OPTIMITY PRIVACY POLICY
Updated: January, 1 2021

OPTIMITY Inc. wants to ensure that you are aware how we collect and use information you supply to us when using our service. In this policy we explain what data we collect about you and how we store, analyze and share the data through OPTIMITY’s website and mobile application.

INTRODUCTION
OPTIMITY’s online tool enables you to better manage your health and wellbeing (the “Service”). In this policy, "OPTIMITY Inc. (“Us”,”We”,”Our”, “OPTIMITY”) and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership.

.This Privacy Policy describes:

By accepting our Privacy Policy and Terms of Service in registering to use our Service, you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. If you do not consent to the collection, use and disclosure of your information as described in this Policy, you will not be able to use the Service.

INFORMATION WE MAY COLLECT
Information we receive about you
OPTIMITY may request and store information used to personalize the user experience as allowed by you and your preferences, such as, but not limited to:

By using the Service you are authorizing OPTIMITY to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the third party could provide to OPTIMITY. Your agreement takes place when you "accept" or "allow" (or similar terms) one of our applications.

Devices and Third Party Apps
As a user of the Service you may be able to connect activity and health trackers (“Devices”) to your account. These devices and applications can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity as well as your nutrition. In general, these Devices have specific privacy policies that outline what data they collect. We strongly suggest you review the right privacy policy to know what specific data points your activity tracking device collects about you.

Information We Collect from You Directly
When you interact with the Service (whether or not on a third party site) We may collect and store information from you directly as described below.

Registration Information
We may allow you to “register” with Us by using our Service directly and not through a third party site. We may provide a typical registration flow where you may be required to provide the following information: your first and last names; your e-mail address; a password and other information that helps Us confirm that it is you accessing your account.

We may also offer you the option to complete a user profile that is visible to other users of our Service. Your user profile may include: a profile photo; one or more Service username(s); details about your nutrition and fitness activity; and a user ID number that we create which is used to identify your profile.

The OPTIMITY user ID number used to identify your account and profile will be public to users in your company and will appear in the URL of your profile page, but will only permit access to information that is considered public or that you have designated as public in your settings.

Your first and last names and profile picture are considered "public" on OPTIMITY websites that offer direct access to OPTIMITY Services and search engines may index this publicly available information. When We offer profiles, We will also offer functionality that allows you to opt-out of public indexing of your public profile information.

Information We Receive or Collect When You Access OPTIMITY Services on a Mobile Device
If you use OPTIMITY Services on your mobile device or other device when you use our Service, We collect your mobile device identifier and IP Address. In certain Services We will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, country, and any other information you choose to provide, such as user name, character name or e-mail address.

Technical and Usage Information
When you access our websites or use our Services, We collect (i) certain technical information about your mobile device or computer system, including IP Address and mobile device ID; and (ii) usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files (“Log Files”), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how We utilize cookies and other tracking technologies please review the "Cookies and Automated Information Collection" portion of Section 3 ("How We Collect Information about You").

HOW WE COLLECT INFORMATION ABOUT YOU
We may collect information about you in any one or more of the following ways:

Information about Users and the Services they use
When you use one of our Services, OPTIMITY collects and stores certain information that you provide directly or through the third party website that is offering our Service(s). How we use the Information We collect depends in part on which Services are offered to you, which Services you use, how you use them and any preferences you have communicated to us.

Communications Features
You may be able to take part in certain activities on our Services that give you the opportunity to communicate or share information not just with OPTIMITY, but also with other users of our Service. These include:

We may record and store archives of these communications on OPTIMITY's servers or alternatively on a third party service provider’s servers, to protect the safety and wellbeing of our users and OPTIMITY's rights and property in connection with the service. If your activities take place on third party sites then your communications may be stored on those sites and is subject to the privacy policies of those third party sites. You acknowledge and consent to the recording and storage of such communications for these purposes.

Cookies and Automated Information Collection
When you access the Service, We collect certain technical information in order to (i) analyze the usage of our sites and services; (ii) provide a more personalized experience; and (iii) manage testimonials.

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow.

Other Sources
We may collect or receive information from other sources including third party information providers. This information will be used to supplement your profile - primarily to help you and your friends connect. It will be combined with other information We collect.

HOW WE USE THE INFORMATION WE COLLECT
In general, We collect, store and use your information to provide you with a safe, smooth, efficient, and customized experience. For example, We may use information collected from you in any one or more of the following ways:

One important use of your information is communication. If you have provided your e-mail address to OPTIMITY, We'll use it to respond to (i) customer support inquiries, and (ii) keep you informed of your activity, including comments and invites from friends. Some messages, such as invites for friends to join you, may include your name and profile photo. We may also send promotional e-mail messages ("Promotional Communications'') directly or in partnership with parties other than OPTIMITY. Each Promotional Communication will generally offer recipients choices about receiving additional messages.

SHARING OF YOUR INFORMATION
We may share your Information with third parties so we can provide our services to you. If we need to share your Information with third parties, we will limit the Information to the minimum amount necessary to ensure the provision and quality of the Services we offer you.

Third Party Service Providers
We will provide your information to third party companies to perform services on our behalf, including payment processing, data analysis, e-mail delivery, hosting services, customer service, connector services and data integration to assist Us in our marketing efforts. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on OPTIMITY's behalf.

Third Party Partners
We may ask for your consent to disclose your personal information collected by Optimity (including health data or biometric data) to our third party partners, such as Insurers and reinsurers, who will use your information for the following purposes:
research and analytics related to government, research organizations, insurance, reinsurance, and other organizations;
building predictive models related to government, research organizations, insurance, reinsurance, and other organizations for commercial purposes;
anonymization of your personal information; and
use in underwriting, application assessment and/or claims assessment related to life or accident and sickness insurance for individuals.

These partners may transfer your personal information to their affiliates and/or third party services providers, which may be located outside of Canada. The privacy laws in these countries may differ from those in Canada and your personal information may be subject to access by, and disclosure to, foreign courts, law enforcement and security authorities as required by applicable foreign legislation. You can withdraw your consent at any time (subject to legal or contractual obligations and on providing us reasonable notice) by contacting our Privacy Officer at support@myoptimity.com. If you choose not to consent to providing personal information to our third party partners, certain features or services may be unavailable or not function properly.

Third Parties that Have Purchased OPTIMITY Services on Your Behalf
We will provide information for aggregate reporting to third party companies who have purchased OPTIMITY Services on your behalf, including aggregate participation in events, aggregate interests, aggregate health conditions, aggregate health objectives, improvements in aggregate health statistics. Our collection, use, and disclosure of anonymous or aggregated information are not subject to any of the restrictions in this Privacy Policy. For OPTIMITY provided by an insurance carrier user explicitly agrees to share personal data provided to OPTIMITY through the application and related connected devices with the insurance carrier for the sole purpose of the insurance carrier to provide valuable personalized advice and products, based on the information collected.

SAFETY, SECURITY AND COMPLIANCE WITH LAW
Your information, and the contents of all of your online communications (including without limitation chat text, voice communications, IP addresses and your personal information) may be accessed and monitored as necessary to provide the Service and may be disclosed: (i) when We have a good faith belief that We are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations (iii) where We believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when We have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect the rights or property of OPTIMITY, including to enforce our Terms of Service.

SALE OR MERGER
In the event that OPTIMITY undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, We may transfer all of your information, including personal information, to the successor organization in such transition. If material changes to OPTIMITY's privacy practices will occur as a result of the business transition, We will notify you and other users (in the manner described in Section 12) of the business transition prior to transferring your personal information.

OUR POLICIES CONCERNING CHILDREN
Our Services are not intended for children under the age of 13 and We do not knowingly collect any personal information from such children. Children under the age of 13 should not use our Services at any time. In the event that We learn that We have inadvertently gathered personal information from children under the age of 13, We will take reasonable measures to promptly erase such information from our records.

HOW TO ACCESS AND UPDATE YOUR INFORMATION
Information We Receive From a third party site when You use Our Service

To manage the information OPTIMITY receives about you from a third party site where you use our Services, you will need to follow the instructions at that site for updating your information and changing your privacy settings. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.

Once OPTIMITY receives your information from a third party site, that information is stored and used by OPTIMITY in accordance with this Privacy Policy, and you may access and update that information as described below. User accounts created with OPTIMITY are considered active until We receive a user request to delete them or deactivate them.

Other Methods of Accessing and Controlling Your Information
If you no longer want OPTIMITY to make active use of your information, you may send an e-mail to support@myoptimity.com. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and user ID number for the third party site from which you access our Services (if applicable) in the body of the e-mail. We will respond to your request within thirty (30) days.

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To figure out the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, the applicable legal requirements, and regulatory retention periods. If you have sent or posted content on the Service, We may not be able to delete it.

When you delete data, we follow a deletion process to make sure that your data is safely and completely removed from our servers or retained only in anonymised form. We try to ensure that our services protect information from accidental or malicious deletion. Because of this there may be delays between when you delete something and when copies are deleted from our active and backup systems.

If you wish to review or change the information OPTIMITY has about you, e-mail Us at the address provided herein.
If you have additional questions about this Privacy Policy, contact Us at support@myoptimity.com


YOUR SHARING AND MESSAGING OPTIONS
Information We Receive from Third Party Sites Where You use an OPTIMITY Service
If you use our Services at a third-party site, OPTIMITY will be able to access and store profile and other information about you as described above. The categories of information you share with Us will depend, in part, on the permissions you grant Us and the privacy settings you have established at the third party site where you access the application. OPTIMITY does not offer an "opt out" option for specific fields that are shared by the third party site where you access and use the Service(s).

Opting Out of Other Communications
When you install our apps on your mobile device you can choose to receive push notifications. You can turn off push notifications by visiting the “options” or “settings” page within the relevant Service. You may also receive local notifications. You can turn off local notifications by visiting the “options” or “settings” page within the relevant Service.

We may e-mail or communicate with you from time to time if We need to provide you with information or if We need to request information from you with respect to a transaction initiated by you or for other legitimate non-marketing reasons.

SECURITY OF YOUR INFORMATION
At OPTIMITY we take your privacy and data very seriously. We follow strict security and compliance standards not only because we need to meet specific regulations, but because we consider it one of the most important things we can do for you.

We are committed to the protection of customer information. In the event that We are aware of a breach of information We will inform you and your employer of the breach.

For user accounts registered directly with OPTIMITY profile information is protected by the password each member uses to access their online account. It is important that you protect and maintain the security of your account and that you immediately notify Us of any unauthorized use of your account. If you forget the password to your OPTIMITY account, the website allows you to request that instructions be sent to you that explain how to reset your password. When you sign into your account or enter payment information (such as a credit card number when purchasing virtual currency), We encrypt the transmission of that information using secure socket layer technology ("SSL").

While We take reasonable precautions against possible security breaches of our websites and our customer databases and records, no website or Internet transmission is completely secure, and We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If your third party site account is hacked, this may lead to unauthorized use of OPTIMITY Service you have registered to use, so be careful to keep your account information secure. If you have questions about the security of our websites, please contact Us at support@myoptimity.com.

Unfortunately, the transmission of information over the Internet is not completely secure. Although We strive to protect your personal data, We cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once We have received your information, We have procedures and security features in place to try to prevent unauthorized access.

FOREIGN USE OF THE SERVICE
To the extent that you are accessing the Service while domiciled outside of the United States, you acknowledge that the Personal Information you are providing Us is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information outside of your domiciled country and in the United States.

CALIFORNIA PRIVACY DISCLOSURES
If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act ("CCPA").

In accordance with California Civil Code Section 1789.83, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: http://www.ftc.gov. If you have questions about this policy, please contact us at support@myoptimity.com.

RIGHT TO ACCESS
Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law. Please submit any requests for access to your personal data in writing to support@myoptimity.com.

CHANGES TO OUR PRIVACY POLICY
If We decide to make material changes to our Privacy Policy, We will notify you and other users by placing a notice on myOptimity.com or by sending you a notice to the e-mail address We have on file for you. We may supplement this process by placing notices in our Services. You should periodically check myOptimity.com and this privacy page for updates.

CONTACT US
If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us at:

Attention: Data Protection Officer
Optimity Inc.
91 Oxford St, Toronto, Ontario
M5T 1P2

All other inquiries should be directed to OPTIMITY's Feedback Page or support@myoptimity.com