Advica Health, A Division of Royal VIP Health Options Inc.

Privacy and Confidentiality Policy (V.2019 Revised Dec 2019)
Advica Health and all designated third-party partners and service providers are committed
to maintaining the accuracy, confidentiality, and security of any and all personally
identifiable information (“Personal Information”). As part of this commitment, our privacy
policy governs our actions as they relate to the collection, use and disclosure of Personal
Information. Our privacy policy is based upon the values set by the Canadian Standards
Association’s Model Code for the Protection of Personal Information and

Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).
Advica Health agrees to implement appropriate internal measures to protect client
specific Confidential and Personal Information from accidental, unlawful or unauthorized
access, use, disclosure, tampering, destruction or loss.

Access to information across the organization is limited to a “need to know basis” by staff
members that require some information to perform their assigned duties. Only the least
amount of health information necessary to carry out the intended purpose is collected,
used and disclosed at all times.

1. Introduction We are responsible for maintaining and protecting all Personal
Information under our control. We have designated measures in place that allow both
updates to procedures and policies, as well as technology to ensure they comply with our
privacy policy.

2. Identifying Purposes We collect and use any Personal Information to provide our
clients with the products or services that they have requested. We may also use that
information to offer our clients additional products and services we believe they might be
interested in as well as to communicate with them from time to time.

We disclose any Personal Information to our partners and service providers only to
ensure that they can manage, guide, and help provide the products or services that our
clients have requested.

The purposes for which we collect Personal Information will be identified before or at the
time we collect the information. In certain circumstances, the purposes for which
information is collected may be clear, and consent may be implied, such as where name,
address and payment information is provided as part of a new account set up process.

3. Consent Knowledge and consent are required for the collection, use or disclosure of
Personal Information except where required or permitted by law. Providing us with your
Personal Information is always your choice. However, your decision not to provide certain
information may limit our ability to provide you with our products or services. We will not
require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except when required to be able to supply a specific
product or service.

4. Limiting Collection The Personal Information collected will be limited to those details
necessary for the purposes identified by us. With your consent, we may collect Personal
Information from you in person, over telephone, email, fax or video conferencing.

5. Limiting Use, Disclosure and Retention Personal Information may only be used or
disclosed for the purpose for which it was collected unless you have otherwise consented,
or when it is required or permitted by law. Personal Information will only be retained for the period of time required to fulfill the purpose for which we collected it or as may be
required by law. With your written consent, we will forward information to your family
physician or another third-party service provider to ensure appropriate ongoing monitoring
and long-term follow up. Your information will not be forwarded without your consent.

6. Accuracy Personal Information will be maintained in an accurate, complete and up-to-
date form as is necessary to fulfill the purposes for which it is to be used. Personal

Information will be updated on an ongoing basis as required and as provided by the client.

7. Safeguarding Customer Information Personal Information will be protected by
security safeguards that are appropriate to the sensitivity level of the information. We take
all reasonable precautions to protect your Personal Information from any loss or
unauthorized use, access or disclosure. In the case of a breach that is made known to
us, we will contact you in a timely manner with specific details around next steps.

8. Openness We will make information available to you about our policies and practices
with respect to the management of your Personal Information upon request.

9. Customer Access Upon request, you will be informed of the existence, use and
disclosure of your Personal Information, and will be given access to it. You may verify the
accuracy and completeness of your Personal Information, and may request that it be
amended, if appropriate.

However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal or security proprietary restrictions.

10. Customer Complaints and Suggestions You may direct any questions or enquiries
with respect to our Privacy Policy by contacting our Designated Privacy Officer at
[email protected] or 1.905.220.7574.