TELUS HEALTH MYPET PRIVACY COMMITMENT

By accessing or using TELUS Health MyPet Services, you understand that your information will be treated in accordance with this TELUS Health MyPet Privacy Commitment (the “Privacy Commitment”). 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 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 the TELUS Health MyPet Services.

The following definitions apply to this Privacy Commitment.

Personal Information – 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.

Services – The TELUS Health MyPet virtual platform, including our app and website, that enable you to, among other things, access Veterinary Care. Services do not include Veterinary Care.

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

TELUS Family – 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.

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

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

Veterinary Facility – The accredited veterinary practice or facility in association with which a Veterinarian practices.

Veterinary Record – 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:

1. your Personal Information, such as first and last name, email address, phone number, home address, payment or insurance information, a record of communications and a record of missed and/or cancelled appointments; and
2. medical information and history about your Pet, such as information you provide about your Pet’s symptoms, consultation notes, diagnoses, prescriptions, lab requisitions and reports, and referrals.

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

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

TELUS Health MyPet has overall responsibility for protecting the privacy of the Personal Information we collect about you through the Services, and we are directly accountable to you with respect to the handling of that information.

The Veterinarian from whom you receive Veterinary Care practices in association with a Veterinary Facility. The Veterinary Facility has overall responsibility for protecting the Veterinary Record, including any of your Personal Information contained therein, and is directly accountable to you with respect to the handling of the Veterinary Record. We act as a service provider to the Veterinary Facility when we provide you with access to Veterinary Care through your use of the Services, and when we store and make available the Veterinary Record in the TELUS Health MyPet app.

When you access or use the Services, you consent to our collection, use, disclosure, and storage 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, disclose, and store your Veterinary Record.

Details

When you access or use the Services, you consent to our collection, use, disclosure, and storage 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, disclose, and store 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 regular veterinary clinic.

You can close your account at any time. To close your account or request to delete your Personal Information, you can do so by requesting the same within the TELUS Health MyPet app, or by sending an email to TELUSHealthMyPet@telus.com. In accordance with your instructions, we will close your account or delete your Personal Information promptly and will confirm with you by email when this is completed.

If you close your account or request deletion of your Personal Information, we and the Veterinary Facilit(ies) that have provided Veterinary Care to you may retain certain information to meet our legal or regulatory obligations; for example, Veterinary Records must be retained by the Veterinary Facilit(ies) for a specified period of time in each province to meet legal and regulatory obligations. Please review the ‘Retention’ 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, 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.

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

• App usage information
• Website and device information
• Cookies
• Payment and third party pet insurance information

We may use Personal Information to send you relevant marketing messages. You can opt out of receiving marketing messages at any time.

Details

By creating an account with TELUS Health MyPet, you will be able to access and use the Services, and to access Veterinary Care, including consultations with Veterinarians through video or audio consultations.

We only collect and use Personal Information for the following purposes:

To establish and maintain our relationship with you

TELUS Health MyPet Account Creation: In order to use the Services and access 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 form part of the Veterinary Record when you receive Veterinary Care through the TELUS Health MyPet app.

To provide you with the Services and access to Veterinary Care

Adding a Pet: Before booking your first video or audio consultation with a Veterinarian, you will be asked to provide 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). This information helps the Veterinarian get to know your Pet, just as a veterinarian would in a physical veterinary clinic, and to provide tailored Veterinary Care. We may also use this information to send you relevant news and offers (see ‘Sending marketing communications’ below).

The information you provide about your Pet is stored in the app under the ‘Pets” tab and forms part of the Veterinary Record when you receive Veterinary Care through the TELUS Health MyPet app. You can add multiple Pets to your account.

Booking a Consultation with a Veterinarian: 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. This information, together with any consultation notes taken by the Veterinarian during your consultation, will be stored in the ‘History’ tab of the app and form part of the Veterinary Record. With your consent, the Veterinary Record will be shared with your regular veterinary clinic, but only if you select this option.

Real-Time Video and Audio Consultations with a Veterinarian: Your consultation with a Veterinarian will take place virtually over real-time video or audio. All video and audio calls conducted through the TELUS Health MyPet app are confidential and end-to-end encrypted. Recordings are never made.

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

Payments and Insurance Information: For consultations with Veterinarians, 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.

We do not offer direct billing to third party pet insurance providers. However, 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 us 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.

Service Messages: 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.

TELUS Health MyPet Technical Support: 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.

To develop, enhance or market our products and services

Developing and enhancing our services: We analyze Personal Information in your TELUS Health MyPet account profile, 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 clinic.

Satisfaction and experience surveys and questionnaires: 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 our third-party to address an issue or concern and to improve our service offerings.

Sending marketing communications: Your TELUS Health MyPet contact details, including your name, phone number, email address, or home address may be used so that TELUS Health MyPet can provide you with news and offers by SMS, email or mail about TELUS Health MyPet, the TELUS Family, and third-party partners. These communications may be tailored based on data in your account profile (including the information you provide to us about your Pet(s)) and app activity. We may send you offers for a TELUS service you may not currently subscribe to, or send you offers for a TELUS third-party partner that may be of interest to you.

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 below.

To maintain and improve the security, performance and functionality of the TELUS Health MyPet Website and App

Visiting the TELUS Health MyPet Website: 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.

Device Information: 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.

App Usage Information: 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.

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

De-Identification and Aggregation

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

1. To protect your privacy and the security of your Personal Information;
2. To conduct analytics and/or research in a privacy protective manner to:
   a. better understand and improve the Services;
   b. operate and expand our business opportunities; and
   c. improve pet health outcomes.

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 express 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:

Consultation with a Veterinarian: 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 about your Pet with the Veterinarian (and the Veterinary Facility with whom the Veterinarian is associated), and this information will form part of 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.

The Veterinary Record will be stored in the TELUS Health MyPet app and accessible to Veterinarians who provide or assist in the provision of Veterinary Care.

Sharing with your Regular Veterinary Clinic: With your consent (and on the Veterinary Facility’s behalf), we will share the Veterinary Record with your regular veterinary clinic and/or others who assist in the provision of care to your Pet for the purpose of providing or assisting in the provision of continuing veterinary care to you and your Pet.

Pet Insurance: 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, with your consent, release the requested information to the third party pet insurance provider.

Service Providers: 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.

Within the TELUS Family: Your name, email address, home address, and phone number 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:

• Perform aggregated reporting and demographic analysis;
• Ask for your feedback on the Services through surveys or other means; and
• Help us and the TELUS Family provide better recommendations of TELUS products and services that may be of interest to you and exclude those that are not relevant. For example, we and the TELUS Family will try not to contact you to register for the TELUS Health MyPet app if you have already downloaded the TELUS Health MyPet app and registered for the Services.

Disclosures required or permitted by law or regulation: 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 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.

Sale of Business: 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.

Analytics: We may use a third-party such as Google Analytics 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) in order to evaluate and improve the user experience and our website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
https://policies.google.com/technologies/partner-sites, and
https://support.google.com/analytics/topic/2919631.

Third Party Links: The TELUS Health MyPet app and website may contain links to other websites or platforms that TELUS Health MyPet 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, secure and otherwise handle Personal Information.

You can request access to or correction of the Personal Information we collect about you by contacting us at TELUSHealthMyPet@telus.com. We rely on you to keep your Personal Information up-to-date and accurate so that we can serve you.

Details

You may request access and corrections to the Personal Information we collect about you at any time, subject to limited exceptions. 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. Please contact TELUSHealthMyPet@telus.com for additional information.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

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 profile on the TELUS Health MyPet app or by contacting us at TELUSHealthMyPet@telus.com.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

For a copy of your Personal Information, please contact us at TELUSHealthMyPet@telus.com. We will take reasonable steps to verify your identity before granting access or making corrections. In addition, your right to access or correct your Personal Information is subject to certain legal restrictions.

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.

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 Consent section herein.

When we store Veterinary Records on a Veterinary Facility’s behalf, the records must be retained in accordance with provincial retention guidelines.
In general, for Veterinary Records, we will follow a retention schedule of a maximum of 10 years from the date of last entry.

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

We have implemented a comprehensive information security program.

Details

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 MyPet 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.

Details

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 TELUSHealthMyPet@telus.com if you have privacy questions, concerns or complaints.

Details

Please contact us at TELUSHealthMyPet@telus.com or the address below if:

• you have any questions related to our collection, use or disclosure of your Personal Information;
• you need to report any privacy or security violations, including any suspected or actual unauthorized access, use, disclosure or loss of Personal Information;
• you wish to withdraw your consent to our collection, use or disclosure of your Personal Information;
• you have any questions or comments about this Privacy Commitment; or
• you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information, including our policies and practices with respect to the use of service providers outside of Canada.

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

If you wish to access, update, and/or correct inaccuracies in the Personal Information we collect about you through the Services, please contact us at TELUSHealthMyPet@telus.com.

If you have concerns with our Privacy Commitment or privacy practices, we encourage you to first bring your concerns to us at TELUSHealthMyPet@telus.com. 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:
Alberta: www.oipc.ab.ca
British Columbia: www.oipc.bc.ca
Manitoba: www.ombudsman.mb.ca
New Brunswick: https://oic-bci.ca/
Newfoundland and Labrador: www.oipc.nl.ca
Northwest Territories: https://atipp-nt.ca/
Nova Scotia: https://oipc.novascotia.ca/
Nunavut: https://atipp-nu.ca/
Ontario: www.ipc.on.ca
Prince Edward Island: https://www.assembly.pe.ca/
Québec: www.cai.gouv.qc.ca
Saskatchewan: https://oipc.sk.ca/
Yukon: https://www.ombudsman.yk.ca/
Federal: https://www.priv.gc.ca/