Nicole Olson

Privacy Policy

TOGETHER IN MOTION PROGRAM

PRIVACY POLICY

Revised for alignment with the Together In Motion Terms and Conditions and for compliance with the laws of British Columbia and Canada. This revision is a working draft prepared for internal review and should be confirmed by a lawyer licensed in British Columbia before publication.

1. Overview

Rebalance Rehab (“Rebalance Rehab,” “we,” “our,” or “us”) operates the Together In Motion (“TIM”) Program and uses the mobile application “Together In Motion” (the “Platform” or “App”) to support program delivery. The App is developed and maintained by FitBudd Inc., including its subsidiaries (“FitBudd”), and is licensed to Rebalance Rehab for use in delivering the TIM Program to its facilitators and participants.

Rebalance Rehab places high importance on the privacy and protection of personal information collected through the Platform. This policy sets out our practices regarding the collection, use, and disclosure of personal information, and is intended to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, British Columbia's Personal Information Protection Act (PIPA). We have implemented security safeguards reasonable to the sensitivity of the information collected. Because no method of transmission over the internet is completely secure, we cannot guarantee absolute security of information transmitted to us.

This Privacy Policy should be read together with the TIM Program Terms and Conditions. It may be updated from time to time, and we encourage you to review it periodically. By using the Platform, you agree to this Privacy Policy. We may rely on third-party service providers, including FitBudd, to deliver aspects of the Services. These third parties are required to maintain reasonable and commensurate security practices.

This Privacy Policy applies to all Users of the Platform, including TIM Program participants, caregivers enrolled in the program, and Rebalance Rehab facilitators (collectively, “Users” or “you”).

2. Information Collection

If you register as a User of the Platform, you will create a unique username and password (collectively, the “Access ID”) used to activate an account through which Rebalance Rehab makes the Platform available to you (your “Account”). To deliver the TIM Program, we may collect personal information such as your name, age, gender, general health or caregiving context relevant to the program, and email address (“Personal Information”). You may be asked to upload photos to the Platform to help track your progress through the program. FitBudd stores Personal Information in accordance with applicable law, and Rebalance Rehab takes reasonable steps to protect photos and other content you upload, but is not responsible for disclosure by FitBudd or by facilitators outside the scope of authorized program delivery.

Facilitators may upload videos or images to support program delivery. Rebalance Rehab is not responsible for the source or content of such materials and is not liable for any third-party copyright or plagiarism claim relating to them.

The TIM Program is currently grant-funded and provided to participants at no cost. Rebalance Rehab does not collect payment card or banking information (“Financial Information”) from participants in connection with the TIM Program. If this changes, this Privacy Policy will be updated to describe how any Financial Information collected would be gathered, used, and protected. You may contact nicole.olson@rebalancerehab.ca to correct, amend, or request removal of your Personal Information, with the understanding that withdrawing certain information may limit our ability to provide some Services.

We may collect information about how you use the App, such as the pages or features you access, general device information (for example, device or browser type), information you send us directly, and referral information. This helps us deliver, troubleshoot, and improve the Services.

Information that identifies your general location (such as a postal code or city) may be used to support program delivery and improve the Services. We do not use this information for advertising or marketing purposes.

Creating an Account makes you responsible for the accuracy of the information you provide, including your name, phone number, and email address. We may verify information you provide through a Rebalance Rehab representative.

3. Purpose of Information Collection

We collect, record, store, and use your Personal Information only to enable your participation in the TIM Program, to communicate with you about the program unless you opt out of non-essential communications, and to support facilitators in tracking participant progress. We use this information to maintain the quality and safety of the Services, understand participant needs, troubleshoot issues, customize your experience, detect and prevent fraud or misuse, enforce the Terms and Conditions, and for any other purpose described to you at the time of collection. Photos uploaded to the Platform are used solely to support tracking of your progress through the TIM Program.

4. Privacy, Security, and Related Matters

We do not sell or rent your Personal Information to third parties for marketing purposes without your explicit consent, and we use your information only as described in this Privacy Policy and the Terms and Conditions. We may disclose or transfer information to affiliates, agents, or service providers, including FitBudd, where necessary to deliver the Services. To the extent permitted by applicable law, Rebalance Rehab is not responsible for unauthorized access to or misuse of information by a third party that has not been authorized by Rebalance Rehab. We use industry-standard encryption, including secure socket layer (SSL) technology, to protect the transmission of sensitive information.

The Platform is protected by copyright as a collective work or compilation of its content, in accordance with applicable Canadian law.

Rebalance Rehab's logos, names, trademarks, and other intellectual property (“IP”) are owned exclusively by Rebalance Rehab. You agree not to display or use this IP without Rebalance Rehab's prior written permission. Nothing on the Platform grants any licence or right to this IP without express written permission.

References on the Platform to third-party names, products, services, or links are provided for convenience only and do not imply endorsement, sponsorship, or recommendation by Rebalance Rehab.

5. Acceptable Use

You agree not to violate or attempt to violate the security of the Platform, including by:

• attempting to probe, scan, or test the vulnerability of a system or network, or to breach security or authentication measures without authorization;

• interfering with the Service to any other User, host, or network, including through a virus, overloading, flooding, spamming, or similar means; or

• sending unsolicited emails, including for advertising or promotional purposes.

Violations of system or network security may result in civil or criminal liability under Canadian law. We will investigate suspected violations and may cooperate with law enforcement authorities where appropriate. You agree not to use any device, software, or routine to interfere with the proper functioning of the Platform.

6. Email Communications

We may send you emails or newsletters related to the TIM Program or other Rebalance Rehab Services. You may opt out at any time using the unsubscribe link in any email, or by emailing nicole.olson@rebalancerehab.ca to request removal from our mailing lists.

7. Exceptions to Disclosure

We will not voluntarily disclose your Personal Information except as described in this Privacy Policy and the Terms and Conditions. We may disclose information where required by court order or applicable law, where requested by a government or law enforcement authority, where required by other legal process, or where necessary to protect the rights or property of Rebalance Rehab.

Except as required by applicable law, neither Rebalance Rehab nor FitBudd is liable for physical injury or other harm arising from use of the Services through the App.

8. Contact

If you have a question or concern about the use or protection of your personal information, or any other aspect of this Privacy Policy, please contact us at nicole.olson@rebalancerehab.ca.

9. Applicable Privacy Framework

Rebalance Rehab is a Canadian organization and handles personal information collected through the TIM Program in accordance with PIPEDA and, where applicable, British Columbia's PIPA, rather than United States health privacy frameworks such as the Health Insurance Portability and Accountability Act (HIPAA). If you access the Services from outside Canada, please note that your information will be handled under Canadian privacy law rather than the law of your home jurisdiction, except to the extent otherwise required.

10. Data Deletion

You may request deletion of your personal data from the Platform at any time using the in-app data deletion feature or by contacting nicole.olson@rebalancerehab.ca. We will process deletion requests promptly and remove your data from our systems, except where retention is required to comply with legal obligations, resolve disputes, or enforce our agreements. Some anonymized, de-identified data may be retained for program evaluation and reporting to funders, but will not be linked back to your identity.

11. Miscellaneous

This Privacy Policy and the Disclaimer provided separately form an integral part of the TIM Program Terms and Conditions and should be read together with them.

Personal Information may be stored and processed by FitBudd or other service providers in Canada or, where necessary, in other countries. Where information is processed outside Canada, it becomes subject to the laws of that country, including potential disclosure to courts, law enforcement, or regulatory authorities there. Regardless of where it is processed, Rebalance Rehab's handling of your Personal Information remains governed by this Privacy Policy and applicable Canadian privacy law. We will not transfer Personal Information outside Canada for processing without confirming that the recipient maintains protections comparable to those required under PIPEDA.

Capitalized terms used in this Privacy Policy and not otherwise defined have the meaning assigned to them in the Terms and Conditions.