SPARROW HEALTH INC. (“Company” or “We”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website users (“you“) .
• Describes the types of information we may collect from you or that you may provide when you visit the website sparrowhealth.ca (our “Website“ ).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Privacy laws in Canada generally define “personal information” 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. Personal information does not include business contact information, including your name, title, or business contact information.

Privacy laws in Canada generally define “personal health information” as information about an identifiable individual, if the information:

• relates to the individual’s physical or mental health, including family health history;
• relates to the provision of health care, including the identification of persons providing care;
• is a plan of service for individuals requiring long-term care;
• relates to payment or eligibility for health care;
• relates to the donation of body parts or bodily substances or is derived from the testing or examination of such parts or substances;
• is the individual’s health number; or
• identifies an individual’s substitute decision-maker.

Any other information about an individual that is included in a record containing personal health information is also included in the definition.

This policy applies to information we collect, use, or disclose about you:

• On this Website;
• In email, text, and other electronic messages between you and this Website;
• Over the telephone;
• Over Ontario’s Health Report Manager from electronic medical record providers; or
• To or from your physician or other health care practitioner.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, and any other identifier we may use to contact you (“personal information“).
• Personal Health Information, that we obtain from you or your authorized health care practitioner that we use to process your orders such as your provincial health card number, prescription information and prescription history, health and medical information and health and medical history, family health history, names and contact information for persons providing care;
• Non-personal 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 a specific Website feature.
• Technical information, including 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 Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), 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.

We use different methods to collect your information, including through:

• Direct interactions with youwhen you provide it to us, for example, by filling in forms or corresponding with us by phone, email, in person or otherwise.
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Direct interactions with your physician and other health care practitioners, who you authorize to provide such information to us.

Ontario’s Health Report Manager, from electronic medical record providers, in accordance with its policies and procedures.

Information You Provide to Us

The information we collect directly from you may include:

• Information that you provide by filling in forms on our Website or uploading documents on our website. This includes information provided at the time of registering to use our Website, subscribing to our service, and/or requesting further services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Information that you provide to us over the telephone or in person.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

Information Received from Third Parties

The information we collect from third parties may include:

• Information that is provided to us by authorized health care practitioners including your physician.
• Records and copies of correspondence with authorized health care practitioners.
• Information received from Ontario’s Health Report Manager from electronic medical record providers.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our Website, 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 our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate number of users and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. 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 Website.
• Flash Cookies.Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
• Web Beacons.Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use information that we collect about you or that you provide to us, including any personal information and personal health information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To improve our Website, products or services or customer relationships and experiences.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information and personal health information that we collect or you provide as described in this privacy policy:

• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• 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 Website improvement and optimization) 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 policy.

We may also disclose your personal information and personal health information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our TERMS OF USE and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SPARROW HEALTH INC., our customers, or others.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.

The security of your personal information and personal health information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information and personal health care information from accidental loss and from unauthorized access, use, alteration, and disclosure. [We store all information you provide to us behind firewalls on our secure servers. Any payment transactions [and [OTHER INFORMATION]] will be encrypted [using SSL technology].]

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 of our Website, you are responsible for keeping this 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 and personal health information, we cannot guarantee the security of your personal information transmitted to our Website. 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 the Website.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information or personal health information changes. By law you have the right to request access to and to correct the personal information and personal health information that we hold about you.

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information or personal health information you may also send us an email at [EMAIL ADDRESS] to request access to, correct, or delete any personal information or personal health information that you have provided to us. We cannot delete all of your personal information and personal health information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information and personal health information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information and personal health information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information and personal health information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.

Information that is prohibitively expensive to provide.

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us by mail at Suite 205 – 2009 Long Lake Rd, Sudbury, ON, P3E6C3 or by phones or fax at 706-674-3503 or 705-674-1729 respectively. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information or personal health information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

policies@sparrowhealth.ca

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws.