PRIVACY POLICY

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Last updated: June 1, 2024

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The words and phrases used in this Policy have the same meaning as in Actic’s Terms and Conditions. You can also find a list of definitions at the bottom of this Policy or if you still have questions, contact our Privacy Officer as indicated below.

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Actic Incorporated (“Actic”, “we”, “us”) uses a number of safeguards to protect the privacy ofUsers of the Actic Platform and the confidentiality of their Personal Information including Personal Health Information (collectively referred to together in this Privacy Policy as“Information”). When discussing Services, Information typically refers to Personal HealthInformation (“PHI”).

The agreement between Actic and Authorized Providers providing services through the Actic Platform, (Actic Services Agreement) and the Terms of Conditions for the Actic Platform explain the Services that Actic provides to Authorized Providers and to Users respectively.

This Privacy Policy (“Policy”) summarizes how Actic collects, uses, discloses, retains, disposes of, destroys, and protects Information as well as Data (information that does not identify an individual) in the course of providing our Services. We are committed to complying with thisPolicy and with applicable Provincial and Federal privacy legislation.

Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Providers. Authorized Providers are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use, and retain in the course of providing Services through the Actic Platform. Please feel free to ask any Authorized Provider if you have questions about how he, she or they will treat your Information.

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COLLECTING AND USING INFORMATION

Actic provides analysis that informs treatment options and recommendations that may be carried out at the option of your disability insurer, rehabilitation provider and/or family doctor(the “Services”). We do so through web-based and mobile application platforms. Actic collects and uses Information only as necessary to provide our Services, including to develop, assess, and improve our Services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes.

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SERVICES INFORMATION

Actic collects and uses Information that you provide in the course of obtaining Services, by viewing the information that you have entered or uploaded to the Actic Platform and by creating or compiling Information in the Actic Platform. The Information that they collect, and use includes: the details provided by you and/or your insurance provider when your file was registered such as name, gender, date of birth and place of residence. Authorized Providers are bound to comply with privacy legislation applicable to providers of Services.

Actic provides Users with a one-time secured link that may not be used again. Actic may require additional authentication to ensure each User has been correctly identified before accessing the Platform.

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PROVISION OF THE ACTIC PLATFORM

• We collect and use your Information to authenticate you while using the Actic Platform.We confirm your eligibility to use the Actic Platform for Services by asking you to confirm your place of residence/date of birth/ Health Card number that you provide when your case was registered.
• You may also choose to enter Information about individuals for whom you have the legal authority to make decisions. We use their date of birth where applicable and your assertion of their relationship with you to confirm your eligibility to obtain Services for them and their eligibility to receive Services.
• We use Information that you enter, or which is created as part of an interaction with an Authorized Provider to provide Services.
• We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.
• We may use Information to help us create, develop, operate, deliver, support, and improve the Actic Platform and its content.
• We may use your Information to contact you for additional information concerning your assessment and treatment plan, future improvements to the Platform and/or research purposes. We will only do this with your explicit consent.

• We only permit our Personnel to access Information to the extent necessary to perform their designated functions. We require them to protect the Information and maintain its confidentiality by complying with our policies, procedures, and applicable law.

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DISCLOSING INFORMATION

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We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Providers and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Actic’s legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person.

We may disclose Information for the purposes of the due diligence required or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.

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RETAINING AND DISPOSING OF INFORMATION

Unless we otherwise give you notice, we will retain your Information on the Actic Platform as required by law, professional regulations, contractual requirements and to fulfill our own purposes for collecting Information. To ensure that Authorized Providers may exercise any authority they have to withhold Information they compile in connection with Services from patients under the law, you will be required to request any access you would like to notes made by an Authorized Provider about your assessment from the Authorized Provider.

Information that is no longer required to fulfill the identified purposes may be destroyed, erased, or made anonymous safely and securely according to Actic policies, client contractual requirements and provincial and federal legislation.

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ACCESSING AND CORRECTING INFORMATION

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SERVICES

If any information you provide to Actic becomes inaccurate, incomplete, or otherwise false, or if you wish to access your information or that of your Registered Dependents you may contact us at privacy@actic.ai

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SECURITY AND SAFEGUARDING INFORMATION

Actic takes the security of your information seriously. We store your information in electronic format within Canada, using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Actic Personnel are obligated to protect Information by adhering to our policies, practices and applicable laws.

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your Information. This includes providing one time links to you and Authorized Providers to access the site. However, since theInternet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Should we be made aware of a privacy breach we will comply with all provincial and federal laws in addition to our own policies and procedures. We will remedy the breach to the best of our ability and notify all parties as required.

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COLLECTING, USING AND SHARING DATA

Actic does not engage in the practice of medicine or provide health care. Actic is not an insurance company. Services we provide are limited to providing an analysis of your condition and treatment options and recommendations that may be carried out at the discretion of your disability insurer, rehabilitation provider and/or your family physician. To do so we collect and use personal information directly from you, from your disability insurer and from third-partyAuthorized Providers to which you may be referred. We will not collect any more information than is necessary to provide Services.

Actic uses your de-identified data for purposes that include: quality control activities improving User experience on the Platform; conducting academic research and designing surveys (to be posted and completed at the discretion of Users). We will not use Data to re-identify individuals.

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COOKIES AND SIMILAR TECHNOLOGIES

The Actic Platform may use “cookies” and other technologies such as pixel tags and web beacons. We use these technologies to better understand User behaviour, analyze trends, administer, personalize, and improve the experience of using the Actic Platform. You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, the Actic Platform might not function correctly. By using the Actic Platform and not turning off cookies, you are consenting to their use for the purposes described in this Policy.

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POLICY CHANGES

Actic may, at its sole discretion and without prior notice to you, revise and update the Policy.Should the Policy change materially, Actic will update the effective date noted above and post a notice regarding the updated Policy. The amended Policy will be effective as of the EffectiveDate unless otherwise stated.

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CONTACT US

If you have any questions, concerns, or suggestions about our privacy practices, please contact our Privacy Officer. Please include your name and contact information if you would like us to respond to you.

Actic Inc.,
Actic Privacy Officer

PO Box 67059 Sunningdale PO,London, ON, N6G0V5privacy@actic.ai

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DEFINITIONS

• “Authorized Provider” means an independent, regulated health professional (such as a physiotherapist) registered to provide healthcare in a Province or Territory of Canada, meets Actic’s other criteria, and is permitted to provide Services through the Actic Platform.
• “Data” means information collected or compiled through the Actic Platform which has been de-identified.
• “De-identify” in relation to PHI, means to remove information that identifies the individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify the individual.
• “Device” means a mobile or desktop device owned or controlled by a User and used to access Actic Services.
• “Services” means the provision of assessments, surveys and treatment recommendations by Authorized Providers and Actic through the Actic Platform.
• “Actic Platform” means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Providers to provide Services to Authorized Users.

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• “Personal Information” means information about an identifiable individual which is notPHI and which is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Actic Platform.

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• “Personnel” in relation to Actic, means its employees and agents including independent contractors and sub-contractors, for whom Actic is responsible at law.

• “PHI” or “personal health information” means information about an individual’s health or healthcare that is subject to Privacy Law and that is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Actic Platform.

• “Privacy Law” means the applicable legislation governing the collection, use, disclosure,and/or protection of PHI in the Province or Territory in which a User resides.
• “User” means an individual who has been registered by their disability insurer and hasaccepted our Terms and Conditions and is thereby eligible to receive Services through the Actic Platform.

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