Pet Telemedicine Veterinary Care Privacy Commitment

When you use our Services, you understand that your Personal Information will be treated in accordance with this Privacy Commitment. 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 our Services.

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We have developed this Privacy Commitment to provide you with specific details about how we collect, use and disclose your Personal Information when you use our Services or otherwise interact with us. This Privacy Commitment reflects the requirements of applicable Canadian privacy legislation and our own continuing commitment to privacy.

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. – 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 your TELUS Health MyPet account, which includes information 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 Pet Telemedicine Veterinary Care, including Veterinary Telemedicine Services and in-person retail services through our clinic storefront located in Ontario.

– TELUS Health Solutions Inc., a service provider to us.

– A virtual platform provided by TELUS Health through which we facilitate the provision of Veterinary Telemedicine Services to you.

– A veterinarian licensed by the College of Veterinarians of Ontario, practicing in association with us, that provides Veterinary Telemedicine Services through the TELUS Health MyPet app.

– The veterinary and related services, including telemedicine services, provided to you by a Veterinarian (in association with us) 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. Veterinary Telemedicine Services also includes Veterinary Record storage and pharmaceutical dispensing; however, these activities do not occur through the TELUS Health MyPet app.

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

– An individual who accesses or uses the Services.

– A cat or dog whose information you provide to us in order to receive Veterinary Telemedicine Services.

We have overall responsibility for protecting the privacy of the Personal Information we collect about you through your use of the Services (including the Veterinary Record), and we are directly accountable to you with respect to the handling of that information.

In order to receive Veterinary Telemedicine Services, you will be required to download and install the TELUS Health MyPet app and create an account with TELUS Health MyPet. TELUS Health is a service provider to us and does not carry on the practice of veterinary medicine. All Veterinary Telemedicine Services are provided by Veterinarians in association with us.

When you register for and use the TELUS Health MyPet app, your Personal Information will also be handled by TELUS Health in accordance with the TELUS Health MyPet Privacy Commitment available

here

. TELUS Health is accountable for certain information that it collects about you, including your registration information and app usage data. We remain accountable for the Veterinary Record, which will only be handled by TELUS Health as necessary to assist us in providing Veterinary Telemedicine Services to you.

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.

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

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.

If you close your TELUS Health MyPet account or request deletion of your Personal Information, we may retain certain Personal Information, including your Veterinary Record, to meet our legal or regulatory obligations. Please review the “” section below for more information on our retention practices.

Individuals under the age of majority may not create an account with TELUS Health MyPet or receive Veterinary Telemedicine Services from us.

We collect only the Personal Information required for us to establish and maintain a relationship with you and provide the Services.

In order to access Veterinary Telemedicine Services, you will need to create an account with TELUS Health. TELUS Health collects Personal Information to set up an account for you on the TELUS Health MyPet app, which you can then use to receive Veterinary Telemedicine Services from us. See the “” section above for further information regarding the handling of your Personal Information by TELUS Health.

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We collect and use Personal Information for the following purposes: : In order to access Veterinary Telemedicine Services, you will need to download the TELUS Health MyPet app and create an account with TELUS Health 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 to TELUS Health at the time of account creation will be governed by the TELUS Health MyPet Privacy Commitment available

here

. It will also be incorporated into the Veterinary Record, for which we are responsible. See the “” section above for further information.

: Before booking your first video or audio consultation with a Veterinarian, you will be asked to set up a Pet Profile for your Pet in the TELUS Health MyPet app 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). You can create multiple Pet Profiles (one for each of your Pets) in your TELUS Health MyPet account.

The Pet Profile is stored in the TELUS Health MyPet app under the ‘Pets’ tab and is incorporated into the Veterinary Record when you receive Veterinary Telemedicine Services. The information you provide in the Pet Profile helps the Veterinarian get to know your Pet, just as a veterinarian would in a physical veterinary clinic, and to provide tailored Veterinary Telemedicine Services.

: 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 Telemedicine Services. 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 any consultation notes taken by the Veterinarian during your consultation) will be stored in the ‘History’ tab of the TELUS Health MyPet app and form part of the Veterinary Record.

: Your consultation with a Veterinarian will take place virtually over real-time video and audio through the TELUS Health MyPet app. All video and audio consultation calls are confidential and end-to-end encrypted. Recordings of consultations are never made. 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.

Following your consultation with a Veterinarian, your Veterinarian or a Veterinary Technician 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.

: Prior to consulting with a Veterinarian, you will be required to provide your payment information to us through the TELUS Heath MyPet app, such as your payment method, payment card number and CVV code. TELUS Health uses 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, you will also be asked whether you have third-party pet insurance, your pet insurance provider’s name and contact information, and whether we have your consent to respond (or for TELUS Health to respond on our behalf) 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 offer a clinic retail storefront location for you to purchase pet-related products or services or pick up prescriptions. In order to provide you with the products or services you request, we may collect certain Personal Information from you, including information about your Pet, your full name, phone number, email address, mailing and delivery address, insurance information (optional), and payment information.

: TELUS Health MyPet may, on our behalf, contact you by SMS, email or push notification to provide you with helpful information related to the Veterinary Telemedicine Services you receive, 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 the TELUS Health technical support staff in order to resolve technical issues. Where possible, the TELUS Health 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 may de-identify or aggregate Personal Information, including information in your Veterinary Record, such that it cannot reasonably be associated with you or your Pet and use this data in order to better understand and improve pet health outcomes, and share this information with third parties, such as pharmaceutical partners or regulators, to improve telemedicine vet care. For example, we may report on the number of veterinary consultations that resulted in a prescription, full resolution, or referral to an in-person clinic.

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.

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

: With your consent, we will 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 Telemedicine Services you received from us through TELUS Health MyPet, we will, 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 use TELUS Health to facilitate the offering of Services through the TELUS Health MyPet app and we may use service providers to process payments, send communications 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.

: With your consent, we may share certain Personal Information with TELUS Health so that TELUS Health can send you tailored 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 TELUS Health affiliates and other third-parties). Your Veterinary Record will not be shared with or used by TELUS Health for this purpose. For more information about how TELUS Health handles your Personal Information, please see the TELUS Health MyPet Privacy Commitment available

here

.

You can opt out of receiving marketing messages from TELUS Health at any time by following the unsubscribe instructions included in each of TELUS Health’s marketing messages or by contacting TELUS Health using the contact information set out in the TELUS Health MyPet Privacy Commitment.

: We may obtain your consent to share information about you and your Pet in a publication or article. In addition, we may obtain your consent to participate in a study or research project, in which case your Personal Information will be treated in accordance with the consent you provide at the time of enrollment.

: 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, US 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 Norwich Veterinary Medicine Professional Corporation carrying on business as Pet Telemedicine Veterinary Care, or as part of a corporate reorganization or other change in corporate control.

: The TELUS Health MyPet app may contain links to other websites or platforms that neither we nor TELUS Health own or operate. Also, links to the Services or the TELUS Health MyPet offering 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. Links to third-party websites or platforms are provided 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. Neither we nor TELUS Health have any control over such websites or platforms, and therefore neither we nor TELUS Health have 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, including your Veterinary Record, by contacting us using the contact information set out under “” below. We rely on you to keep your Personal Information up to date and accurate so that we can serve you.

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By contacting us using the contact information set out under “” below, 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 to us 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 by contacting us using the contact information set out under “” below.

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.

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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 store Veterinary Records in accordance with provincial retention guidelines.

We may also create and retain de-identified or aggregated information and continue to use such 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.

We understand that data security is a critical issue, and we are committed to safeguarding the Personal Information in our custody or control.

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We have implemented 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.

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.

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

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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.

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 using the contact information below if you have privacy questions, concerns or complaints regarding our handling of your Personal Information.

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Please contact us using the contact information below if you:

:

Pet Telemedicine Veterinary Care c/o Privacy Officer 103-410 Adelaide Street West Toronto, ON M5V 1S8

PTVChelp@telushealthmypet.com

If you have concerns with our Privacy Commitment or privacy practices, we encourage you to first bring your concerns to us at PTVCprivacy@telushealthmypet.com. You may also seek advice from the

Office of the Privacy Commissioner of Canada

, and, if appropriate, file a written complaint with the Commissioner's office.