Privacy Policy

Lifespire is operated by Lifespire Inc. (the “Operator”). Certain regulated healthcare services available through Lifespire are provided by physicians and other healthcare professionals who are independent health contractors to Lifespire (each a “Professional Corporation”). All other services made available at the Clinic are provided by the Operator and its employees and contractors. Each Professional Corporation and the Operator separately control the personal information that they collect while providing services and will process personal information in accordance with this Privacy Policy. For the purposes of this Privacy Policy, when we refer to “we”, “us” or “our”, we mean each Professional Corporation and the Operator.  

For U.S. Residents

If you are located in the United States, please refer to our U.S. Privacy Policy for information specific to how your personal information is collected, used, and protected in accordance with applicable U.S. laws.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect the following personal information directly from you, unless we have your consent or are legally permitted to collect your personal information indirectly. 

• Your name and contact information (email address, phone number, mailing address)
• Your health information, including medical history, family history, test results, referring physicians, reports, symptoms, diagnosis, treatments performed, prescriptions, clinic attendance, and instructions for care of person or genetic material
• Biomarkers and genetic data information 
• Lifestyle and behavioural data (e.g. sleep, nutrition, activity) 
• Responses to health questionnaires and wellness goals
• App usage and engagement data 
• Communications between you and the Lifespire team
• Billing information, including provincial/territorial health insurance plan (health card) number, private medical insurance details, and credit card information for private payments

If you apply for a job at Lifespire, you may be asked to provide us with certain personal information about yourself, such as your resume, cover letter, or similar employment related materials. We use this information for the purposes of processing and responding to your application and assessing your suitability for current and future career opportunities. 

We may use artificial intelligence, machine learning, and automated decision-making technologies to evaluate and assess your personal information.

We use the personal information we collect to provide the Services. This includes: 

• Providing services you request, providing customer service and support, and processing payments;
• Verifying your identity;
• Contacting your emergency contact in emergency situations;
• Providing personalized health reports, insights and recommendations; 
• Assigning and track tasks to support your longevity goals;
• Sharing test results and summaries with you; 
• Scheduling appointments; 
• Communicating with you about products, services, and events that may be of interest;
• Aggregating or otherwise anonymizing your personal information in accordance with any applicable laws for use for technical, research, and analytical purposes;
• Conducting quality assurance and risk management activities;
• Better understanding how you use the Website, our App and our services, to improve the Website and our services and develop new products or services; 
• Requesting and collecting feedback and responding to requests and complaints; 
• Meeting our regulatory and other legal reporting obligations;
• Managing our business, including to maintain business records for reasonable periods, enforce our agreements, and collecting amounts owing to us.

With your express consent, we may use personal information for marketing and sales purposes, including informing you about unregulated products and services that may be of interest to you, whether provided by Lifespire or our affiliates or third-party partners. Please contact Lifespire if you wish to revoke your consent.   

Where personal information is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described in the “Contact” section below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain parts of our Services.

INFORMATION COLLECTED AUTOMATICALLY

Cookies. The Websites uses cookies (small files containing program code that reside on your computer), to provide usage statistics about the Website, and to understand where visitors learn about the Website. We also may use cookies to simplify the re-entering of your data. You can adjust your browser settings to opt out of the use of cookies by having your browser disable cookies. Look for the cookie options in your browser in the Options or Preferences menu.

Log Files. When you use the Website, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with the Website, domain names, landing pages, and pages viewed, mobile carrier, and similar information. Log files help us to monitor, analyze, improve and maintain the Website and to diagnose and fix technical issues.

Device Identifiers. When you access the Website using a mobile device, we collect information about your device contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We use this information to optimize the Website and fix technical issues.

Analytics. We may use third party service providers like Google Analytics to collect information about your use of the Website, such as the features used and time spent on the Website, to help us better understand our users and improve the Website. The information we gather is used in an aggregate, non-identifiable form. For information about how information is processed in connection with Google Analytics, please read the Google Analytics Policy here

DISCLOSURE OF PERSONAL INFORMATION

Healthcare Professionals. We will share your personal information with licensed healthcare professionals on your Lifespire care team as well as approved laboratories and diagnostic partners supporting our care. 

Professional Corporation and Operator. As described above, certain regulated healthcare services are provided through Professional Corporations and all other services are provided through the Operator. Professional Corporations and the Operator share personal information with each other as necessary for the provision of healthcare services, for billing and administrative purposes (including scheduling), and otherwise to ensure a seamless experience at the Clinic. These records may be comingled to achieve consistency of care and operational efficiencies.

Service Providers. We may transfer personal information to third party service providers that provide certain services on our behalf, such as data hosting and processing, marketing, analytics, information technology services, and payment processing. Some of these service providers may be located outside of Canada, including in the United States. While outside of your jurisdiction of residence, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances. For more information about the way in which our service providers treat personal information, please contact us as set out in the “Contact” section below.

Business Transaction. We may disclose personal information to parties in connection with a corporate transaction, such as a sale, financing or other disposition of all or part of our business or assets, for the purposes of evaluating and/or performing the transaction.  

Other. We may disclose personal information to meet our legal and regulatory obligations or otherwise as permitted or required by law, including to comply with a subpoena or warrant, to law enforcement in connection with an investigation, to protect our rights and the safety and security of our employees, and to enforce our agreements and collect debts owed to us.

With consent. We may disclose your personal information in other circumstances with your consent.  For example, you may request that we share information with your employer sponsored benefits provider or with your lawyer.

THIRD PARTY LINKS

The Website may contain links to other websites that Lifespire does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

SAFEGUARDS

We protect personal information using safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures to protect against unauthorized access, alteration, disclosure or destruction of personal information, through the use of physical (e.g. locking cabinets and restricted access to offices), organizational (e.g. policies, training, access limitations), or technological (e.g. passwords, secure computer networks, encryption, audits) measures. 

We limit access to personal information to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information. Despite these measures, since no system or security measure is completely secure, it is possible that personal information may be lost, stolen or accessed without authorization. 

RETENTION OF PERSONAL INFORMATION

Personal information is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfilment of the purposes for which it was collected, in accordance with prudent business practices on general document retention, or as otherwise required by law. 

YOUR RIGHTS

You may request access to or correction of your personal information in our custody or control. You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us in a structured, commonly used technological format to use for your own purposes or to have transferred to a third party, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. For instance, your restriction may not impede the Professional Corporation from recording personal health information about an individual that is required by law or by established professional standards or institutional practice. To exercise any of these rights, please contact us in writing using the contact information set out in the “Contact” section below.