INTRODUCTION

Milan Madhavji Dentistry Professional Corporation o/a Canaray (“Company” or “we”) respects your privacy and is committed to protecting it. This policy describes our approach to privacy and how we treat your personal information.

This policy describes:

• The types of information we may collect or that users (“you”) may provide when you download, register with, access, or use the Canaray Mobile Application (the “App”) and/or the Canaray website (the “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 and applicable federal and provincial privacy laws. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

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, do not download, register with, or use the App and/or the Website.

By registering with, or using this App and/or Website, you indicate that you understand, accept, and consent to the practices described in this privacy policy.

This policy may change from time to time . Your continued use of this App and/or Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect information about you through:

• Direct interactions with you when you provide it to us, for example, completing self-attestation forms, responding to questions, or corresponding with us.
• Digital system or imaging results portal, for example, if you choose to register for diagnostic services and results reporting through our digital system, the App and/or the Website.
• Automated technologies or interactions, when you use the App and/or the Website, for example, usage details, IP addresses, and information collected about your location.

We may collect and use the following information about you:

• Your name, birth date, 2D and/or 3D photo(s) that you provide to us or that we acquire at the time of the appointment, email address, as well as personal health information (collectively, “personal information”).
• When you register for diagnostic services, your name, contact information, health provider information, symptoms, health history, and prior radiographs and diagnoses, if any (“personal health information”).
• Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. We may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the demographics of users accessing a specific feature of the App and/or the Website.
• Technical information, including your login information, device type, time zone setting, and usage details.

Information You Provide to Us

When you register with, or use this App and/or Website, we ask you to provide:

• Information by filling in forms on the App and/or the Website. For example, when you use the App and/or the Website you will be asked to complete a medical history and book an appointment time.
• Information about your referring dentist and the reason for your referral. This information is available at all times within the App and Website in order to help you understand the reasons that you have been referred to us, the procedures requested, the pricing of the services, the expected service turnaround times, service rush options, and the insurance claim codes for pre-authorization.
• Information when you report a problem with the App and/or the Website. We use this information to troubleshoot and help correct performance issues.
• Information about your health status and testing results. We will always ask for your consent before we collect, use, or disclose your personal health information.

Automatic Information Collection and Tracking Technologies

When you download, access, and use the App and/or the Website, we may automatically collect:

• Usage details. When you access and use the the App and/or Website, we may automatically collect certain details of your access to and use of the App and/or the Website, including location data, logs, and other communication data.
• Device information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, operating system, browser type, and mobile network information.

The information we collect automatically is statistical information and may include personal information. We may maintain it or associate it with personal information that you provide to us. This usage information helps us to improve our App and/or Website and to deliver a more useful service, including by helping us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences and customize our App and/or Website according to your individual activity or behavior.
• Speed up our services.
• Recognize you when you use the App and/or the Website.

Third-Party Information Collection

When you use the App and/or the Website or its contents, certain third parties may collect information about you or your device. These third parties include:

• Your mobile device manufacturer.
• Your mobile and internet service provider.
• Our push notification service provider.
• Our cloud storage service provider.
• Our analytics and performance diagnostics providers.

We do not control these third parties' tracking technologies or how they use them.

HOW WE USE YOUR INFORMATION

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

• To provide you with the App and/or the Website and its contents.
• To provide you with oral radiology services and communicate results.
• To improve our App and/or Website, products or services, or customer relationships and experiences.
• For any other purpose with your consent.

We will not use the information we have collected from you to display advertisements to you.

In addition to the above, we use personal health information that you provide to us to schedule appointments, to provide oral radiology services to you either directly or through our third party service provider(s) and dentist(s), to provide you and with your consent, your connected referring dentist(s) with diagnostic results, and to comply with legal and professional regulatory reporting obligations.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users that does not identify any individual.

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

• To your referring dentist and associated providers in your circle of care.
• To comply with any court order, law, or legal process, including to satisfy the disclosure requirements of any governmental health agency, respond to any government or regulatory request, in each case according to applicable law.
• To enforce our rights arising from any contracts between you and us, including the App’s and/or the Website’s Terms and Conditions.

TRANSFERRING YOUR PERSONAL INFORMATION

We may process, store, and transfer personal information that we collect or that you provide to us, to service providers (such as cloud storage and push notification providers), and other third parties we use to support the App and/or the Website and as needed to provide services (i.e. data processing partners involved in the creation of our final diagnostic results). We will take commercially reasonable steps to ensure that such service providers and other third parties treat your information confidentially and consistent with the terms of this privacy policy.

We may process, store, and transfer your personal information in and to other countries 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. Whenever we engage a service provider, we will take commercially reasonable steps to ensure that its privacy and security standards comply with this policy and applicable Canadian laws.

We may disclose your information to other third parties in relation to a potential merger, acquisition, or sale of some or all of our assets or business. Your information may be provided to the entities and advisors conducting due diligence on any such transaction. You will be notified in the event any such transaction is completed, at which point your information may be transferred and the successor business may continue to use and disclose the information for the purposes described in this Privacy Policy.

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:

CANADA’S ANTI-SPAM LEGISLATION AND ELECTRONIC COMMUICATIONS

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. 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 electronically 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.

With your consent, we may communicate limited personal health information via email or text in the interest of promoting timely communication. The use of technology may increase the risk of your personal health information being unintentionally disclosed or intercepted by third parties. Technical failures and technological issues may result in a loss of personal health information and/or delay or interruption. We assume no responsibility or liability for any technical failures or technological issues associated with communicating through electronic communications.

DATA SECURITY

The security of your personal information (which for the purpose of this policy includes personal health 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. We store all information you provide to us either directly on your device or with our third-party cloud storage service provider(s). Information stored on your device (iOS or Android) is stored using a minimum AES-256bit encryption and in a secure hardware enclave located on your device. Information that is stored in the cloud is encrypted at rest and in transit and is stored using a minimum AES-256bit encryption on the server.

We only use cloud storage service providers that maintain high industry standards, including globally recognized security and data use & protection certifications.

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 or aggregate 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.

CHILDREN UNDER THE AGE OF 13

Our App and Website are not intended for children under 13 years of age. No one under age 13 may directly provide any personal information to or on the App and/or the Website. If you are under 13, do not use this App and/or Website.

If you are the parent or legal guardian of a child under 13 years of age, and you have been asked to use this App and/or Website by your connected organization (e.g. a daycare, school, or club), then you may use this App and/or Website and provide personal information about your child through your own account.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@canaray.com.

If you are between the ages of 13 and 18 you must fully review this Privacy Policy with your parent or legal guardian prior to using the App and/or the Website.

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. 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 privacy@canaray.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or put the health or safety of others at risk.

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.

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 privacy@canaray.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.

CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. By continuing to use the App and/or the Website you are consenting to the Privacy Policy as of its most recent revision date.

We include the date the privacy policy was last revised at the top or bottom of the policy. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting 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:

Attn: Privacy Officer
Canaray
Email: privacy@canaray.com

If you are not satisfied with our privacy practices, you may bring a complaint to the Office of the Privacy Commissioner or provincial information and privacy commissioner, as applicable.