PRIVACY POLICY – TOMTM

JLG Health Solutions Inc. (“JLG”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information, including through our Top of Mind (TOM™) mobile application (the “Software”) and related services (the “Services”). The Software acts as a personal aide for activity and medication scheduling and reminders, directed at those who have mild cognitive impairment and other equivalent challenges and their caregivers.

The privacy of our users is of great importance to us. By visiting our website located at http://jlghealthsolutions.com (the “Website”) or using the Software or related Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals or information that is linked to an identifiable individual (“Personal Information”). This Privacy Policy does not apply to the practices of companies that we do not own or control.

WHAT TYPES OF INFORMATION WE COLLECT

Personal Information                                                

In order to use the Software, a user must have a valid JLG account to log into TOM™ (“Account”). When a user registers with JLG, JLG collects each of their:

  • first and last names;
  • email address;
  • phone number;
  • if applicable, information about their caregiver including:
    • first and last name
    • relationship; and
  • billing information.

JLG uses this Personal Information to uniquely identify each user, authenticate their Account access, and provide access to the Software and Services. JLG also uses this Personal Information for record keeping and data analytics. JLG uses billing information to process payments for subscription fees in respect of any paid subscriptions to the Software and Services.

Caregiver Users’ Information

In order to use the Software, a Caregiver must have a valid JLG account to log into TOM™ (“Account”). When a user registers with JLG, JLG collects each of their:

  • first and last names;
  • email address;
  • phone number;
  • information about the user they will be accessing including:
    • first and last name
    • relationship; and

JLG uses this Personal Information to uniquely identify each user, authenticate their Account access, and provide access to the Software and Services. JLG also uses this Personal Information for record keeping and data analytics.

“Software” Usage Data

TOM™ tracks certain information about usage of the Software, including the entry of user or Caregiver information and the Software usage (i.e. time spent on the Software, frequency of logins, etc.) (“Usage Data”). JLG uses Usage Data in order to diagnose technical issues with the Software, monitor and improve efficiency, monitor and create logs for security purposes, and to inform product development and improvement. Aggregated and anonymized Usage Data may be used for marketing purposes to allow JLG and its partners to provide customized advertising and recommendations.

Website Data

JLG may also collect certain information from users of the Website through web forms that collect your first name, last name, email address, phone number, and may also collect Internet addresses, time spent logged into the website, and other usage data (“Website Data”). This information is logged to respond to user queries, provide ongoing email updates, and to continually improve the quality of the Services.

The JLG Website uses “cookies” to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your e-mail address or identity. We may use “persistent cookies” to save your registration ID and login password for future logins to our service or XSRF tokens for cross site scripting protection. We may use “session cookies” to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. You can change your browser options to stop accepting cookies or to prompt for your permission before accepting cookies. Choosing to decline cookies may affect your access to our products and services. The JLG Website may include links to third-party Web sites. These third-party Web sites may assign different cookies to you. Those cookies may be used to track your involvement with the advertising site. You may choose not to accept these cookies. JLG does not control these parties, and you should review their privacy policies to learn more about what, why and how they collect and use personal information.

STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

JLG stores its data, including Personal Information, using cloud services on servers located in Canada. By submitting Personal Information, you agree to this transfer, storing or processing of your Personal Information in Canada by our service providers. You acknowledge and agree that your Personal Information may be accessible to Canadian law enforcement and governmental agencies under lawful access regimes or court order.

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION

Service Providers and Business Partners

We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the TOM and related Services. In particular, JLG uses cloud services provided by Amazon Web Services Inc., which may be replaced or supplemented by JLG from time to time (“Service Providers”). Unless we tell you differently, such Service Providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of software licensing, maintenance services, database management, Web analytics and general improvement of the Platform and related Services.

Business Transfers

If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.

HOW WE PROTECT YOUR INFORMATION

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.

You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your personal Information or other content you transmit using the service, and you do so at your own risk.

USE OF AGGREGATED DATA

Aggregated data will not contain any information that could be used to contact or identify you. We may analyze and/or combine all information we receive, including Health Information and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Service.

RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you for up to thirty (30) days.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

ACCESS, CORRECTION AND ACCURACY  

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavour to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service. All requests to delete your Personal Information must be directed to JLG Health Solutions Inc’s Privacy Officer, whose contact information is listed at the end of this policy below.

CHANGES TO THIS PRIVACY POLICY

We may modify the terms of this Privacy Policy at any time. You understand and agree that collection of Personal Information is governed by this Privacy Policy effective at the time of your access to or collection of the information. If JLG makes material changes to this Privacy Policy, JLG will notify you by email, by posting notice on the Software, and/or by other methods as the case may be. JLG will also indicate on our Website the date that such changes were last made. You should revisit this Privacy Policy on a regular basis as revised versions will be binding on you. You understand and agree that your continued access our Website after the effective date of changes to this agreement represents your acceptance of such changes.

ADDITIONAL INFORMATION

Questions regarding this Privacy Policy or JLG Health Solutions Inc’s privacy practices should be directed to:

Attn: Privacy Officer

JLG Health Solutions Inc.

Email: info@topofmind.tech

 

Last Updated: January, 2021