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HALEO Privacy Policy

Last Updated : 2023-05-01
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HALEO Preventive Health Solutions Inc. (“HALEO” or “we” or “us” or “our”) provides this Privacy Policy (“Privacy Policy”) to inform you (“User” or “Users” or “you”) of our policies and procedures relating to the collection, use, disclosure, maintenance and protection of personal data and information we receive from Users who use the HALEO services (the “Services”) made available via the websites haleoclinic.com, haleo.ca, haleo.clinic and all related subdomains (the “Websites”), as well via the mobile applications which we may own or operate currently or in the future (the “Apps”). We will only use your Personal Information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
This Privacy Policy DOES NOT apply to information that we collect offline or through any other means, or that you provide to or is collected by any third party (including our affiliates and subsidiaries) through any application or content (including advertising) that may link to or be accessible from or via any of our Websites and Apps.
Unless otherwise stated, the terms used in this Privacy Policy have the same meaning as in our Terms and Conditions of Use. Be sure to return regularly to this page for the latest version of the Privacy Policy. We reserve the right at any time, in our sole discretion and without any liability, to update or modify the Privacy Policy without notice, and your continued access to or use of the Services means that you agree to the Privacy Policy. If we change the Privacy Policy, we will update the “Last Updated Date” at the top of the document. By continuing to access or use the Services, you indicate that you agree to be bound by the Privacy Policy. If the Privacy Policy does not seem acceptable to you, please do not use the Services.

Information we collect about you

When you use the Services, we collect and use several types of information from and about you, including:
Non-Personal Information: information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing any specific feature from any of our Websites or Apps. This type of information will not allow you to be personally identified.
Personal Information: “personal information” is generally defined as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. To use the Services, you must first provide such personal information that will allow you to be identified (“Personal Information”). This type of information will not be collected without your consent. For certain parts of the Services, such as creating an account, we collect Personal Information that you voluntarily provide to us using the Services, and could include information such as your name, email address, telephone number, mailing address, date of birth and personal information in relation to your health. We may obtain Personal Information about you through other third parties, such as when you register with such party to participate in any of the Services they offer via their website or their mobile application.  We may also automatically import some of the Personal Information that you provide to such third parties into your account to use our Services. Our Websites, their subdomains and our Apps may also include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling or accepting those connections may allow such third parties to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin or service, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites or services, and we encourage you to read the privacy policy of each one before visiting, enabling or accepting.
Technical Information: such information includes your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Websites and/or Apps, and usage details.
Non-personal details about your Website or App interactions: such information includes the full Uniform Resource Locators (URLs), clickstream to, through and from any of our Websites and Apps (including date and time), products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies: As you navigate through and interact with our Websites and/or install, download or use the Apps, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
  • Details of your visits to, and use of, our Websites and Apps, including traffic data, location data, and other communication data and the resources that you access and use via the Websites or Apps.
  • Information about your mobile device and/or computer and internet connection, including your IP address, operating system, and browser type.
  • Metadata and other information associated with other files stored on your device (when using our Apps). This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
The information we collect automatically is statistical information and may include Personal Information, and we may maintain it or associate it with Personal Information that you provide to us,  or receive from third parties. It helps us to improve our Websites and Apps and to deliver better and more personalized Services, including by enabling us to estimate our audience size and usage patterns,  store information about your preferences, allowing us to customize our Websites and Apps according to your individual interests,  and recognize you when you return to our Websites or Apps.
The technologies we use for this automatic data collection may include, but are not limited to:
Cookies (or browser cookies): A cookie is a small file placed on the device that you are using. Whether it is a desktop computer or a mobile device, you may refuse to accept browser cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of our Apps or Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites or Apps; and 
Web Beacons: pages of our Websites, our Apps, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages, used the Apps or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

How we collect information about you

We use different methods to collect your information, including through:
  • Direct interactions with you when you provide it to us, for example, by filling in forms, creating an account or corresponding with us by phone, email, or otherwise;
  • User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website or App users or third parties;
  • Automated technologies or interactions, as you navigate through our Websites or use our Apps. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
  • Third parties or publicly available sources, for example, our business partners.

Purpose and Use

The purpose of the collection of personal information is to:
  • Provide, maintain, execute and improve the Services;
  • Create your account and access the Services;
  • Perform internal operations, including, for example, preventing fraud and abuse of our Services to resolve software problems and operational problems, to perform data analysis, testing and research and to monitor and analyze trends in use and activity;
  • Send you our newsletter or any other communication that may be of interest to you, including information about products, services, promotions, and news, and for marketing campaigns destined to our users that promote our products and services, or to offer you the products and services of our trusted partners, provided that you have given your explicit consent to receive such communications, which consent you can withdraw any time by following the unsubscribe link provided in such communications;
We expressly acknowledge that we will not use your Personal Information for any other purpose without your consent. We will only collect Personal Information to the extent necessary for the purposes described above.
Personal Information may be used and disclosed to the extent that HALEO may reasonably consider it necessary to enforce the terms of an agreement between you and HALEO, or to protect the rights, property or security of any person or entity or, if required by law, in particular, in response to a request from government authorities. In addition, certain Personal Information or personal health information may be anonymized or aggregated for purposes of research or development of the Services.

Right to Examine Information

You have the right to review the Personal Information we collect. If you would like to review this information, please send a written request to data.officer@haleoclinic.com. We reserve the right to charge you a reasonable administrative fee to access your information in accordance with applicable laws. In some cases, we may not be able to give you access to all of your Personal Information (eg, if the information also relates to another Customer’s Personal Information).

Promotional Communications

You may choose not to receive promotional messages from us by following the instructions in these messages. If you unsubscribe, we may still send you non-promotional communications, such as those about your account, the Services you requested, or our current business relationships.

Sharing Information

We do not sell, rent or disclose to third parties the information we collect and store. You can expect us to share the information collected with other parties as follows:
  • Affiliated Service Providers: We have agreements with various third-party affiliated service providers to facilitate the delivery of our Services, where we may share the information we have collected. All the administrative service providers we use are required to have the same level of privacy protection as ours. Therefore, we expect your information to be treated with the same level of attention that we use.
  • Statistical Analysis: We may share Non-Personal Information and information that has been anonymously aggregated with third parties, including but not limited to statistical, machine learning, advertising, or marketing purposes.  No personal information will be shared in this way.
  • Transactions: Transactions occur in connection with or during negotiations of a merger, sale of assets of the corporation, any financing or acquisition, or any other situation in which Personal Information may be disclosed or transferred as one of our corporate assets. However, under no circumstances will these transactions permit the use of your information for purposes other than those for which you have given us your consent.

Transferring your Personal Information

We may transfer personal information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with the improvement and optimization or our Websites and Apps) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Privacy Policy.
We may process, store, and transfer your Personal Information in and to countries other than Canada, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
In addition, our Services may integrate with online platforms of third parties that provide marketing and management tools to companies to help us deliver the Services to you, which means in such cases that your Personal Information may be shared with such third parties to provide the Services.
By submitting your Personal Information or engaging with any of our Websites or Apps, you consent to this transfer, storage, or processing.

Third Parties Authorized to Receive Personal Information

Third-party service providers have their own privacy policies and terms of service, and we do not accept any responsibility or liability for these policies. We do not control these third-party services, and we encourage you to review the privacy policies and terms of service of each one that you use.

Data Security

The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts or features of our Websites and/or Apps, you are responsible for keeping such password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via our Websites or Apps. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Websites or within our Apps.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, 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. Under some circumstances we may anonymize your Personal Information 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 or your consent.

Employees, Agents and Self-Contractors

HALEO employs other companies and / or individuals to perform functions on its behalf. For example, we may appoint third parties to develop software applications and / or database functions or to send communications on our behalf. Your Personal Information may be disclosed to such persons during the course of HALEO’s business operations. All HALEO employees and all agents, affiliates and contractors working for HALEO who have access to your Personal Information are required to protect such information in a manner that is consistent with this Privacy Policy.

Third Party Tracking Technologies

Some content or applications on our Websites and Apps, which may include advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites or Apps. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We are not responsible for the privacy practices of other websites or online services that you may click when you use our Services and encourage you to read their privacy statements.

Contact Us

If you have any questions, comments, or concerns about this Privacy Policy, send us an email at data.officer@haleoclinic.com.

Privacy Commissioner

If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may send us an email at the email address of the privacy officer to request access to, correct, or delete any Personal Information that you have provided to us.

Privacy officer

Quentin Gay


Where a User has provided their consent to the collection, use, and transfer of their Personal Information, the User may have the legal right to withdraw such consent. To withdraw consent, if applicable, contact the Privacy Officer. Please note that if the User withdraws consent, we may not be able to provide the User with products or services. Upon receipt of the email by which you withdraw your consent, we will stop using your Personal Information within a reasonable period of time, which will vary based on the information we have collected and for what purpose we have collected it. Please note that we will send you a confirmation email upon receipt of your request.


The Services are not intended for persons under 18 years of age. If HALEO realizes that Personal Information about people under the age of 18 has been inadvertently collected, it will delete it without delay.

Terms and Conditions of Use

This Privacy Policy is incorporated into and forms an integral part of our Terms and Conditions of Use, which set out the terms and conditions you agree to abide by using the Services and which are located at the bottom of most pages of our Websites.
HALEO’s Policy and General Practices are designed to ensure compliance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”, SC 2000, c.5) of Canada and the Act respecting the protection of personal information in the private sector (CQLR c P-39.1) of the Province of Quebec. If you have any questions regarding compliance with these laws, please contact us at the above address.