Seekintoo

Updated: August 4, 2023

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WELL Health Technologies Corp. (“WELL” or “we”) is proud to offer you the Seekinto webpage (the “Webpage”) and the associated cyber and digital security services (“Services”). WELL is committed to protecting your personal information and complying with applicable data protection and privacy laws. This “Privacy Policy” tells you how we do so.

This Privacy Policy does not apply to the collection, use and disclosure of personal information by third-party hardware or software deployed in the performance of the Services. Such hardware and software will have their own privacy policy. We encourage you to read their privacy policy to understand how they protect information. We will update this Privacy Policy as necessary. Please check it regularly.

What information do we collect?

Webpage Access

Unless you opt-out, our website uses “Cookies” and other automatic data collection technologies with your consent to collect personal information whenever you visit or interact with the Webpage, including unique identifiers and preference information such as IP address, technical usage, browser type, time zone settings,language preferences, operating system, unique device identifiers, search history, page response times and length of visit, pages viewed, marketing preferences or navigation and clickstream behavior for onlineinteractions.

These Cookies helps us understand how you use the Webpage and the content of the Webpage in order to make improvements. We also may use these Cookies to promote our services through marketing and advertising.These Cookies may be accessed or disclosed to third-parties for the purpose of serving you relevantadvertisements.

You can opt-out of Cookies or prevent third-party websites from accessing our Cookies through the privacysettings on your browser. However, opting-out of our Cookies may disable some of the Webpage’s features, andmay prevent us from providing you with the information and services you have requested.

Contact us

When you submit a “Contact Us” form on the Webpage, or send us e-mail, we will collect your name, e-mail,phone number, and your company’s name and website. This information will be used by the Seekinto’s team toconduct the appropriate follow-up.

Direct marketing

If you sign up to receive direct marketing or promotional communications from WELL, we will collect your name and e-mail to inform you about WELL and our products and services.

Services

If you engage WELL to provide you Services for your organization, we will collect some information about you and your organization’s operations, including staff members’ contact information, such as names, e-mails, address and phone numbers. This information will be used to create a unique customer profile within WELL’s system, to track the products and services WELL provides the organization, as well as help WELL implement different security solutions on your behalf.

Why do we use personal information?

We use your personal information to:

• manage our relationship with you and provide you with the information or services you request,
• instal hardware and software and ensure organization’s staff members are properly set up on different systems,
• conduct research and evaluate research and development on the Webpage including analyzing testing data to improve our services,
• communicate with you regarding inquiries for information or customer service request,
• detect, prevent or investigate security breaches,
• protect our business, and
• maintain appropriate records for internal administrative purposes.

WELL reserves the right to aggregate, de-identify and anonymize personal information (or other information) stored on its system and use such aggregated information as it sees fit.

Who do we share the personal information with?

We only share your personal information with service providers in order to operate the Webpage, provide the Services and offer you the information or services you request. This includes sharing your personal information for

• fraud prevention,
• providing requested services or information,
• operating the Webpage,
• setting up staff members’ profiles on different security software, and
• customer service.

We only use service providers that ensure a comparable level of protection for your personal information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information for the services requested.

Exceptionally, as allowed or required by law, we may have to disclose your personal information to law enforcement agencies where they demonstrate they have the legal authority to request it. If we merge with another business, we will inform you of any impact on your personal information.

How long do we keep personal information?

We retain personal information for as long as required to provide the services for which it was collected, otherwise, in accordance with applicable legal and regulatory requirements.

How do we keep personal information accurate?

We take reasonable steps to ensure that any personal information in our custody is accurate and up-to-date but we mostly rely on you to notify us of any changes to personal information you provided us.

How do we protect your personal information?

We use reasonable and appropriate physical, administrative and technical measures designed to help you secure your personal information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the personal information collected by us are authorized to do so. Unauthorized use of personal information by anyone affiliated with WELL is prohibited and constitutes grounds for disciplinary action.

Even though we take all necessary steps to protect your personal information, security breaches cannot be eliminated and we cannot guarantee no breach will ever occur.

Where do we store personal information?

All personal information we collect on our Webpage is stored on secure servers in Canada; however, persona information processed by our third-party service providers may be done outside of Canada. While outside of Canada, personal information is subject to that jurisdiction’s laws, which may permit governmental authorities the right to access your personal information.

For the performance of the Services, we only use hardware and software that permits us to specify the location of where all data is stored. For instance, if you are a Canadian organization, we ensure that we only use vendors that allow us to store all data in Canada. If you are an American organization, we ensure that we only use vendors that allow us to store all data in the United States of America.

For more information on our service providers or where we store personal information, contact us at privacy@well.company.

Links to third-party sites

Our Webpage may lead you to third-party websites, including websites advertising other products or services. The third-party hardware and software used in the performance of the Services may also lead you to other websites. These organizations and websites are separate and distinct from WELL and have their own separate privacy policies. We are not responsible in any way for how any third-party collects, uses or discloses your personal information, so it is important to familiarize yourself with the privacy policies of these websites before providing your personal information to them.

Direct marketing

You may sign up to receive marketing or promotional communications from WELL. Where you have expressly consented, we may use your personal information to inform you about us and our products and our services, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

• using the unsubscribe feature found in our emails and other electronic communications, or
• contacting us via email at marketing@well.company.

We remove your contact details from our distribution list as soon as you unsubscribe.

Your rights

You also have the right to:

• make a written request to access your personal information,
• request us to restrict our use or disclosure of your personal information,
• object to our use or disclosure of your personal information,
• request that we edit, but not remove, certain information (like an e-mail address),
• request that we transfer to another organization the personal information you have provided us, and
• request us to delete the personal information we hold about you.

Contact us at privacy@well.company to exercise any of these rights. We will respond within 30 days. If we cannot grant your request, for example if you make an access request and providing you access would disclose personal information about another person, we will give reasons.

We will address all requests with equal attention.

Contacting us

Accountability with respect to your personal information is important to WELL. In the event that you have any questions (including how personal information is managed by WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company.

If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.