Maple Corporation Privacy Policy
    Introduction
    Maple Corporation ("Maple", "we", "us") offers two kinds of services: Healthcare Services and optional
        Wellness Services. When you register with Maple as a User, you become eligible to use our Healthcare
        Services. You also become eligible to sign up separately for one or more of our Wellness Services, should you wish
        to. 
    Please read this Privacy Policy carefully. It describes how Maple will collect, use, store, disclose, and protect
        your information in relation to our Healthcare Services and our Wellness Services.
    
        Definitions
    
    The following provides the meaning of certain terms used in this Policy. If not defined below, the capitalized words
        and phrases in this Policy have the same meaning as in Maple's Terms of Use. "Maple Platform" means,
        collectively, the hardware, software, applications, websites, Content, products and services owned and/or operated
        by us to enable the provision of remote Healthcare Services to Users, among other purposes. "Information"
        means, collectively, "Personal Information" (information about an identifiable User as further defined in
        Applicable Law) and "Personal Health Information" or "PHI" (information about an identifiable User's
        health or healthcare as further defined in Applicable Law). A "User" is an individual registered to use the
        Maple Platform, including, unless otherwise specified, as part of a customized program provided by a third party. A
        "PCH User" is a User also registered to use Loblaw's PC Health application. Unless we make a distinction,
        "Users" means all Users. Health professionals ("Authorized Providers") are, collectively,
        "Authorized Physicians" (physicians registered to practice medicine in a province or territory of Canada) and
        "Authorized Non-Physician Providers" (regulated health professionals other than physicians registered to
        practice in a province or territory of Canada) who are registered to use the Maple Platform to provide
        "Healthcare Services" within their scope of practice to Users. An Authorized Provider provides Healthcare
        Services through a "Consultation," which includes a review by the Authorized Provider to determine if the
        Healthcare Services requested by the Users are ones that can be provided on the Maple Platform. "Applicable
            Law," in relation to Maple, Authorized Providers, or Users, means the laws and regulations, including
        privacy laws and regulations, to which each is subject. "Content" means general information about
        health-related topics posted on the Maple Platform, access to which is not the delivery of Healthcare Services and
        does not replace and cannot be relied upon as Healthcare Services.
    
        Your Agreement with Maple
    
    If you are an Authorized Provider, your arrangement with Maple - your rights and obligations and those of Maple - is
        set out in the agreement between you and Maple or, if you are providing Healthcare Services on behalf of a third
        party organization that has contracted with Maple, in the agreement between you and the third party organization
        with which you are associated. If you are a User, the arrangement between you and Maple - your rights and
        obligations and those of Maple - is set out in the Terms of Use and, where applicable, supplementary Terms. The
        Terms of Use for PCH Users may differ from those for other Users to take into account supplementary Terms for use of
        the PC Health application.
    
        Application of this Policy
    
    This Policy describes Maple's management of Information, including the purposes for which we collect, use and
        disclose Information and the safeguards we use to protect Information. This Policy does not apply to the
            collection, use, retention, disposal, destruction, or protection of Information by Authorized Providers through
            the Maple Platform. The Authorized Providers who provide care to Users through the Maple Platform are
        responsible at law for the Information that they collect, use, disclose, and store via the Maple Platform. Please
        direct any questions you may have about how an Authorized Provider will treat your Information to the Authorized
        Provider.
    
        The Maple Platform and How Maple Collects and Uses Information
    
    The following is an overview of how the Maple Platform generally functions and how Maple collects and uses
        Information. The details of how the Maple Platform functions may vary by Consultation and Authorized Provider.
    Healthcare Services 
    Authorized Providers collect Information about you (or any Registered Dependent, as defined below) that you provide
        before or during a Consultation. They may collect this Information in different ways, including through discussions
        with you during the Consultation, via text messages with you before the Consultation, or when you enter or upload
        Information to the Maple Platform before the Consultation. Authorized Providers also have access to other
        Information about you through the Maple Platform. This includes Information that you provide in your consultation
        request; Information you've entered or uploaded to profiles and medical records; Information created during your
        earlier interactions through the Maple Platform with other Authorized Providers; the name, email address, phone
        number, gender identity, date of birth and province/territory that you provided when you registered with Maple; and
        your emergency contact's name and contact information (if you have chosen to add an emergency contact to your
        account). Authorized Providers use this Information to provide you with Healthcare Services. As noted above, they
        must comply with the privacy legislation and medical record-keeping obligations to which they are subject.
        Authorized Providers may create Information in the Maple Platform, such as prescriptions, sick notes, and notes
        about your Consultation. They may export or print copies of your Information. Authorized Providers may, but are not
        required to, email or text your emergency contact if they believe that you are presenting with a healthcare
        emergency. You are responsible for advising your emergency contact that you are providing their name and contact
        information to Maple and Authorized Providers, and for obtaining any necessary consent from your emergency contact
        for the provision and use of that information in connection with the Maple Platform.
    Wellness Services
    You have the option to sign up to receive Wellness Services from Maple, such as our Recommendations service, which
        sends you preventative health recommendations based on your health profile. If you sign up to receive one or more of
        our Wellness Services, you will be invited to provide Information about yourself (or any Registered Dependent) as
        part of your Maple Health Profile. This may include, for example, Information about your health and wellness
        interests, your demographic data, and your health history. Maple will collect this Information and use it to provide
        you with any Wellness Services for which you sign up. The data created through your use of our Wellness Services is
        used to further enhance and tailor your experience by suggesting similar Wellness Services to you that you may be
        interested in. For example, if a User who chooses to receive a Wellness Service related to dermatology, we may
        recommend other dermatology-related Wellness Services to them.
    Other Services
    Maple provides services that support the provision of Healthcare Services. These services may include receiving,
        reviewing, and scanning or otherwise uploading laboratory test results to the Maple Platform; faxing prescriptions
        to pharmacies; obtaining referrals for consultations with specialists; and collecting Information required for
        scheduled appointments (such as health card numbers or information from referral letters). Maple provides some of
        these services to Authorized Providers (for example, the receipt and preliminary review of laboratory results) and
        some to Users (for example, faxing prescriptions and arranging referral to specialists). These services require the
        use of Information.Maple may also provide services through the Maple Platform that are healthcare-related but not
        Healthcare Services (such as navigational services to assist you to access Healthcare Services on the Maple
        Platform). Unless otherwise advised, Maple Personnel will deliver these services. Maple Personnel receive privacy
        and security training and commit to complying with Maple's obligations in connection with Information, as described
        below in the section on Safeguarding Information.
    Other Collections and Uses of Information
    Maple uses Information to the extent necessary to develop, evaluate, improve, provide, and support the Maple Platform
        and its various services. We may also use Information for loss prevention, to prevent fraud, and to comply with
        legal requirements. We do not collect or use Information if non-identifying information will suffice. We do not
        record the audio or video portions of Consultations. For more information about how Maple collects and Uses
        Information when you create your Maple account, use our Healthcare Services, and use our Wellness Services, please
        see the section of this policy entitled "More information on how we collect and use your information".
    Third party service providers
    Maple uses third party software and service providers for a variety of services, such technical, operational, and
        marketing services. For example, our live User support chat (through which Users may get troubleshooting and related
        technical assistance) is provided through a third party service provider. We require our third party service
        providers to limit their use of Information to what is necessary for their services. We also require them to have
        security measures in place that are appropriate for the protection of Information. Some of our service providers
        operate from outside of Canada, which means that Information they use to provide their services to us will be
        subject to the laws of other jurisdictions and may be available to foreign government authorities under lawful
        orders and laws applicable in those jurisdictions.For additional details about Maple's third party service
        providers, please see https://www.getmaple.ca/subprocessors/.
    
    Third party payers
    As described in the Maple Platform Terms of Use, by authorizing someone else (a "Third Party Payer") to pay
        the Fees and/or Membership Fees for your Healthcare Services or Wellness Services, you are representing to Maple,
        and Maple will rely on your representation, that you consent to Maple:
    
        -  using the email address provided to us by the Third Party Payer to communicate with you regarding the Maple
            Platform and Healthcare Services or Wellness Services;
 
        -  disclosing to the Third Party Payer that you have requested Healthcare Services or Wellness Services, to permit
            Maple to process payment for the Healthcare Services or Wellness Services; and
 
        -  notifying the Third Party Payer of any changes to or termination of your access to the Maple Platform.
 
    
    If you have questions about the Information shared between us and Third Party Payers, please contact us as indicated
        below.
    
        Maple's disclosure of Information
    
    Emergency contacts.
    
We may disclose Information to emergency contacts as described above.
    Third parties, on consent.
    We may disclose Information to third parties with User consent. For instance, we may disclose Information to the
        extent needed to an insurer or other Third Party Payer for the purpose of facilitating payments and benefits plans.
    
    Compliance, Fraud Prevention.
    
We disclose Information to the extent required to comply with Applicable Law, including to respond to a subpoena,
        order, or similar obligation to produce information; and to establish or exercise Maple's legal rights, including to
        defend against legal claims and to detect, investigate, suppress, prevent or take action regarding illegal or
        prohibited activities, such as suspected fraud and threats to the reputation or safety of any person.
    Business transactions.
    
We may disclose Information for the purposes of conducting required due diligence or the completion of a business
        transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements,
        including agreements and notice requirements that apply to the disclosure of Information for such transactions.
    
        Maple's retention/deletion of Information
    
    Unless we notify you otherwise, we will retain your Information on the Maple Platform until you (or Maple) close your
        Account. On termination, for a limited time, you will be able to print or copy your Information held in the Maple
        Platform, except for any private notes of Authorized Providers. Any request for access to an Authorized Provider's
        notes should be made directly to the Authorized Provider outside of the Maple Platform. If you are having trouble
        finding the provider you consulted with, our Customer Support team may be able to help. Please contact us directly
        at support@getmaple.ca. After the time period during which you may print or copy your Information has ended, we will
        securely delete the Information associated with your Account, except for any Information that Maple is required to
        retain under Applicable Law or Information required by an Authorized Provider in connection with Healthcare
        Services. Maple will delete the latter once the Authorized Provider makes a copy of the Information or terminates
        their account with Maple. When Information is deleted, it is removed from our active database. Any Information that
        remains in our backup is securely stored and isolated from any further processing until deletion is possible.
    
        Accessing and correcting Information
    
    You can access your Information or that of your Registered Dependents by logging in to your Account at
        https://app.getmaple.ca/login. You may update or otherwise correct your Information at any time, except Information
        that an Authorized Provider has viewed or created. Any request to update or correct Information that an Authorized
        Provider has viewed or created should be made directly to the Authorized Provider outside of the Maple Platform.
    
        Privacy Settings
    
    The Maple Platform enables you to make choices to enhance the protection of your privacy. For example:
    
        - You may enable two-factor authentication on your Account to help prevent unauthorized access. If
            you enable two-factor authentication, then to log into your Account, in addition to entering your password, you
            will have to enter a code that we send separately to your mobile number. This added security means that a third
            party would need both your login information and your mobile phone to access your Account.
 
        - You have the option of using audio, chat, or video for your Consultations.
 
        - When requesting a Consultation, you may choose to withhold Information, for example Information
            contained in your healthcare records, from the Authorized Provider. Please be aware that Authorized Providers
            may be unable to provide you with Healthcare Services as a result. They will advise you of the implications of
            your choice.
 
        - You may choose whether to receive communications from Maple by email or SMS.
 
        - You can check your login history when you access the Maple Platform.
 
    
Please contact us directly at support@getmaple.ca if you require assistance with these options or more generally
    have questions about how to use the Maple Platform. To protect your privacy, we may request information to verify your
    identity when you contact us.
    
        Safeguarding Information
    
    We permit Maple personnel ("Personnel," which includes our employees, contractors and subcontractors) to access
        Information only to the extent necessary to perform their designated functions. We require Personnel to complete
        privacy and security training and to commit to protecting Information by complying with our policies, procedures and
        Applicable Law.We store your information in electronic format within Canada, using computer systems with restricted
        access and that are housed in facilities using physical security measures.More generally, we have in place
        appropriate physical, technological, and organizational safeguards, including access controls, to protect
        Information against loss, theft, and unauthorized access, use and disclosure. Notwithstanding the safeguards we
        employ and our commitment to protecting Information, we cannot guarantee the security or error-free transmission or
        storage of Information. There are risks inherent in the use of electronic means to transmit and hold information in
        electronic format. These risks can be minimized but not eliminated by the use of appropriate security measures, such
        as the measures Maple employs. These risks include interception, loss, corruption, unauthorized access to, use and
        disclosure of Information, and delay in the availability of Information.You play an important role in protecting and
        the privacy of your Information. We ask you to do the following.
    
        - Create a strong and unique password for your Account using Maple's password strength estimator and
            update your password periodically.
 
        - Do not share your Account or password with anyone. We will never ask you for your password,
            including in any unsolicited communication such as letters, phone calls or email messages, so please do not
            provide it and contact us if you receive such a request.
 
        - Log out of your Account as soon as you finish using it, especially if you share the device you use
            to access the Maple Platform with anyone else.
 
        - Password-protect your device with a strong and unique password.
 
        - Choose a quiet, private location from which to receive Healthcare Services.
 
    
    
        Maple's collection and use of non-identifiable Data
    
    Maple obtains the authorization of Authorized Providers to collect and use non-identifiable data about their use of
        the Maple Platform ("Data"). This may include, for example, non-identifiable information about the number of
        consults carried out by Authorized Providers on the Maple Platform or the symptoms most commonly treated by
        Authorized Providers using the Maple Platform. Maple may use Data to monitor the compliance of Users and Authorized
        Providers with the Maple Platform terms of use, to make the use of the Maple Platform more accessible and enhance
        the Maple Platform experience for Users and Authorized Providers, and to design optional surveys for Users. We may
        also use or disclose Data for internal product development purposes or for duly approved research projects. We will
        not use Data to re-identify Users or for any other purpose prohibited by Applicable Law. 
    
        Cookies and similar technologies
    
    The Maple Platform and Maple's email messages and marketing materials use "cookies" and other technologies such as
        pixel tags and web beacons. We use these technologies to better understand the use of the Maple Platform, analyze
        trends, and administer, personalize and improve the Maple Platform user experience for Users and Authorized
        Providers. For more information about our use of cookies and your ability to accept or decline our use of cookies,
        please refer to our Cookie Policy, posted at https://www.getmaple.ca/cookie-policy/. 
    
        Links to third party websites
    
    The Maple Platform may contain links to websites that we do not own or operate. The provision of these links is not
        an endorsement of or referral to the linked websites. We provide the links solely for your convenience. We strongly
        encourage you to review the privacy policies and terms of use applicable to any website you visit. This Policy does
        not apply to linked sites or pages and we are not responsible for the content or privacy practices applicable to
        them or used by their operators.
    
        Amendments to this Policy
    
    Maple last updated this Privacy Policy ("Policy") on March 3, 2025. We post the current version of the Policy at
        www.getmaple.ca/privacy. We reserve the right to amend the Policy at any time to account for changes in Applicable
        Law, our practices and the Maple Platform. Please check to see if we have amended the Policy since you last used the
        Maple Platform to ensure you are aware of (and agree to) our current privacy practices.
    
        Contact Us
    
    If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance
        Officer. Please include your name and contact information if you would like us to respond to you.Maple
        CorporationATTN: Roxana Zaman - Chief Compliance Officerprivacy@getmaple.ca(888)-886-4724201-225 Richmond Street
        WestToronto, OntarioM5V 1W2
    
        More information on how we collect and use your information
    
    The following table gives you more information on how and for what purposes Maple collects and uses Information when
        Users create their Maple accounts, use Maple's Healthcare Services, or use Maple's Wellness Services.
    
When you create your Maple Account:
    
        
            
- First and Last Name
 
            - Maple will collect, use, and store your first and last name to create your Maple account, personalize your
                experience within the Maple Platform, contact you via email, and provide you with personalized customer
                support. Maple may also provide your first and last name to a Third Party Payer if applicable (see below).
            
 
        
        
            
- Email Address
 
            - Maple will collect, use, and store your email address to create your Maple account and authenticate you
                during future visits. We use your email address to send you service announcements, including information
                about our latest products and updates to our policies, Terms of Use and software ("Essential
                Communications"). We use your email address to send you newsletters or information about upcoming events
                that we believe may be of interest or apply to you ("Non-Essential Communications"). You may opt-out of
                receiving Non-Essential Communications at any time by logging into your User Account and updating your
                preferences. We use your email address to contact you via email and provide you with personalized customer
                support. We may also provide your email address to a Third Party Payer if applicable (see below).
 
        
        
            
- Date of Birth
 
            - Maple will collect, use, and store your date of birth to confirm your eligibility to use the Maple Platform.
            
 
        
        
            
- Province of Residence
 
            - Maple will collect, use, and store your province or territory of residence to confirm your eligibility to
                use the Maple Platform.
 
        
        
            
- Phone Number
 
            - Maple will collect, use, and store your phone number to create your Maple account and contact you via SMS.
            
 
        
        
            - Technical Information
 
            - 
                
Maple will collect, use, and store technical information for security purposes, such as monitoring for
                    malicious activity, displaying recent login activity in your account settings, improving the Maple
                    Platform, and understanding and enhancing the user experience on the Maple Platform.
                This includes:
                
                    - IP address
 
                    - Device information
 
                    - Browser information
 
                    - Click IDs
 
                
             
         
    
    Healthcare Services
    
        
            
- Sex Assigned at Birth
 
            - Maple will collect and store your sex assigned at birth on behalf of your Authorized Providers, who require
                this Information to provide you with Healthcare Services.
 
        
        
            
- Gender Identity
 
            - If you choose to provide your gender identity, Maple will collect and store this information on behalf of
                your Authorized Providers, who will use this Information to provide you with Healthcare Services.
 
        
        
            
- Provincial Health Number
 
            - If you receive Healthcare Services that are insured by your provincial health plan, Maple will collect and
                store your provincial health number on behalf of your Authorized Providers, and disclose the number to your
                provincial health plan for the purpose of billing for insured services on behalf of your Authorized
                Providers.
 
        
        
            
- Health Profile
 
            - If you choose to fill out your Maple Profile, you will provide, and Maple will collect and store on behalf
                of your Authorized Providers, Information such as your height, weight, allergies, or medical records (these
                could be records that you create or that are created by your Authorized Providers). Your Authorized
                Providers will use this information to provide you with Healthcare Services.
 
        
        
            - Requests for Healthcare Services
 
            - 
                
When you submit a request for Healthcare Services, we pass along some of the Information you provide in
                    your request to your Authorized Provider, to enable them to determine whether your request is for
                    Healthcare Services that they can deliver through the Maple Platform. The Information we pass along may
                    include the reason for your request for Healthcare Services (such as your symptoms, a brief history
                    obtained via chat, or your need for a prescription renewal or sick note), your age, your gender identity
                    (should you choose to provide it), and, in some cases, your name).
                If the Authorized Provider confirms that your request is eligible, we identify the Authorized Provider to
                    you and send the Authorized Provider the Information in your request, your name, and, where applicable,
                    the name of your Registered Dependent. Unless you have elected to withhold access to Information held in
                    the Maple Platform about you (or your Registered Dependent), the Authorized Provider will also be able
                    to view that Information, such as clinical records created during your previous Consultations and
                    medical records you create.
                If, based on the Information provided, the reviewing Authorized Provider believes that you need emergency
                    services, Maple reserves the right to use any of the contact information you have provided to contact
                    you or your emergency contact, to inform you that an Authorized Provider has viewed and declined your
                    request for a Consultation because your symptoms suggest you are experiencing a healthcare emergency.
                
                This includes:
                
                    - The reason for the request, such as your symptoms, or your need for a prescription renewal or sick
                        note
 
                    - Your age, sex assigned at birth, and gender identity (if you have added your gender identity to your
                        Maple account)
 
                
                And may include:
                
                    - Your name
 
                    - The name, age, sex assigned at birth, and gender of your Registered Dependent
 
                
             
         
        
            - Medical Records Created by Authorized Providers
 
            - 
                
If you receive Healthcare Services, we will store the records created during your Consultation so you and
                    your Authorized Providers can access them in the future as needed.
                At your request, we will use this information to support your Healthcare Services, such as by faxing a
                    prescription to a pharmacy. Depending on your request, this may require Maple to disclose the medical
                    records to a third-party.
             
         
        
            - Personal information of Registered Dependents
 
            - 
                
If you choose to have a Registered Dependent on your Maple account, Maple will collect and store the
                    Information of your Registered Dependents to confirm your eligibility to obtain Healthcare Services for
                    your Registered Dependents, and their eligibility to receive Healthcare Services.
                Authorized Providers will also use this Information for the purpose of providing the Registered Dependent
                    with Healthcare Services.
                This includes:
                
                    - First and last name
 
                    - Date of birth
 
                    - Sex assigned at birth
 
                    - Relationship to you
 
                
             
         
        
            
- Location Data Collected Through GPS technology
 
            - Maple may collect and use location data collected through GPS technology to identify the province or
                territory in which you are located, to ensure that we connect you to an Authorized Provider that is licensed
                or authorized to provide services in your province or territory and, if applicable, to connect you to a
                pharmacy near you.
 
        
    
    Wellness Services
    In addition to receiving Maple's Healthcare Services, you have the option to sign up to receive Wellness Services
        from Maple, such as our Recommendations service, which sends you preventative health recommendations based on your
        health profile. If you sign up for a Wellness Service, your Information will be used as described below. If you do
        not sign up for any Wellness Services, this section does not apply to you.
    
        
            
- Health Profile
 
            - If you sign up for our Wellness Services, Maple will use the Information you provided when you created your
                account, such as your age, and sex assigned at birth and any Information that you enter into your Health
                Profile, such as height, weight, allergies, and medication, to provide you with your Wellness Services.
 
        
        
            
- Information Created from Your Use of Healthcare Services
 
            - If you sign up for any of our Wellness Services and choose to include Information from your use of
                Healthcare Services, such as your diagnosis and treatment details, in your Health Profile, Maple will use
                this Information to provide you with suggestions for similar Wellness Services that may be of interest to
                you.