DATA PROTECTION AND USE POLICY SINGULARITY HEALTH

Introduction

At Singularity Health, we recognize the importance of privacy and trust in the sensitive healthcare environment. As a company located at the intersection of advanced technology and healthcare, we are committed to protecting the personal and health information of our users, including patients, medical professionals, and visitors to our website. Our goal is to empower users with innovative solutions, such as Zaia Health and Florence, while ensuring the integrity, confidentiality and security of their data.

Our focus on chronic patient care through the effective integration of cutting-edge technologies places us in a unique position to significantly improve the quality, efficiency and personalization of healthcare. We understand that this comes with great responsibility in handling sensitive health data, and we are dedicated to meeting the highest data privacy and security regulations in every interaction.

The privacy policies we present reflect our commitment to transparency and responsibility in the collection, use, storage and protection of your information. These policies are designed to inform you about how we collect your information, why we need it, how we use it to improve your experience and health care, and how we protect your privacy throughout this process.

We are committed to continuous improvement and responsible innovation, always with respect for your privacy as one of our fundamental principles. We appreciate the trust you place in us when using our services and we are dedicated to protecting your personal and health information with the utmost care and rigor.

Scope

Singularity Health's privacy policies apply to all interactions and relationships between the company and those individuals who use our services and platforms, including but not limited to:

Patients: Individuals seeking to improve their management of chronic health conditions through our digital solutions.
Health Professionals: Doctors, nurses and other health service providers who use our platforms to monitor, manage and care for their patients.
Visitors to Our Website: Any person who accesses our website seeking information about Singularity Health, its products and services.

These policies apply regardless of how you access or interact with our services, whether through our website, mobile applications, online platforms, telephone or in-person contact, and other available digital or physical means. They cover all Singularity Health operations in the geographic regions where we offer our services, specifically in Canada, Colombia and the United States. We are committed to complying with applicable data protection and privacy laws and regulations in these jurisdictions.

Our focus is on ensuring a safe and reliable experience for all our users, protecting their personal and health information in accordance with applicable legal regulations and industry best practices. As our services evolve and expand, these privacy policies may be updated to reflect changes in our practices or relevant laws. We are committed to communicating any modification in a timely and transparent manner.

By using our services, you accept the practices described in these privacy policies. If you have questions or need more information about our approach to privacy, please do not hesitate to contact us.

Information We Collect

At Singularity Health, information collection is an essential part of our effort to provide personalized and effective technology solutions that improve healthcare for patients and professionals. The information we collect helps us better understand your needs, offer relevant services and continually improve the quality of our solutions. The information collected can be categorized as follows:

Personally Identifiable Information (PII)

We collect information that can be used to personally identify you, such as your name, email address, postal address, telephone number, and other contact information. This information may be collected when you register on our platforms, subscribe to our services, or communicate with us directly.

Health Information

As part of our chronic patient management and health monitoring solutions, we collect information related to your health, including, but not limited to, medical records, information about treatments and medications, test results, and data about your condition. physical and general well-being. This information is essential to personalize your care experience and provide specific recommendations.

User Generated Information

We collect information that you voluntarily provide to us through our platforms, such as logs of symptoms, medications, lifestyle habits, and feedback about your experience with our solutions. This information allows us to adjust our tools to your specific needs.

Technical and Usage Information

When you use our platforms, we collect technical and usage information, such as your IP address, browser type, operating system, pages you visit within our platforms, and the time you spend on them. This information helps us understand how you use our services and identify opportunities for improvement.

Information Collected through Tracking Technologies

We use cookies and similar tracking technologies to collect information about your interaction with our platforms and services. This includes browsing preferences, personalization of the user experience, and effectiveness of our marketing campaigns. You have control over the use of these technologies through your browser settings.

Sensitive information

In certain circumstances, we may collect sensitive information, such as genetic or biometric data, when strictly necessary for the provision of our health services. This information is treated with the highest level of security and confidentiality.

Consent

The collection and use of your personal and health information is always done with your explicit consent. You have the right to withdraw your consent at any time, although this may affect our ability to provide you with certain services.

How we use information

At Singularity Health, we use the information collected with the primary objective of offering and continually improving our healthcare technology solutions, ensuring they are effective, personalized and secure. The information we collect allows us to:

Personalize the Care Experience

Adjust our solutions and recommendations to individual health needs and personal preferences, creating a personalized care plan that contributes to better management of your health.

Improve the Quality and Effectiveness of Our Services

Analyze how our platforms and services are used to identify areas for improvement, develop new functionality and resolve technical problems, ensuring that our solutions are intuitive and meet the needs of our users.

Direct communication

Use your contact information to communicate directly with you, providing important updates about our services, relevant health information or personalized assistance.

Investigation and development

Contribute to research and development in the field of digital health, using anonymized or aggregated data to study health trends, improve treatment practices and develop new technologies that can have a positive impact on healthcare.

User Support and Assistance

Provide technical support and user assistance to ensure a smooth and effective experience with our services, and respond to your questions, comments or concerns.

Protection and security

Implement security measures to protect your information against unauthorized access, misuse or disclosure, guaranteeing the confidentiality and integrity of your personal and health data.

Legal and Regulatory Compliance

Comply with applicable laws and regulations, including, but not limited to, data protection and health regulations. We may use your information to respond to legal requests from competent authorities or in legal proceedings

Marketing and Promotion Information

With your consent, send you promotional and marketing information about our services and solutions, including news, special offers and events that may be of interest to you. You have the right to opt out of receiving these communications at any time.

Importantly, Singularity Health takes a privacy-focused approach to the use of personal and health information, basing all processing activities on principles of legality, transparency, and necessity. The minimum information necessary to fulfill the described purposes will be processed, and we will keep your information only as long as it is necessary for these purposes or as required by applicable laws.

How we share information

At Singularity Health, we understand the importance of maintaining the confidentiality and protection of your personal and health information. We share your information only under specific circumstances and always with the goal of improving health care, complying with our legal commitments, or providing you with improved services. Ways we may share your information include:

Health Service Providers and Clinical Partners

To provide coordinated and complete health care, we may share information with health care professionals and providers involved in your care. This includes, but is not limited to, doctors, nurses, pharmacies and laboratories, always under your explicit consent.

Subcontractors and Service Providers

We may share information with subcontractors or third-party service providers who help us operate our platforms, perform data analysis, provide customer support, or manage email communications. These service providers operate under strict instructions and are required to ensure the security and confidentiality of your information.

Compliance with Laws and Legal Requirements

We may disclose your information if required by law or if we believe in good faith that such action is necessary to comply with legal processes, respond to claims, or protect the rights, property or safety of our company, employees, customers or the public.

Commercial transactions

In the event of a merger, acquisition, restructuring, or sale of the company or its assets, your information may be part of the transferred assets. In such event, we are committed to ensuring that the receiving entity maintains the confidentiality of your information in accordance with its policies.

Express Consent

In addition to the above, we may share your information with other parties with your explicit consent. For example, if you choose to participate in research studies or want your information to be shared with partners for additional services.

Aggregation and Anonymization

We may share anonymous or aggregated information that does not directly identify you with research organizations, business partners or for statistical purposes, ensuring that it cannot be used to identify you personally.

In all cases, we limit information sharing to the minimum necessary to meet our stated objectives and require third parties to protect your information and use it only for the purposes for which it was disclosed. Singularity Health never sells your personal information to third parties for marketing purposes without your explicit consent.

User rights

At Singularity Health, we recognize and respect the importance of your rights related to privacy and the handling of your personal and health information. We are committed to ensuring that you have control over your own information. Under applicable data protection laws, you have various rights, including but not limited to:

Right of access

You have the right to request a copy of the personal information we hold about you. This includes information about how we use your personal information, to whom it has been disclosed, and the purpose of processing.

Right of Rectification

If you believe that the personal information we hold is inaccurate or incomplete, you have the right to ask us to correct or complete this information.

Right to Erasure (Right to be Forgotten)

In certain circumstances, you have the right to ask us to delete your personal information from our records, for example, when the information is no longer necessary for the purposes for which it was collected.

Right to Limitation of Processing

You have the right to ask us to restrict the processing of your personal information, which means that we may continue to store your information, but not use or process it. This is applicable in specific circumstances defined by law.

Right to Data Portability

In certain situations, you have the right to receive the personal information you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller without hindrance on our part.

Right to Oppose

You have the right to object at any time to the processing of your personal information in certain circumstances, including processing for direct marketing purposes.

Right to Not Be Subject to Automated Decisions

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects that concern you or similarly significantly affect you.

Right to Withdraw Consent

Where the processing of your personal information is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Right to File a Complaint

If you have concerns about how we handle your personal information, you have the right to lodge a complaint with a data protection supervisory authority.

To exercise any of these rights, please contact us using the details provided in the contact section of these policies. We may need to verify your identity before we can act on your request.

At Singularity Health, we strive to respond to all legitimate requests in a timely manner and in accordance with applicable laws.

Data security

At Singularity Health, the security of your personal and health information is our top priority. We implement rigorous technical, physical and organizational measures to protect your data against unauthorized access, disclosure, misuse, alteration, loss or destruction. Our comprehensive approach to information security includes:

Data Encryption

We use advanced encryption technologies to ensure that your information is protected both in transit and at rest. This ensures that your data is encrypted and inaccessible to unauthorized third parties.

Controlled access

We limit access to your personal and health information only to employees and third parties who need to know such information to provide our services to you. This access is based on the principle of least need and is granted through secure access controls.

Training and Awareness

We regularly train our employees on the importance of data protection and information security. Our team is committed to best practices in privacy and security management to ensure the proper handling of your information.

Monitoring and Response to Incidents

We implement advanced monitoring systems to quickly detect and respond to any suspicious activity or attempted security breaches. In the event of a security breach, we have procedures in place to act immediately, minimize damage, and notify affected parties in accordance with applicable laws.

Security Reviews and Audits

We conduct regular security reviews and audits to continually evaluate and improve our security measures. This includes evaluating our data processing practices, technological infrastructure and security policies.

Protection against Malware and Ransomware

We use industry-leading security solutions to protect our platforms and systems against malware, ransomware, and other types of malicious software.

Normative compliance

We ensure that our security practices comply with all applicable data protection and privacy laws and regulations. This includes staying up to date with regulations such as GDPR, HIPAA and other relevant data protection laws in the jurisdictions in which we operate.

Although we take every precaution to protect your information, it is important to recognize that no security system is foolproof. We are committed to informing regulatory authorities and you as an affected user in the event of a security breach, in accordance with our legal obligations and in an effort to maintain transparency.

Data retention

At Singularity Health, we are aware of the importance of handling your personal and health data with the utmost care and responsibility. Our data retention policy is designed to ensure that we only retain your personal and health information for as long as necessary to fulfill the purposes for which it was collected, including for compliance with any legal, accounting, or reporting requirements.

Retention Periods

Personal and Health Information: We will retain your personal and health information for as long as you have an active account on our platforms or as long as it is necessary to provide you with our services. After this period, your information will be anonymized or securely deleted, unless it is required to retain it for longer periods due to legal or regulatory obligations.
Information for Legal Compliance: In some cases, we may be required by local laws and regulations to retain certain types of information for a specific period. For example, tax laws may require us to retain records of transactions for a certain number of years.
Research and Development: For research and development purposes, we may retain anonymized or aggregated information that does not directly identify you. This allows us to analyze health trends and improve our services, without compromising your privacy.

Elimination Process

At the end of the applicable retention period, we take steps to delete or anonymize your personal information so that it can no longer be associated with you. This is done in accordance with our data security policies and using deletion methods that ensure that your data cannot be reconstructed or read.

Review of Retention Policies

We regularly review our data retention policies to ensure that they are appropriate and comply with all applicable laws and regulations. This review helps us ensure that we do not retain your personal information longer than necessary.

User Deletion Requests

You have the right to request deletion of your personal information. In such cases, we will delete your information in accordance with our retention policies and applicable laws. However, in certain cases, we may be required to retain your information to comply with our legal obligations or resolve disputes.

Disposal Security

We are committed to ensuring the security of your personal information during the deletion process. The deletion techniques employed are designed to prevent unauthorized access to or recovery of any deleted information.

At Singularity Health, your privacy is our priority. We strive to handle your information with the utmost care throughout its lifecycle, from collection to retention and eventual deletion.

Changes to privacy policies

At Singularity Health, we are committed to continuous improvement and adaptation to changing data privacy and security regulations, emerging technologies, and the needs of our users. Therefore, it is important to recognize that our privacy policies may be updated periodically.

Updates and Revisions

Periodic Review: We will review our privacy policies regularly to ensure that they remain relevant and effective, taking into account new laws and regulations, changes in our operations or business practices, and the development of new technologies.
Significant Changes: Any significant changes to our privacy policies will be clearly communicated to our users prior to their implementation. This may include, but is not limited to, changes in the way we collect, use or share your personal information.

Notification to Users

Notification Methods: We will use various methods to notify you about changes to our privacy policies, including email, notifications within our platforms, or a prominent announcement on our website.
Access to the Updated Version: The most recent version of our privacy policies will always be accessible on our website, with a “last updated” date so you know when changes were last made.

Acceptance of Changes

Consent and Acceptance: By continuing to use our services after the implementation of changes to our privacy policies, you will be deemed to have read, understood and accepted the updated terms. If you disagree with the changes made, you are free to stop using our services.

At Singularity Health, we understand the importance of the privacy of your information and are dedicated to protecting it. We appreciate your trust in us and we strive to maintain that trust through transparency and commitment to the privacy and security of your data.

Contact

At Singularity Health, we welcome your questions, comments, and any concerns related to the privacy and security of your personal and health information. If you need more information about our privacy policies, have specific questions, or wish to exercise any of your data protection rights, our team is here to assist you.

Contact information

For any questions regarding our privacy policies or the handling of your personal and health information, please contact us:

Email: info@singularity.health
Website: https://www.singularity.health
Postal Address: 605 - 1477 Continental Street, Vancouver, Canada ZIP V6Z 0G4

Customer Support

Our customer support team is available to provide you with any necessary assistance regarding your privacy concerns or to guide you through the process of exercising your rights. Please feel free to contact us via the email provided.

Presentation of Complaints

If you have any complaints about how we handle your personal and health information, we encourage you to contact us first, so we can address your concerns directly. Additionally, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

Suggestions and comments

We are committed to continually improving our privacy and security practices. If you have suggestions or comments on how we can improve, we would appreciate it if you would take the time to share them with us.

At Singularity Health, your privacy is our priority. We are committed to keeping communication channels open and responding in a timely and effective manner to all your queries.