Privacy and Security Policy

VIVER HEALTH INC. is committed to protecting your privacy. This Privacy Policy explains our information processing practices. It applies to any personal information you provide to Viver Health Inc. and, subject to local law, any personal information we collect from other sources.

This Privacy Policy describes the principles that we follow to ensure that we protect Personal Information that we receive, collect, use or disclose in the course of carrying on our business. All of our employees who have access to Personal Information must adhere to this Privacy Policy and related procedures.

By submitting your Personal Information to us through your use of our website or otherwise, you signify your consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any Personal Information to us through the website or any other manner.

What is Personal Information

“Personal Information” is information about an identifiable individual. However, it generally does not include business contact information when used to contact a person in respect of their business role or function. Sometimes we will de-identify information in order to use and share that information for our business purposes in a way that does not identify you. For example, we may aggregate your personal information with other individuals to prepare claims statistics.

Why We Collect, Use and Disclose Personal Information

Collecting personal information about you is essential to our being able to provide the products and services that best meet your needs (including individuals associated with you, all of whom we refer to as “client” in this Privacy Policy). While the personal information we collect may come directly from you, it may also be provided by our affiliates or other third parties (such as employers, insurance companies, insurance brokers or advisors, credit organizations, motor vehicle and driver licensing authorities, financial institutions, medical professionals, etc.).

Personal information may be used for the following purposes:

• To determine eligibility and process applications for products and services and to provide information and services
• To understand and assess ongoing needs of Clients and potential Clients and offer products and services to meet those needs
• For communication, service, marketing, billing, and administration
• For fraud detection and prevention
• For analytics purposes
• To develop proprietary tools and databases
• To provide consulting services to insurance companies
• To comply with legal, audit, security, and regulatory requirements

Other purposes disclosed in our terms of business or disclosed to you at the time of collection, use or disclosure.

What Information We Collect

Depending on the products or services you request, we may collect information that you provide on applications for products and services, such as your first name, last name, email address, company, company size, role, and phone number. To assess risk or if you make a claim, we may collect information from insurers, industry associations, claims adjusters, and consumer reporting agencies.

We may also automatically collect information through our marketing programs through the use of cookies, beacons and other technologies that track how you use our website and marketing communications.

Consent To Use Personal Information

We may obtain your express consent, or we may determine that consent has been implied by the circumstances. Express consent can be verbal (in person or over the telephone), written or by electronic application (including email). Implied consent occurs when we can assume you have given consent by some other action you take or decide not to take. For example, if you request a specific product or service and provide us personal information in that regard, we infer that you consent to us using that personal information reasonably to provide this service.

If you need to provide personal information about other individuals (such as employees, dependents, etc.), you must obtain their consent for these purposes prior to your disclosure to us.

When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described above. Your consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is withdrawn, and then subject to legal or contractual restrictions and reasonable notice. You should note that by withdrawing your consent, or not providing it in the first place, you may limit or even prevent us from being able to provide you or an authorized third party (such as an employer) with the products or services desired. However, we may collect, use or disclose Personal Information without an individual’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law, or where you violate our Website Terms of Use.

In certain circumstances, refusing to provide personal information or withdrawing consent will mean that you will not be entitled to insurance policy issuance or renewal, insurance underwriting or claims administration of existing policies. Additionally in certain circumstances, we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. For example, this exception would apply if there is an emergency that threatens the life, health or security of an individual, for fraud detection or prevention, or if we must comply with a court order.

Sharing Personal Information With Others

Viver Health Inc. only discloses personal information as is required and described in this Policy or as otherwise required by law. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other service providers or advisors who perform various functions for us. Such parties may be located in Canada, or in other jurisdictions outside of Canada. While your personal information is always subject to confidentiality obligations, while stored in another jurisdiction, it may be subject to the laws of that jurisdiction.

Depending on the products or services that we provide to you, we may disclose personal information to insurance companies, reinsurers and other parties who have a need for the information in order to make available insurance coverage and other products and services. We also share information with claims adjusters and insurers in order to settle claims. If we are legally entitled to do so, we may share information with consumer reporting agencies, insurance reporting agencies and governmental authorities when requested to do so or in order to protect our business. We may also be required by law or by rules of arbitration or rules of court to share information.

Viver Health Inc. develops and uses proprietary platforms and databases to gather, store and use information about insurance policies, including, but not limited to, names, industry codes, policy types, premium and policy expiration dates as well as information about the insurance companies that provide coverage to its clients or compete for its clients’ insurance placements. Viver Health Inc. uses and combines this information and other information collected from Viver Health Inc.’s clients for the purposes of developing Viver Health Inc.’s products and services and Viver Health Inc.’s relationship with its clients (for example: benchmarking, market research, data analysis, and marketing of products and services that may be of interest to Viver Health Inc.’s clients) and to help insurance companies to strengthen their offerings for Viver Health Inc.’s clients. The databases may be accessed by Viver Health Inc. and Viver Health Inc. affiliates to provide consulting or other services to insurance companies for compensation as well as for other purposes described in this Privacy Policy.

As Viver Health Inc. continues to develop and grow, we may buy or sell parts of a business. As our businesses consist primarily of client relationships, information regarding the particular accounts or services being purchased or sold could include personal information and be one of the transferred business assets. We may also use this personal information to assess your future needs and to offer the products and services that may best meet those needs, from ourselves, our affiliates or reputable organizations selected by us. If you do not wish to receive these offers or such information, please contact our Privacy Officer as outlined below in the Contact Information section.

Keeping Information On Accurate

It is important that your personal information is accurate and complete. Having accurate information about you enables us to give you the best possible service. You have the right to access, verify and amend the information we have about you. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly. To keep personal information up to date, please inform us of any changes, such as a change of address, telephone number or any other circumstances by contacting your local office representative.

How We Safeguard Personal Information

We will use reasonable efforts and security measures to protect Personal Information against loss or theft, as well as unauthorized access, use and disclosure. We have controls in place to maintain the security of our information and information systems. Files containing Personal Information are stored according to the sensitivity of the information contained therein and are backed up at offsite locations. Appropriate technological controls (such as passwords, encryption, firewalls) are placed on our computer systems and data processing procedures. Physical controls (such as locked filing cabinets, restricting access to offices, alarm systems) are in place as are organizational controls (such as staff training and access on a “need to know basis”).

All client information is processed and stored in servers and data centres geographically located within Canada and is never transported outside Canadian geographical boundaries. To the extent we employ third-party service providers to store, access, handle, or process Personal Information on our behalf; we will use contractual and other means in an attempt to provide a comparable level of protection. Service providers, however, may be located in various countries, so please be aware that authorized officials of governments in those countries may be lawfully able to access your Personal Information without your knowledge or consent pursuant to the laws of such countries.

Employees are governed by strict standards and policies to ensure that personal information is secure and treated with the utmost care and respect.