CBx Data Labs provides a cloud-based application that can be accessed from an internet browser and/or downloaded on compatible smartphone devices (the “Application”). The Application allows users to input data and information regarding their medication management regime, and to track their symptoms and outcomes. This privacy policy explains how CBx Data Labs collects, uses and discloses personal information in connection with the Application and any related activities.

Personal Information We Collect and How We Use It
Personal information is information that can be used alone or in combination with other information to identify or contact a specific individual.

We collect personal information about individuals who use our Application, including: name, contact information and date of birth; symptoms, conditions, medication usage (including type of medication, when and how it is used), and general health status; and Application usage (when the App is used, what features are used and for how long). We may also request and gather feedback on the Application generally. We collect this information directly from the user or from the Application. If you have paired a medical device with the Application, we may also receive some of this information directly from the device.

We use this information to provide the Application features to users, to administer any program in which the user has chosen to participate (including determining eligibility for participation in and payments under such program, as applicable), to communicate with users, to make improvements to the Application and to create new applications and software products. We may also use this information to create aggregate data and reports for our partners, who may include researchers or
research organizations, health associations and health-related businesses.

We may also collect personal information from individuals who are interested in CBx Data Labs or the Application, including their name and contact information, and any other information they may choose to provide. We use this information to provide the information that has been requested.

When We Share Personal Information
We share personal information with our service providers to the extent necessary to allow the service providers to perform certain services on our behalf, such as data hosting, marketing and information technology services.

We may use or share personal information with parties in connection with the proposed or actual sale or other business transaction involving CBx Data Labs or our business or assets for the purposes of evaluating and/or performing the proposed transaction.

We may disclose personal information to the extent necessary meet legal, regulatory, insurance, audit, and security requirements.

Your Rights
If you wish to request access or correction of your personal information in our custody or control, or if you would like to withdraw your consent to our processing of your personal information, you may write to us as described below. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.

Security and Retention of Personal Information
The file containing your personal information will be maintained on our servers or those of our service providers and will be accessible by our authorized employees, contractors and service providers who require access for the purposes described in this privacy policy. CBx Data Labs has implemented reasonable security measures to protect the personal information in our control. Personal information is retained for as long as necessary to fulfill the purposes described in this privacy policy and otherwise in accordance with CBx Data Labs’ record retention policies.

Links to CBx Data Labs Websites and Third Parties
The CBx Data Labs website may provide links to third-party web sites for your convenience and information. If you access those links, you will leave the CBx Data Labs website. CBx Data Labs does not control those sites or their privacy practices which may differ from those of CBx Data Labs. We encourage you to review the privacy policy of any company or institution before submitting your personal information.

Changes to this Policy
This privacy policy is effective as of the effective date below and may be revised from time to time. We will make reasonable efforts to notify you of material changes to this privacy policy, including by posting the revised policy online or in the Application. Your continued provision of personal information or use of the Application following any changes to this privacy policy your acceptance of any such changes.

For more information about CBx Data Lab’s privacy practices, or to raise a concern you have with our practices, please contact:

Chad Walsh, Chief Executive Officer
CBx Data Labs,

52 Robert St., Toronto, ON M5S 2K3 Tel: (647) 691-0203
Effective Date: October 18, 2019