AppGen Studio Inc. (“us,”, “we,”, “our”, or “AppGen Studio”) is committed to protecting your data, and our highest priority is keeping your sensitive information—especially your personal health information—safe. In this policy we explain what data we collect about you and how we store, analyze and share the data through CarePortals’ website, mobile and web applications (together, the “CarePortals Platform”, "CarePortals", or “Platform”).
Nothing in this Policy limits your rights under applicable laws, including your ability, depending on your country of residence, to file a complaint with your local Data Protection Authority.
CarePortals allows health care providers to enhance their service with secure video consultations, and patients to consult health care providers from the privacy and convenience of the location they choose. This means personal information and personal health information is collected by CarePortals. This information is highly sensitive and protected by The Personal Information Protection and Electronic Documents Act (PIPEDA), The Personal Health Information Protection Act (PHIPA), Health Insurance Portability and Accountability Act (HIPAA), and all equivalent personal health information protection legislation throughout Canada and United States.
We're committed to safeguard it at the corresponding level. This Privacy Policy describes the physical, technological and administrative measures we implement to safeguard personal and personal health information. We comply with privacy law and we honour the trust of our users by taking every necessary measure to protect personal and personal health information. By law, personal information is information that relates to an identifiable individual, to the exclusion of business contact information (name, title, work address, work phone number or work email address). Personal health information includes information that relates to an identifiable individual’s health, physical or mental, health history including family health history, or medical treatment.
Please carefully read through this Policy. To join and enjoy AppGen Studio’s Platform and its Services, you are required to accept all terms of this Policy. By using the Platform, you are accepting the terms of this Privacy Policy and our Terms of Services, and you are consenting to our collection, use, disclosure and retention of your Information as described in this Privacy Policy. If you do not consent to the collection, use and disclosure of your information as described in this Policy, you will not be able to use the Platform.
Unless otherwise defined herein, capitalized terms shall have the meanings assigned to such terms set forth in the Terms of Service and which incorporate this Privacy Policy by reference.
This Privacy Policy is only applicable to the Platform and does not apply to any other website or service that you may be able to access through AppGen Studio’s Platform or any website or digital services of AppGen Studio’s business partners, each of which may have data collection, storage and use practices and policies that may differ from this Policy. We are not responsible for the actions or privacy practices of these third-party websites or services nor does it signify our endorsement of such websites, locations or its contents. Please consult those websites and services directly to understand their privacy practices. Your use of the CarePortals Platform is governed by this Privacy Policy and the Agreement (as the term “Agreement” is defined in our Terms of Services).
AppGen Studio recognizes that the confidentiality, integrity and availability of information and data created, maintained and hosted by us are vital to the success of the business and privacy of our partners. As a service provider/product, we understand the importance in providing clear information about our security practices, tools, resources and responsibilities within AppGen Studio so that our customers can feel confident in choosing us as a trusted provider. This Security Posture highlights high-level details about our steps to identify and mitigate risks, implement best practices, and continuously develop ways to improve.
You can find our security profile with more detailed policies here.
We collect Information about you when you provide it to us, when you use our Platform and when other sources provide it to us, as described below. Please note that for the purpose of clarity and ease, we will refer to Personal Information or Information for all categories mentioned below throughout this Policy.
Simply stated, Personal Information is any information about you as an identifiable individual. The information we may collect from you includes:
Health and Wellness Information (“Health Information”) is data related to your physical and mental health as well as medical history, including symptoms, diagnosis, procedures, outcomes and claims. When using AppGen Studio’s Platform you may provide certain health or health-related information to us. Health Information includes:
Payment Information is data related to your bank account, debit or credit card. We collect your bank account and billing information when you register for the Platform to process your spending account claims or for any payments through AppGen Studio’s Lifemarket. By linking your bank account to your the Platform account, you authorize us to submit your Payment Information to the financial institution that will process your employee benefit payment.If you provide us with your credit card information, this information is processed by our credit card payment processing partner. This partner collects your voluntarily provided payment information necessary to process your payment or claim. Such partner’s use and storage of information is governed by its applicable terms of service and privacy policy.Personal Information we get from others
Employment and Benefit Information – We may also get Information about you from other sources. For example, we may get employment information from your Employer or Carrier to enroll you in your health benefits and our Platform. The data set may include your first and last name, employee ID, income, role, employment status and dependent information. The data set depends on what your employer shares with us. While you are a user and use the Platform, we may receive additional employment or benefit information from your Employer or Carrier including claims data. We might add this Information to your account. Please note that we will only use and store the information necessary to enroll you in your benefits and our Platform and to provide you with personalized services through Health Profile and Programs.
Devices and Third Party Apps – As a user you may be able to connect activity and health trackers (“Devices”) and third-party applications (“Third Party Apps”) to your account. These devices and applications can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity as well as your nutrition. Depending on the brand and model of tracker you use, the data collected may vary. In general, these Devices and Third Party Apps have specific privacy policies that outline what data they collect. In some cases you may be able to control which data points to share with the Platform. We strongly suggest you review the right privacy policy to know what specific data points your activity tracking device collects about you.
Social Media Account Information – If you create your the Platform account using a social media account (e.g. Google, Facebook) we may also collect Information provided to us by that social media service. This Information may include your name, email address, language preference and profile picture.Information we collect automatically when you use the PlatformDevice and Connection Information – We collect information about your computer, phone, tablet or other devices you use to access the Platform. This Device and Connection Information includes your connection type and settings when you install, access, update or use our Platform. We also collect Information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers and crash data. We use this additional information to enhance the security controls around Platform access and resolve bugs and errors that may exist on the Platform. We use your IP address and/or country preference to approximate your location so we can provide you with a better Platform experience.
Cookies and Other Tracking Technologies – We collect information about you when you use our Platform, including browsing our websites and taking certain actions within the Platform. To do so we use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across our Platform.
AppGen Studio receives employment information from your employer or insurance carrier so we can set up your profile and prepare your account for enrollment. After that, we collect your Information when you sign-up for AppGen Studio’s Platform and as you submit it through the use of the Platform and as provided by your employer or carrier.Depending on the Services and integrations you participate in or enable and the Service being offered to you by your employer through the CarePortals Platform, we may collect and receive Personal Information through your use of the particular Services and integrations. These integrated services and solutions may have their own and separate consent process required prior to you using them with AppGen Studio.
Depending on the Services and integrations you participate in or enable and the Service being offered to you by your employer through the CarePortals Platform, we may collect and receive Personal Information through your use of the particular Services and integrations. These integrated services and solutions may have their own and separate consent process required prior to you using them with AppGen Studio
How we use the Information we collect depends in part on which Services are offered to you, which Services you use, how you use them and any preferences you have communicated to us. Below are the specific purposes for which we use the Information we collect about you.
For enrollment and decision support – We guide you every step of the way so you fully understand your options and choose the best coverage for your needs. To do so, we gather the Information we have received from your employer about you and apply eligibility rules to facilitate your enrollment into your health benefits as well as any other benefit spending accounts offered to you through your employer.
For a personalized digital wallet – We provide you with one easily-accessible place to manage your coverage, dependents and benefit spending accounts.
For processing your claims – If you are being offered additional benefit spending accounts by your employer through the CarePortals Platform, you can submit eligible claims online. In order to process these claims and reimburse your bank account, we process the claim information provided to us by you and use the Payment Information we have on file.
For Customer Care services – Through the Platform you have immediate live chat support for all your benefit-related questions. To answer your request and to provide you with personalized recommendations, our agents access your Personal Information on file and may ask you to provide us with additional Information. Additional Information requested or provided by you may contain Health Information.
For immediate, expert health and wellness guidance – We provide health and wellness-related guidance and navigational support through live chat with Health Concierge. To answer your request and to provide you with personalized guidance, AppGen Studio’s Concierges access your Personal Information on file and may ask you to give them additional information including Health Information.
For creation or enhancement of your personalized health profile and programs – As a user of AppGen Studio’s Platform you have access to a central place for your health information, personal progress on health and wellness programs, earned rewards and any Device and Third Party App integrations. AppGen Studio uses Personal Information and Health Information provided to us to help you understand your health risks and long-term outcomes and how you can use your benefits and programs to improve your overall health and wellbeing.
For health and wellness assessments – You may have access to AppGen Studio’s health assessment (“Health Profile”). Through a number of questions, the Health Profile assesses your wellbeing across a number of dimensions. You don’t have to complete the Health Profile if you don’t want to share this information with us.
For processing your orders and to facilitate bookings and communications with a Service Provider – Through AppGen Studio’s Lifemarket we provide you with offers and discounts on products and services that support better health, fitness and wellbeing. When you buy products or sign-up for services through the Lifemarket, we access your Personal Information including your benefit spending accounts and Payment Information. AppGen Studio needs access to this Information to process your order and payments and facilitate communication between you and the Service Provider.
For safety, security and compliance – We use information about you and your Platform use to identify you as a user of our Platform, verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Platform policies.
To provide the Platform and personalize your experience – We use Information about you to provide the Platform to you, to enhance the security controls around Platform access and resolve bugs and errors. We may also use your Information to verify your geographic location. We may use your geographic location data to personalize your experience in the Platform, to recommend content and to see whether the information you request is available in your location.
For research and development – We’re always looking for ways to make our Platform smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our Platform and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Platform.
To market, promote and drive engagement – If you give your consent, we use your Information to send newsletters, surveys, offers and promotional materials that may be of interest to you and tailored to your individual health and wellness goals. You can opt out of receiving such messages from AppGen Studio by following the opt-out instructions in these messages. If you opt out, we may still send you non-commercial electronic messages, such as messages about your account or our ongoing business relations. Please note that AppGen Studio does not sell or share your Information to third parties for their marketing purposes.
For Challenges – If your employer offers AppGen Studio Challenges your progress may be shared with other participants and HR admins.
We may share your Information with third parties so we can provide our services to you. If we need to share your Information with third parties, we will limit the Information to the minimum amount necessary to ensure the provision and quality of the Services we offer you. We share your Information with third parties as follows:
Contractors – We may disclose your Personal Information with contractors that work on our behalf and assist us in providing and supporting the services we offer.
Third Party Providers – We share Information with third parties that help us operate, provide, improve, integrate, customize and support our Platform and Services we offer to you such as:
If a Third Party Provider needs to access Information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your Information. Our Third Party Providers undergo a thorough security and privacy review as a part of the evaluation process and then regular SOC1, SOC2 and/or ISO/IEC 27001 audit reviews thereafter. In the event these audits have material findings that present risks to AppGen Studio or our clients, we work closely with the vendor to track their remediation efforts until the issue has been resolved.
Insurance Carriers – We’ll automatically feed your benefits elections and status/profile updates to your Insurance Carriers for faster, more accurate enrollment and to determine eligibility. When you reach out to us for support about your eligibility or coverage, we may share this Information with your Insurance Carriers on your behalf.
Your Employer – We may share Information with your employer in an anonymous and aggregated or group format only. Any data sharing practices going beyond anonymous, aggregated or group format need your explicit consent. When sharing de-identifiable or aggregated information, we will use procedures compliant with applicable privacy laws and regulations to ensure that all identifiable data and dimensions have been removed from the data sets and reports provided to your Employer. Please note that your Employer may combine the information we provide with other data available to them and use the combined data at their discretion, including to evaluate the overall program, as well as to provide additional benefits, programs and services. Your Employer’s use of the data and reports are not controlled by us, and this Policy does not cover your Employer’s data use and sharing practices.
“Cleared for Workplace Module” – If your Employer offers the “Cleared for Workplace Module” as part of the Platform, your participation status will always be shared with them. None of your responses to individual questions in the module will ever be shared with your Employer. Only if you give your explicit consent to share the results of the module, your COVID-19 status and a recommendation for testing or self-isolation will be passed to your employer. No other health conditions or symptoms will be disclosed to your Employer.
If your Employer is not using this service this does not apply to you.It is Your Employer’s responsibility to comply with its own privacy policy and applicable laws. We encourage you to review your Employer’s data practices with your Human Resources team.
Service Providers – We may share your information with Service Providers you choose through the CarePortals Platform including our Lifemarket. When you book an appointment and buy a product through the Platform, we automatically provide your first and last name as well as a Service or product description to the Service Provider. We want everyone to feel safe and cared for when they visit AppGen Studio Lifemarket or use a Service Provider offered through the Platform. So before we admit any new Service Providers, we thoroughly review their practices to make sure they’re in line with our standards. We also regularly review our Service Providers to make sure they stay compliant.
Devices and Third Party Apps – You may choose to add new functionality and Information to your account by connecting Devices and Third Party Apps to your account. If you do, you may give these Devices and Third Party Apps access to your account and Information about you like your name and email address, and any content you choose to use in connection with those apps and devices. Device and Third Party App policies and procedures are not controlled by us, and this Policy does not cover how Devices and Third Party Apps use your Information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices. If you object to Information about you being shared with these third parties, please disable the device or app within your the Platform account settings.
Law Enforcement, Governmental Authorities and Agencies – We may disclose information we have collected from and about you – including Personal Information – if we believe in good faith that it’s necessary to:
We may share your Information with third parties so we can provide our services to you. If we need to share your Information with third parties, we will limit the Information to the minimum amount necessary to ensure the provision and quality of the Services we offer you. We share your Information with third parties as follows:
Contractors – We may disclose your Personal Information with contractors that work on our behalf and assist us in providing and supporting the services we offer.
Merger, Sales and Acquisition – In the event that we (a) undergo reorganization or (b) that AppGen Studio is sold to a third party, any Personal Information we hold about you may be transferred to the re-organized entity or third party, in accordance with applicable laws and regulations. If an acquisition like this occurs, the new entity will continue to use your Personal Information within the limits of this Policy, to continue delivering your service.
Aggregated/non-personal data may be shared between accounts (such as the balance of a shared Spending Account, deductibles and out-of-pocket spending).
At AppGen Studio, we take security and privacy very seriously. We’re committed to protecting your data, and our highest priority is keeping your sensitive information – especially your personal health information – safe. We follow strict security and compliance standards not only because we need to meet specific regulations, but because we consider it one of the most important things we can do for you.
Security is at the heart of every process and every technology we use across all our teams at AppGen Studio. The CarePortals Platform is regularly audited to make sure it complies with security, availability and confidentiality requirements for managing client data.
Communication with AppGen Studio should always be done through the CarePortals Platform where the information is encrypted. While AppGen Studio makes every effort to secure all communications within our control and in our Platform, please be advised that no method of delivery is absolutely secure and any communication of Personal Information may be accidentally or deliberately intercepted by third parties. No company, including AppGen Studio, can fully eliminate security risks associated with your Information. While we strive to protect your Information, we cannot guarantee its security.
To help protect yourself and your Information, choose a unique password for our Platforms and do not use a password that you would use on any other website or online service. You are responsible for the security of your Information that you transmit to us or view, download or otherwise access when using public or otherwise unsecured networks. If you use a mobile device to accept your authorization code, you should have the ability to remotely wipe the phone in the event that your device is lost or stolen.
Your Personal Information is maintained on AppGen Studio’s infrastructure or those of third-party providers. For that reason, AppGen Studio employees and contractors have access to your Information so we can provide you with quality services, including user support and Health Concierge services. Our employees and contractors are obligated to respect the confidentiality of your Personal Information and are only authorized to access your Information as necessary to provide you with Services or support.
In the event that we (a) undergo reorganization or (b) that AppGen Studio is sold to a third party, any Personal Information we hold about you may be transferred to the re-organized entity or third party, in accordance with applicable laws and regulations. In the event of an acquisition, the new entity will continue to use your Personal Information within the limits of this Policy, to continue delivering your service.
Yes. If your Personal Information changes over time or you realize your Information is outdated or incorrect, you have a right to be able to update or correct it. You may update or correct the Information by changing it right in the Platform. If you aren’t able to update or correct the Information right in your account, you can reach out to us through the Chat function in the Platform. You can also contact us at support@appgen.ca to request that we update or correct the Information for you. We will respond to your request within a reasonable timeframe.
Yes. All our users, no matter where they live, except in specific circumstances identified by local laws, have a legal right to access the Information we have collected about them and an account of its use and disclosure. You can request a copy of all the Information and data we hold about you. We’ll give you a copy of the data in a standard format through a secure channel. To make this request, reach out to us at support@appgen.ca. We will respond to your request within a reasonable timeframe.
Please note that we may not be able to delete your Information without also deleting your user account. You may terminate your account at any time by submitting a deletion request to support@appgen.ca. Once your account is terminated, you will no longer be able to access or use your health and wellness benefit accounts offered through the CarePortals Platform as well as Programs and Services.
Please note that we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To figure out the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, the applicable legal requirements, and regulatory retention periods.
Because of the type of Services we offer, we can’t accommodate requests to restrict the processing of certain sets of Information. You, however, will be able to limit the Information added to your profile based on your use of Services and participation in Programs, the Devices and Third Party Apps you connect to your account and the consent you provide for any data sharing practices.
If you want us to stop processing parts of your Information, you can request that all data be deleted through the process above. You can also limit the Personal Information provided to us as you participate in the Services and programs offered to you.If you have connected any Devices or Third Party Apps, you can manage the data sharing and processing settings for each of them through your the Platform account.
If you’ve provided your consent for additional data sharing, you can withdraw your consent at any time. To do so, please reach out to us through the Chat function in the Platform or by contacting support@appgen.ca.If you provide your consent, we use your Information to send newsletters, surveys, offers and promotional materials that may be of interest to you and tailored to your individual health and wellness goals. You may opt out of receiving such messages from AppGen Studio by following the opt out instructions in these messages. If you opt out, we may still send you non-commercial electronic messages, such as messages about your account or our ongoing business relations.
AppGen Studio is headquartered in Canada and uses Third Party Providers in other countries. Your Personal Information may be transferred to the Canada, United States or other locations outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. AppGen Studio takes appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Information in storage and transmission. We also enter into contracts with our Third Party Providers that require them to treat Personal Information in a way that’s consistent with this Policy.
Individuals under the age of eighteen (18) should not transfer any Personal Information to us. We will neither intentionally ask for Information of users under the age of eighteen, nor process their Personal Information. Additional notice to residents of the United States: We do not intentionally collect or maintain Information from visitors of the website or Platform who are under thirteen (13) years old.
If you believe that AppGen Studio has not adhered to this Privacy Policy, please contact AppGen Studio by email at privacy@appgen.ca. We’ll do our best to make things right. If you feel that your complaint hasn’t been fully addressed, let us know and we’ll investigate further.
If you have questions or concerns about this Privacy Policy, please contact us at:
AppGen Studio, Inc.
+1 (647) 955-5467
3278 Fieldgate Dr., Mississauga, Ontario L4X2H7
privacy@appgen.ca
If this Privacy Policy changes, the revised policy will be posted online and if we make material changes, you may be notified by email. Your continued use of the Platform after the effective date constitutes your acceptance of the amended Privacy Policy. Any amended Privacy Policy supersedes all previous versions. Please check back periodically, especially before you provide any personal information. This Privacy Policy was last updated on May 10th, 2023.
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