.

How we collect information.

We collect personal information in a number of ways:

Directly from you when you provide it to us during registration or during the use of the App.
Automatically when you use the App, which may or may not be personal information. You can change the settings for some aspects of the automatic collection, but this may affect the delivery of the Services in some cases. We will only collect as much information as is reasonably necessary to meet the purposes for which it was collected.

When you upload your health records, health information or wellness-related records, we collect, store and process it on your behalf and solely in accordance with your instructions, or as is required by law. We do not collect, use, or disclose this information for any other purposes. We may de-identify data for the purpose of conducting analytics and internal research on the aggregate data. No identifiable data will be shared with any third-parties.

When you download and register for the App we will ask you to provide your first name, last name, and email address. We will also collect your age and birthdate, gender, country, and address.

You will also be asked to create a password to access your account. All billing information will be collected and processed by our third-party payment processor, Stripe. We do not collect or have access to your billing or credit card information. When you use the App, you may choose to provide us with additional information about your health or well-being. This may include health records or test results you receive from your healthcare provider or other healthcare professionals, and it may include subjective and objective information about your health, health habits, or feelings of well-being. You control this information (your “Vitals”).

You may also choose to upload your Vitals directly or connect other software applications (“third-party apps”) to Eleu. Please note that we do not control the privacy practices of third- party apps. Please make sure you understand and agree with the privacy policies of all third- party apps you connect to Eleu.

We use your Vitals to generate information related to how the information you provide to us is inter-connected or changes over time (“User Analysis”). This User Analysis is personal information that will be treated in accordance with this Policy.

Each User Analysis is specific to you. We collect information based on either manual inputs or automated inputs, such as wearable devices, and other apps you currently use to collect this data). You can choose what type of information and how much information you provide for us to develop the User Analysis.

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Information Collected Automatically.

When you download, access, and use the App or access our Website, we will use technology to automatically collect:

Usage Details. When you access and use Eleu, we may automatically collect certain details of your access to and use of Eleu, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through our Services.
Device Information. We collect information about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

When you use the Website or the App, the following additional information will be collected automatically:

We use so-called “cookies,” web beacons, and other similar tracking technologies, including from third-party partners such as Google, to be able to better target advertisements and for marketing purposes.
These technologies allow us the ability to display our promotional material to you when you visit external sites. We may share information related to your access and engagement on our Website with certain third parties (including third-party websites or social networking platforms) for the purposes of providing you with better-targeted advertisements. We will never share any of the information used to provide you with the User Analysis.

Children.

We do not knowingly collect information of children under the age of thirteen (13) unless the parent/guardian subscribes to the pediatric module of our Services and consents to our collection and use of their child’s personal information. Minors under the age of eighteen (18) may only download the App with parental consent and with the parent or legal guardian assuming all risk on behalf of the minor. If you are a minor and do not have your parent or legal guardian’s consent, you may not download the App or use any of the Services. HOW WE USE YOUR INFORMATION We use your personal information:

To provide you with Eleu and its contents, and any other information, products or services that you request from us.
To administer our commercial relationship with you.
We use some of the information you provide and the Outputs to recommend certain tools and techniques that you may find helpful to improving your well-being.
When you provide us with information about your health or well-being, we may generate Outputs for you that you can use to track those parameters over time and to monitor how certain factors are interrelated or connected.
We store your health records that you upload for your convenience of access and control. We do not use your health records for any other purpose other than those outlined herein or as directed by you.
To run analytics (we provide your IP address to Plausible Analytics; when we obtain the reports, we only receive aggregated information, which is not linked to any users of the App).
If you choose to opt into our mailing list, we may send you, from time to time, promotional information we think will be of interest to you. You will have the opportunity to opt out of those communications at any time following the instructions in the communication or by contacting us indicating your wishes unsubscribe@eleuhealth.com ; désabonner@eleusante.com.

The usage and device information we automatically collect helps us to improve our Services and to deliver a better experience by enabling us to:

Estimate our audience size and usage patterns.
Recognize when Eleu is used and which features are accessed. We collect this information on an aggregated basis only and will not be linked with your personal information.

Sharing your information.

We will not sell or give your information to any third party. We will only share or disclose your information as follows:

To contractors, service providers, third-party processors, and other third parties we use to deliver the Services.
We will not share any personal information with your healthcare providers; however, you are able to create reports (for any Outputs or other personal information) and share them via the tool with healthcare providers or other individuals or entities of your choosing. You have control over this information.
If you opt-in to our Emergency Contact offering, you may permit one (1) Emergency Contact to have access to your information, including your Vitals, which means that Eleu will share all information you have provided to us with that individual. You have full control over this feature and can opt-out or change your Emergency Contact at any time.
To a purchaser in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Eleu Health’s assets.
As may be required by law or as legitimately requested by law enforcement or pursuant to a legal obligation, in which case we will use reasonable efforts to provide notice to you.

If you are using the App as part of an employer program, we will never share any of your personal information, either directly or indirectly, with your employer. We may provide non- identifiable aggregated data of company-wide use of the App as well as aggregated outputs based on the information provided on a company level but this information will never be capable of identifying you or being linked with your personal information. ACCESSING, CORRECTING, AND DELETING YOUR PERSONAL INFORMATION You may send us an email at support@eleuhealth.com to request access to, correct, or delete any personal information that you have provided to us. You control your health records and can add or delete at any time. We will accommodate your request within a reasonable time. Depending on the nature of the request, it may mean that you will no longer be able to use our Services. If you delete the App, we may retain certain information, in accordance with applicable law and the provisions of this Privacy Policy.

Data Retention.

We will retain information collected via the App for as long as we are providing Services to you with respect to such information. We will retain information for as long as it may be required under applicable laws and regulations. We will delete information when it is no longer required or within six (6) months after you no longer use the Services. If you wish for us to retain your information for longer, please contact us. We will send you a reminder 90 days prior to deletion; if we do not receive written notice that you wish to resume the Services we will delete your information, subject to the provisions in this section, without further notice to you.

International data transfers.

Eleu Health is located in Quebec, Canada. While we have employees and service providers located in other countries, but we will not transfer for storage any personal information outside of Canada. ANTI-SPAM Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. This consent is sought by Eleu Health and you can contact us at support@eleuhealth.com, support@eleusante.com. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message. Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

Changed to our privacy policy.

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will alert you to those changes.

Questions and contacting us.

If you have any questions regarding our use of your personal information or this Policy, you can contact our Privacy Officer at privacy@eleuhealth.com , confidentialité@eleusante.com. You are also entitled to contact the Office of the Privacy Commissioner of Canada toll-free: 1- 800-282-1376 if you wish to file a complaint about our privacy practices.