CareVitas Home Care Inc. (hereinafter referred to as “we”, “us”, “our”, or the “Company”) respects the privacy of our clients and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy applies to all individuals who utilize our services, including but not limited to personal care, companion care, home support, overnight and respite care, transportation, dementia care, disability support, and other in-home support services (the “Services”). CareVitas Home Care Inc. operates exclusively in the Province of Ontario, Canada.

This Privacy Policy describes:

• How we collect, use, disclose, and protect the information you provide to us.
• The types of information we may collect from you in the course of providing the Services.
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy is incorporated into, and subject to, our further terms and conditions as set forth on our website at www.carevitas.ca. Any capitalized terms used but not defined in this Privacy Policy take the meaning ascribed in our Terms and Conditions.

We will only use your personal information (“PI”) in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the PI we collect about you is adequate, relevant, not excessive, and used only for the purposes for which it was collected or purposes otherwise disclosed to you.

This Privacy Policy applies to PI and other information we collect from you through:

• Direct interactions during the provision of Services, including through communications with our staff in person, by telephone, or in writing.
• Email, text, and other electronic or written messages between you and the Company.
• Authorized third parties engaged by the Company to support the delivery of Services. Where we share your PI with third parties, we require that those parties are contractually obligated to keep your PI confidential and secure, and to use it only for the purposes for which we disclose it to them.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, we may not be able to provide the Services or any portion thereof. By utilizing the Services, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy.

This Privacy Policy may change from time to time. Modifications will be made available on our website at www.carevitas.ca and will comply with all applicable Canadian and Ontario privacy legislation, including the Personal Health Information Protection Act (PHIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA). By continuing to use the Services after we make changes to this Privacy Policy, you acknowledge that you have read and understood the updated Privacy Policy and agree to be bound by the changes.

1. INFORMATION WE COLLECT ABOUT YOU

We collect and use various types of information from and about you, including but not limited to:

Personal Information (“PI”)

Includes data that reveals something personal about an identifiable individual and is protected by law, such as your given name, surname, date of birth, home address, email address, telephone number, and any other identifier that can be used to contact you or identify you. We collect PI to provide you with the Services, including but not limited to:

• When you sign up for and/or utilize the Services, we collect your name, home address, and other relevant information as reasonably necessary for the safe and appropriate delivery of in-home support.
• When you send us messages, feedback, or questions, we collect your contact information and the content of your communications.
• When you file a complaint with the Company, we collect your name, email address, mailing address, phone number, and information about the reason for your complaint and the resolution you are seeking.

Support and Care Plan Information

In the course of providing in-home support services, we collect relevant information about your personal support needs and preferences. This may include:

• Your personal support needs, daily routines, and care preferences.
• A support plan or service plan developed for you.
• Relevant background information provided by you, your family, or your authorized representative to enable us to deliver appropriate support.
• Information about your substitute decision-maker or authorized representative, where applicable.

CareVitas Home Care Inc. does not provide direct medical or clinical care services. We provide personal support, companion care, and home support services only. Any health-related information we collect is used solely to ensure the safe and appropriate delivery of those support services.

Non-Personal Information

We may also collect information that does not directly or indirectly reveal your identity, such as demographic or statistical information. We may derive non-personal statistical or aggregated data from PI for the purposes of improving our Services.

2. HOW WE COLLECT INFORMATION ABOUT YOU

The Company collects your information through the following methods:

• Direct interactions with you when you provide information to us, for example by filling in forms, communicating with our staff, or corresponding with us regarding the Services.
• Direct interactions during the provision of the Services, for example when a Company staff member assists you in your home or at another location where Services are delivered.
• Interactions with your family members, legal representatives, or authorized representatives, where information is provided to us for the purposes of delivering the Services.

The information we collect directly from you may include:

• Information provided through forms completed online or in person prior to or during the provision of Services, including at the time of registration or intake.
• Information about your support needs, preferences, and daily routines shared by you or your authorized representative.
• Information provided through direct conversations or correspondence with our staff.

3. HOW WE USE YOUR INFORMATION

We use the information we collect about you, including any PI, for the following purposes:

• To provide you with the Services and to communicate with you about those Services.
• To develop and maintain your support plan and ensure Services are delivered safely and appropriately.
• To fulfill the purposes for which you provided the information or that were described when it was collected.
• To provide you with notices about your inquiries or registrations relating to the Services.
• To carry out our obligations and enforce our rights arising from any agreements with you, and to comply with applicable legal requirements.
• To notify you about changes to the Services.
• To continually improve and personalize the Services we provide to you.
• To respond to your questions, comments, and concerns.
• To perform quality assurance and service improvement.
• To maintain compliance with our internal policies and procedures.
• To protect against fraud or error.
• To comply with legal and regulatory requirements under applicable Ontario and Canadian law.
• To investigate breaches of this Privacy Policy or our Terms and Conditions.
• For any other purpose with your explicit consent.

We may also use and disclose PI when we believe such use or disclosure is permitted, necessary, or appropriate under applicable Canadian law, including to comply with legal processes, to respond to requests from public authorities, or to protect our rights and the safety of our clients and staff.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose PI that we collect or that you provide as described in this Privacy Policy:

• To emergency services or other personnel where there is an immediate safety concern involving you or another person.
• To contractors and service providers engaged by us to support the delivery of the Services, who are contractually obligated to keep your PI confidential and to use it only for the purposes for which we disclose it to them.
• To an acquirer, successor, or assignee in the event of a merger, restructuring, reorganization, or other transfer of the Company’s assets, in accordance with applicable Canadian law.
• To fulfill the purpose for which you provided the information.
• For any other purpose disclosed by us when you provide the information.
• For any other purpose with your explicit consent.

We may also disclose your PI:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable Canadian law.
• To enforce or apply our Terms and Conditions and other agreements with you.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our clients, or others.

We do not sell, rent, or trade your personal information to any third party for marketing or commercial purposes.

5. STORING YOUR PERSONAL INFORMATION

CareVitas Home Care Inc. stores your PI within Canada. We are committed to ensuring that your information is stored and protected in accordance with applicable Canadian privacy legislation, including PHIPA and PIPEDA.

Whenever we engage a service provider to assist in the storage or processing of your PI, we require that their privacy and security standards adhere to this Privacy Policy and to all applicable Canadian privacy legislation.

We do not transfer your personal information outside of Canada.

6. DATA SECURITY

The security of your PI is very important to us. We use physical, electronic, and administrative measures designed to protect your PI from accidental loss and from unauthorized access, use, alteration, and disclosure.

While we take all reasonable steps to protect your information, no method of electronic storage or transmission is completely secure. We cannot guarantee absolute security. In the event of a data breach affecting your PI, the Company will notify you in accordance with our obligations under applicable Ontario privacy law.

7. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, the Company will only retain your PI for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

When your PI is no longer required, we will destroy, delete, or anonymize it in a secure manner. Under some circumstances we may anonymize your PI so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you.

8. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the PI we hold about you is accurate and current in order to provide you with safe and appropriate Services. Please keep us informed if your information changes.

By law you have the right to request access to and to correct the PI that we hold about you. You can do so by contacting our Privacy Officer using the contact information set out in Section 11 of this Privacy Policy.

We may request information from you to confirm your identity before fulfilling an access or correction request. If we are unable to provide you with access to your PI, we will inform you of the reasons, subject to any legal or regulatory restrictions.

Examples of exceptions to access requests under applicable law include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information about another individual that would reveal their PI.
• Information that is prohibitively expensive to retrieve.

9. WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, or disclosure of your PI, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact our Privacy Officer using the contact information set out in Section 11 of this Privacy Policy.

Please note that withdrawing your consent may affect our ability to provide you with the Services or any portion thereof. We will explain the impact of withdrawal to you at the time of your request to help you make an informed decision.

10. CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is current as of the date which appears at the top of this document. Any changes we make to this Privacy Policy will be posted on our website at www.carevitas.ca with a notice that the policy has been updated.

If we make material changes to how we treat your PI, we will notify you by email to the primary email address on file for your account or through a notice on our website.

You are responsible for ensuring we have an up-to-date and deliverable email address for you, and for periodically reviewing this Privacy Policy to check for any changes.

11. CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact our Privacy Officer at:

CareVitas Home Care Inc.

Privacy Officer

Website: www.carevitas.ca

Phone: 416-832-9076

Location: Vaughan, Ontario, Canada

Service Areas: Vaughan  ·  Richmond Hill  ·  North York  ·  Toronto  ·  Mississauga

We have procedures in place to receive and respond to complaints or inquiries about our handling of PI, our compliance with this Privacy Policy, and our compliance with applicable Canadian and Ontario privacy legislation, including PHIPA and PIPEDA.

If you are not satisfied with our response to your complaint or inquiry, you may contact the Information and Privacy Commissioner of Ontario:

Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400

Toronto, Ontario  M4W 1A8

Telephone: 416-326-3333  |  Toll-free: 1-800-387-0073

Website: www.ipc.on.ca

You may also contact the Office of the Privacy Commissioner of Canada if your concern relates to the federal Personal Information Protection and Electronic Documents Act (PIPEDA):

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec  K1A 1H3

Toll-free: 1-800-282-1376

Website: www.priv.gc.ca