TELUS HEALTH MYPET PRIVACY COMMITMENT

By accessing or using the Services through TELUS Health MyPet, you understand that your information will be treated in accordance with this TELUS Health MyPet Privacy Commitment (the “”) in connection with your use of the Services. Our Privacy Commitment and practices are consistent with the 10 Fair Information Principles, and we strive to apply the principles of Privacy by Design in the development and review of our products and services.

If you use the Services to access Veterinary Care in British Columbia, your Veterinarian is associated with Little Paws Animal Clinic Inc., which is owned by TELUS Health. The Privacy Commitment available here applies to the Personal Information handling practices of Little Paws in connection with the Veterinary Care you receive.

If you use the Services to access Veterinary Care in Ontario, your Veterinarian is associated with Norwich Veterinary Medicine Professional Corporation carrying on business as Pet Telemedicine Veterinary Care. The Privacy Commitment available

here

applies to the Personal Information handling practices of Pet Telemedicine Veterinary Care in connection with the Veterinary Care you receive.

If you do not want us to collect, use or disclose your Personal Information in the ways identified in this Privacy Commitment, you may choose not to use TELUS Health MyPet.

Details

We have developed this Privacy Commitment to provide you with specific details about how TELUS Health collects, uses and discloses your Personal Information when you use the TELUS Health MyPet app, visit the TELUS Health MyPet website at

https://www.telus.com/en/personal-health/mypet

, or otherwise interact with TELUS Health MyPet. This Privacy Commitment reflects the requirements of applicable Canadian privacy legislation, including provincial and federal privacy laws, and our own continuing commitment to privacy. For additional clarity about how we handle your data and respect your privacy, please see the

TELUS Health MyPet FAQs

.

Please read this Privacy Commitment carefully. By accessing or using the Services, you consent to the collection, use and disclosure of Personal Information in accordance with this Privacy Commitment.

The following definitions apply to this Privacy Commitment.

– In this Privacy Commitment, “Little Paws” means Little Paws Animal Clinic Inc., which is owned by TELUS Health. In British Columbia, Little Paws is your Veterinary Facility.

– Any information about an identifiable individual, other than business contact information used to contact the individual in their business or professional capacity.

Personal Information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.

– A profile that you set up for your Pet in the ‘Pets’ tab of the TELUS Health MyPet app, which includes information you provide about your Pet, such as their name, breed, colouring, sex, age, weight, an image of your Pet, and whether your Pet is spayed or neutered.

– The services provided by TELUS Health through the TELUS Health MyPet virtual platform, including (a) Wellbeing Services, and (b) our app and website, that enable you to, among other things, access Veterinary Care and Wellbeing Services. Services do not include Veterinary Care.

– In this Privacy Commitment, the words “we”, “us”, “our” or “TELUS Health” refer to TELUS Health Solutions Inc.

– The TELUS Health MyPet virtual platform, including our app and website, through which TELUS Health provides the Services.

– In this Privacy Commitment, “TELUS Family” means TELUS Communications Inc. and its subsidiary companies and corporate affiliates, as they may exist from time to time.

– A licensed veterinarian, practicing in association with a Veterinary Facility, that provides Veterinary Care through the TELUS Health MyPet app.

– The veterinary telemedicine services provided to you by a Veterinarian (in association with a Veterinary Facility) through the TELUS Health MyPet app, which may include appointment booking, video and audio consultations with a Veterinarian, prescription services, referrals to a physical veterinary clinic, and related healthcare, professional and administrative support services.

– The accredited practice facility, accredited veterinary facility, or other veterinary practice holding a licence or permit to carry on the practice of veterinary medicine in the applicable jurisdiction.

– A record of information about you and your Pet in connection with the Veterinary Care you receive. This may include but is not limited to:

As Wellbeing Services are provided by TELUS Health and not by a Veterinarian, information about you and your Pet that you provide in connection with the Wellbeing Services you receive through TELUS Health MyPet will only be incorporated into your Veterinary Record with your consent.

– A veterinary technician or a veterinary technologist employed or engaged by TELUS Health that provides Wellbeing Services through the TELUS Health MyPet app. Veterinary Technicians are not providing services with oversight by Veterinarians or a Veterinary Facility and therefore do not carry on the practice of veterinary medicine.

– The wellbeing services provided to you by a Veterinary Technician through the TELUS Health MyPet app, which include services such as consultations relating to general questions about pet nutrition and pet behavioural or training issues and does not include providing specific treatment to your Pet, such as diagnosing your Pet or prescribing medications. The Wellbeing Services are provided by TELUS Health, which is not a Veterinary Facility and does not carry on the practice of veterinary medicine. For additional information on the type of issues that Wellbeing Services are able to address, please refer to

telus.com/mypet

.

– An individual who uses, or registers to use, the Services.

– A cat or dog whose information you provide through the TELUS Health MyPet app.

TELUS Health has overall responsibility for protecting the privacy of the Personal Information we collect about you through your use of the Services (including Wellbeing Services), and we are directly accountable to you with respect to the handling of that information. This includes your account registration information, the Pet Profile, information related to any Wellbeing Services you receive, app usage information and website and device information (as further described in this Privacy Commitment below), but it does not include your Veterinary Record.

All Wellbeing Services are provided by TELUS Health, which does not carry on the practice of veterinary medicine.

The Veterinarian from whom you receive Veterinary Care practices in association with a Veterinary Facility. The Veterinary Facility has overall responsibility for protecting your Veterinary Record and is directly accountable to you with respect to the handling of the Veterinary Record. TELUS Health is a service provider to the Veterinary Facility. We enable the Veterinarian, in association with the Veterinary Facility, to provide you with Veterinary Care through your use of the Services.

All Veterinary Care is provided by the Veterinarians in association with a Veterinary Facility and not by TELUS Health.

When you access or use the Services, you consent to our collection, use and disclosure of your Personal Information as described in this Privacy Commitment. You can withdraw your consent at any time, subject to limited restrictions.

When you receive Veterinary Care, the Veterinary Facility involved in your Pet’s care is responsible for obtaining your consent to collect, use and disclose your Veterinary Record.

When you access or use the Services, you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Commitment.

You can withdraw your consent to our collection, use and disclosure of your Personal Information at any time, subject to our legal and contractual restrictions. However, if you refuse to provide certain information or withdraw your consent, this may limit our ability to provide you with the Services.

When you receive Veterinary Care, the Veterinary Facility involved in your Pet’s care is responsible for obtaining your consent to collect, use and disclose your Veterinary Record. There may be certain instances in the TELUS Health MyPet app where we obtain consent on the Veterinary Facility’s behalf, such as to disclose the Veterinary Record to your primary veterinary clinic.

You can close your TELUS Health MyPet account at any time. To close your account or request to delete your Personal Information, you can make a request within the TELUS Health MyPet app, or send an email to [email protected]. In accordance with your instructions, we will (subject to the following paragraph) close your account or delete your Personal Information promptly, and we will confirm with you by email when this is completed. If your request relates to your Veterinary Record, we may direct your request to your Veterinary Facility and provide assistance as required.

If you close your account or request deletion of your Personal Information, we and the Veterinary Facility that has provided Veterinary Care to you may retain certain information to meet our respective legal, regulatory or contractual obligations; for example, Veterinary Records must be retained by the Veterinary Facility for a specified period of time in each province to meet legal and regulatory obligations. Please review the ‘’ section below for more information on our retention practices.

To collect, use or disclose Personal Information outside of the purposes contemplated in this Privacy Commitment, we will seek your additional consent.

Individuals under the age of majority may not create an account with TELUS Health MyPet.

We collect only the Personal Information required for us to establish and maintain a relationship with you, to provide the Services (including Wellbeing Services), to perform certain administrative activities on behalf of Veterinary Facilities, to develop, enhance or market our products and services (including to send you relevant information about products and services that may be of interest to you), and to maintain and improve the security and functionality of the TELUS Health MyPet app and website.

We collect Personal Information to set up an account for you on the TELUS Health MyPet app so that you can access and use the Services. When you create a Pet Profile, we also collect information about your Pet in order to get to know your Pet better.

When you book a consultation with a Veterinarian, we collect, on behalf of the Veterinary Facility, your payment information, and, on an optional basis, your third-party pet insurance information, where applicable.

We also collect other information from you as you use the Services:

We may use your name and contact information to send you relevant marketing messages. With your consent, these communications may be tailored based on information contained in the Pet Profile (such as your Pet’s name, age and breed). You can opt out of receiving marketing messages at any time by following the unsubscribe instructions included in each of our marketing messages or by contacting us as set out below.

Details

We collect and use Personal Information for the following purposes:

: In order to use the Services, including to access Wellbeing Services and Veterinary Care, you will need to download the TELUS Health MyPet app and create an account by providing your first and last name, email address, phone number, home address and a password that you select. The name and contact information you provide at the time of account creation will also be incorporated into the Veterinary Record when you receive Veterinary Care through the TELUS Health MyPet app.

: Before booking your first video or or audio consultation with a Veterinary Technician or a Veterinarian, you will be asked to set up a Pet Profile for your Pet that includes your Pet’s name and the type of animal (cat or dog), in addition to the following information: the breed, colouring, sex, age and weight of your Pet, whether your Pet is spayed or neutered, your pet insurer (optional), and an image of your Pet (optional). On an optional basis, you can also add other information, such as your Pet’s microchip or tattoo numbers, at any time in the ‘Pets’ tab. You can create multiple Pet Profiles (one for each of your Pets) in your account.

Information in the Pet Profile is incorporated into the Veterinary Record when you receive Veterinary Care through the TELUS Health MyPet app.

: When booking a consultation appointment with a Veterinarian through the TELUS Health MyPet app, you will need to provide information about why you are booking an appointment for your Pet (such as your Pet’s symptoms, the length of time your Pet has been exhibiting symptoms and whether there have been any changes) to enable the Veterinarian to provide you with Veterinary Care. On an optional basis, you can also upload any photos or videos of your Pet’s symptoms for the Veterinarian’s review. This information (together with a summary of your appointment and next steps) will be stored in the ‘History’ tab of the app and form part of the Veterinary Record.

: When booking a consultation appointment with a Veterinary Technician through the TELUS Health MyPet app, you will need to provide information about why you are booking an appointment for your Pet to assist the Veterinary Technician to provide you with Wellbeing Services. Based on the information you provide, we may need to direct you to speak to a veterinarian. This information (together with a summary of your appointment and next steps) will be stored in the ‘History’ tab of the app.

However, it will only be incorporated into your Veterinary Record with your consent.

: Your consultation for Veterinary Care or Wellbeing Services will take place virtually over real-time video and audio. All video and audio consultation calls conducted through the TELUS Health MyPet app are confidential and end-to-end encrypted. Recordings of consultations are never made.

Following your consultation for Veterinary Care, your Veterinary Facility may check in with you by SMS, phone call, or email to follow up on the care instructions your Veterinarian provided during your consultation, to see how your Pet is doing, and to give you an opportunity to ask any follow up questions.

: Prior to consulting with a Veterinarian or Veterinary Technician, you will be required to provide your payment information, such as your payment method, payment card number and CVV code. We use a third-party service provider who is Payment Card Industry Data Security Standard (PCI DSS) compliant to facilitate secure payment processing.

The Veterinary Facility does not offer direct billing to third-party pet insurance providers. However, on behalf of the Veterinary Facility, and on an optional basis, we will also ask you whether you have third-party pet insurance, your pet insurance provider’s name and contact information, and whether you consent to the Veterinary Facility (or us on the Veterinary Facility’s behalf) responding to your pet insurance provider directly if they reach out to us about a claim. Providing us with this information helps expedite our response time in the event of a claim.

: We may contact you by SMS, email or push notification to provide you with helpful information related to the Services, such as appointment reminders, how to prepare for your appointment, and other important information or updates. You can turn off push notifications at any time in your device settings. To adjust your communication preferences for service messages, contact us using the contact information set out under “” below.

: In certain circumstances, Personal Information may be required by or accessible to technical support staff in order to resolve technical issues. Where possible, our support team will resolve issues without viewing Personal Information. If you speak to TELUS Health MyPet support, all audio conversations are recorded to ensure quality of service to you and for training purposes.

: We analyze Personal Information in your TELUS Health MyPet account, actions you take on the TELUS Health MyPet app, and your ratings or responses to surveys, to better understand how we can improve and what care programs or services to provide. For example, we may use your postal code and aggregate it with all other TELUS Health MyPet user postal codes to determine the best location to open a new physical Veterinary Facility, or to locate a third-party Veterinary Facility that may wish to provide veterinary services through the TELUS Health MyPet app.

: Your name and email address may be used by us to contact you regarding your experience when using the Services. We may ask for additional information to follow up. We may share this information with a third-party to address an issue or concern and to improve our service offerings.

: Your name and email address may be used to send you information and offers by email about TELUS Health MyPet and other products, services and pet care that may be relevant to you and your Pet (including products and services offered by the TELUS Family and other third-party partners). With your consent, these communications may be tailored based on information contained in the Pet Profile (such as your Pet’s name, age and breed).

We may use your email address or phone number (where available) to digitally deliver ads about our services and offers on third-party websites and apps where we purchase advertising from our partners. We only share anonymized and aggregated information with our third-party partners.

You can opt out of receiving marketing messages from us at any time by following the unsubscribe instructions included in each of our marketing messages or by contacting us as set out under “” below.

: In general, you can visit our website without telling us who you are or submitting any Personal Information. However, we collect the Internet Protocol (IP) addresses of all visitors to our website and other related information such as device type, page requests, browser type, operating system and average time spent on our website. We use this information to help us understand our website activity and to monitor and improve our website. We also use your IP address and device type to help ensure a secure experience and detect anomalous behaviour.

: As with many applications, certain limited technical data is required for the TELUS Health MyPet app to function on your device. The information we collect includes information about your device and operating system, such as the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the app accesses our servers. This information is used to deliver content appropriate for your device’s capabilities, to deliver push notifications and to help ensure a secure experience and detect anomalous behaviour in order to protect Personal Information from unauthorized access. In addition, in the event the TELUS Health MyPet app crashes on your mobile device, we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of the TELUS Health MyPet app.

: We may collect and analyze information about the actions you take on the TELUS Health MyPet app to better understand what care programs or services to provide.

: Please see our Cookies Notice for information on our use of Cookies.

: We may de-identify or aggregate your Personal Information, such that it cannot reasonably be associated with you, for the following purposes:

We may share such de-identified information or insights with our partners to assist in research, planning, or product and service development.

We will not disclose your Personal Information for any purpose other than what has been outlined in this Privacy Commitment or as permitted or required under applicable law unless we obtain your consent. We disclose only the limited amount of Personal Information reasonably necessary to meet these purposes.

We do not sell your Personal Information to any third parties.

We may share your Personal Information with our service providers who are contracted to perform services or functions on our behalf where they require the information to assist us in serving you. We use contractual controls to protect this information and limit its use to what is necessary for the service provider to perform the service.

Details

We may share or disclose Personal Information for the following purposes:

: When you use the Services to access Veterinary Care, we will share your name, contact information (including your email address, phone number and home address) and information in the Pet Profile with the Veterinarian (and the Veterinary Facility with whom the Veterinarian is associated), and this information will be incorporated into your Veterinary Record. You will develop a veterinarian-client-patient relationship directly with the Veterinary Facility, and the Veterinary Facility is responsible for the Veterinary Record. The Veterinary Facility will collect, use, disclose, secure and otherwise handle the Veterinary Record in accordance with its own privacy policy, and may do so separate and apart from the TELUS Health MyPet app.

: When you use the Services to access Wellbeing Services, the record of your visit with a Veterinary Technician will not automatically be included in your Veterinary Record or disclosed to a Veterinary Facility. If you intend to access both Wellbeing Services and Veterinary Care, information about the Wellbeing Services you receive can be shared with the Veterinary Facility with your consent.

: We may, on the Veterinary Facility’s behalf, obtain your consent to share your Veterinary Record with your primary veterinary clinic, an emergency clinic and/or others who assist in the provision of care to your Pet for the purpose of providing continuity of care to you and your Pet.

: When your third-party pet insurance provider contacts us for information regarding a claim you have made concerning Veterinary Care you received through TELUS Health MyPet, we will (on the Veterinary Facility’s behalf), with your consent, release the requested information to the third-party pet insurance provider.

: We may share Personal Information with our suppliers, agents or other organizations or individuals who are contracted to perform services or functions on our behalf, where they require the information to assist us in serving you. For example, we may use service providers to process payments, power the app, host our website and store and dispose of information on our behalf. We strive to minimize the amount of Personal Information that we share with our service providers and partners and require that it not be used for any other purpose. Our service providers may be located in Canada, the U.S. or other foreign jurisdictions.

: Your name, email address and home address may be shared within the TELUS Family and matched to your existing TELUS customer profile (if applicable) to identify other services that you have with the TELUS Family. This information may be used to:

: We may disclose Personal Information to the extent necessary where we are required or permitted under applicable law. We or our service providers will also share Personal Information with Canadian, U.S. or other law enforcement, courts, other government agencies or other parties if we are required to do so to meet our legal and regulatory requirements in the jurisdictions in which we or our service providers operate; for example, we are required to provide records to law enforcement in response to a valid court order.

: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of TELUS Health MyPet, or as part of a corporate reorganization or other change in corporate control.

: We may use third parties such as Google Analytics and AppsFlyer to help us gather and analyze information about the areas visited on our website (such as the pages most read, time spent, search terms and other engagement data) and the TELUS Health MyPet app, in order to evaluate and improve the user experience and our website, and to help us understand interaction with the ads and marketing campaigns that we place on other applications or websites (such as ad click rates, the types of applications or websites on which such ads were displayed, and number of app downloads) in order to measure and improve the effectiveness of our marketing campaigns. These third parties may use cookies and other tracking technologies.

For more information about Google Analytics or AppsFlyer, or to prevent the storage and processing of this data (including your IP address or device identifier), you can do the following:

You can also obtain additional information on Google Analytics’ and AppsFlyer’s data privacy and security at the following links:

: The TELUS Health MyPet app and website may contain links to other websites or platforms that TELUS Health does not own or operate. Also, links to the Services may be featured on third-party websites or platforms as advertisements. Except as provided in this Privacy Commitment, we will not share Personal Information with these third parties without your consent. We provide links to third-party websites or platforms as a convenience to our users. These links are not intended as an endorsement of, or referral to, the linked websites or platforms. The linked websites or platforms have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites or platforms, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use, disclose and otherwise handle Personal Information. You should read their privacy policies and make an informed decision about whether you want to use those websites or their services.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

You can request access to or correction of the Personal Information we collect about you by contacting us at [email protected]. We rely on you to keep your Personal Information up to date and accurate so that we can serve you.

If your request relates to your Veterinary Record, we will work with the Veterinary Facility to satisfy your request as appropriate.

By contacting us at [email protected], you may request access and corrections to the Personal Information we collect about you at any time, subject to limited exceptions. We will take reasonable steps to verify your identity before granting access or making corrections. Upon written request, we will also provide you with a list of individuals or entities (e.g., third-party service providers) with or to whom we have shared or disclosed your Personal Information, if applicable.

We rely on you to ensure that the Personal Information you provide through the TELUS Health MyPet app is accurate, complete and up to date. You are welcome to make changes or request deletions or corrections to Personal Information we collect about you at any time by updating your account on the TELUS Health MyPet app or by contacting us at [email protected].‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

If your request relates to your Veterinary Record, we will work with the Veterinary Facility to satisfy your request as appropriate.

We retain Personal Information only for as long as necessary to fulfil the purposes described in this Privacy Commitment or as required to meet legal or regulatory requirements.

Your Veterinary Record is stored by your Veterinary Facility in accordance with provincial retention guidelines.

Details

We retain Personal Information only for as long as necessary to fulfil the purposes described in this Privacy Commitment or as required to meet legal or regulatory requirements. We may also create and retain de-identified information and continue to use this information in accordance with this Privacy Commitment.

At your request, we will delete your Personal Information unless we are required to retain it to meet our legal or regulatory obligations. See also the ‘’ section above.

Your Veterinary Record is stored by your Veterinary Facility in accordance with provincial retention guidelines.

Audio recordings of the support services you receive are stored for 90 days.

We have implemented a comprehensive information security program.

We understand that data security is a critical issue, and we are committed to safeguarding the Personal Information in our custody or control. We have implemented a comprehensive information security program that includes written policies and procedures, and security controls, as well as reasonable administrative, technical and physical safeguards, in an effort to protect against unauthorized access, use, loss, modification, and disclosure of Personal Information in our custody or control.

Our team members must complete privacy and security training before they have access to any Personal Information, and they must complete annual privacy and security training for ongoing access to Personal Information.

TELUS Health takes steps to ensure that the security policies, procedures, and controls of our service providers meet industry and TELUS best practices and are regularly tested.

Please keep in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you provide to us, but we can assure you that we will use reasonable and appropriate security controls.

It is important for you to play an active role in the protection and safeguarding of your Personal Information, and to guard your privacy when you are online. If the TELUS Health MyPet app or website contains links to other websites, this Privacy Commitment does not govern those websites. You should read their privacy policies and make an informed decision about whether you want to use those websites or their services.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

We may make changes to this notice, and we will notify you of the changes to our information practices.

This Privacy Commitment may be updated from time to time to reflect changes to our practices. Any notices regarding modifications to this Privacy Commitment will be in written form and provided to you on the TELUS Health MyPet app and on our website.

If any changes to this Privacy Commitment are significant, we will provide a more prominent notice (including email notification, if appropriate).

We encourage you to periodically review this Privacy Commitment for the latest information on our privacy practices and to contact us if you have any questions or concerns.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

You can always reach us at [email protected] if you have privacy questions, concerns or complaints regarding TELUS Health's handling of your Personal Information in connection with the Services.

If you have any privacy questions, concerns or complaints regarding your Veterinary Facility’s handling of your Personal Information in connection with the provision of Veterinary Care, you can contact your Veterinary Facility (see the ‘’ section above).

Please contact us at [email protected] or the address below if, in connection with the Services, you:

: TELUS Health MyPet c/o Privacy Officer 2280 – 510 West Georgia Street Vancouver, BC V6B 0M3

If you have any privacy questions, concerns or complaints regarding your Veterinary Facility’s handling of your Personal Information in connection with the provision of Veterinary Care, you can contact your Veterinary Facility. A list of Veterinary Facilities (see the ‘’ section above).

If you have concerns with our Privacy Commitment or privacy practices, we encourage you to first bring your concerns to us at [email protected]. You may also seek advice from the Office of the Privacy Commissioner of Canada or the provincial Privacy Commissioner having jurisdiction, and, if appropriate, file a written complaint with the Commissioner's office.

To contact the applicable privacy commissioner, please visit the following websites:

Office of the Information and Privacy Commissioner for British Columbia:

www.oipc.bc.ca

Office of the Privacy Commissioner of Canada:

https://www.priv.gc.ca/