Last updated: April 2021

OUR COMMITMENT TO PRIVACY
We are committed to maintaining the security, confidentiality and privacy of your personal information. This Privacy Policy applies to the collection, use and disclosure by Impetus Digital ("Impetus Healthcare Inc.") of information about identifiable individuals ("Personal Information") collected through Impetus Digital websites.

SCOPE OF POLICY
This Policy does not impose any limits on our collection, use or disclosure of the following information:

- your business contact information; and
- certain publicly available information.

ACCOUNTABILITY
Impetus Digital is accountable and responsible for personal information under its control. Impetus Digital has designated a Privacy Officer to ensure compliance with this Policy.

COLLECTION OF PERSONAL INFORMATION
Personally identifiable information may be used for aggregate tracking and site usage information that Impetus Digital gathers on an anonymous basis as you access Impetus Digital websites. It is Impetus Digital's policy to the use the personally identifiable information Impetus Digital acquires in Impetus Digital websites for internal business purposes only in order to provide the services that you have requested. Impetus Digital maintains security measures to keep this information private and agrees not to re-distribute, market, share or sell this information to others.

Impetus Digital may collect Personal information about you such as email addresses, names, home addresses or telephone numbers. Impetus Digital does not sell, rent or lease its user lists to third parties. Impetus Digital may access and/ or disclose Personal Information if required or permitted to do so by law under the following circumstances:

a) To comply with a legal requirement including by not limited to one imposed by a warrant, subpoena, court order or like instrument served on Impetus Digital

b) With a customer or advisor where Impetus Digital has reasonable grounds to believe that such access or disclosure is necessary to prevent or investigate any breach or an agreement or contravention of a law or

c) With customer's consent in urgent circumstances to protect the life, health or security of any person

Members of Impetus Digital's websites can choose to create a personal profile where they can populate information about their areas of expertise, associations and interests. Any information that you enter into your personal profile may be visible to other members of the private advisory or working group of which you are a part of, but not to the general public. You may further restrict access to this information via the privacy tab in your profile.

Members of Impetus Digital's websites may choose to interact with others in public sites/communities, private sites/communities and private areas within either (for example through blogs, forums, or internal email communications). Information posted in public communities (where you have not entered a password) may be viewable by others without a password. Information posted in password-protected communities will only be viewable only by other members of the same community. Information exchanged in private working group areas will only be accessible by others in the same private working group. Information exchanged in password-protected communities is not viewable by the general public, and is only accessible via unique password.

Impetus Digital may collect information about your visits to communities including pages viewed, links clicked and other actions taken with a site managed by Impetus Digital. We also collect certain standard information such as IP addresses, browser types and language, access times and referring web site addresses. Impetus Digital does not sell, rent or lease this information to third parties.

Impetus Digital may also disclose Personal Information to its successor or any assignee of Impetus Digital. Impetus Digital does not use or disclose sensitive Personal Information such as race, religion or political affiliations without explicit consent. Any use or disclosure of Personal Information within Impetus Digital will remain subject to the limitations of this Privacy Policy. Impetus Digital will give notice and obtain consent before using or disclosing Personal Information for any purpose that is not described in this Policy.

LIMITS ON COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately and will limit our collection of your personal information to what is reasonably necessary to provide a product or service either directly or indirectly and which is reasonably necessary for the purposes which you consented to.

COOKIES
We use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. Please note that if you choose to decline cookies, you may not be able to experience fully the interactive features of our sites.

Strictly Necessary: These technical cookies are essential in order to enable you to move around our websites and use its features, such as accessing secure areas of the websites. These technical cookies are only temporarily stored while you are using our websites and are deleted from your device once you close your browser functionality.

Functionality: These personalization cookies allow our websites to remember choices you make such as user name, language or region you are in and provide a more enhanced personal experience. These cookies will expire in one year.

Performance and Statistics: These analysis cookies collect information about how visitors use our websites, for instance which pages visitors go to most often and if they receive error messages. These cookies are used to improve the functionality of our websites.

SECURITY
Impetus Digital is committed to protecting the security of Personal Information. We use a variety of security technologies and procedures to help protect Personal Information from unauthorized access, use or disclosure. We store Personal Information on computer systems with limited access, which are located in controlled facilities. When highly confidential information is transmitted over the internet, Impetus Digital protects it through the use of encryption technologies such as the Secure Socket Layer (SSL) protocol.

COMPLIANCE
Impetus Digital conducts all of its business in compliance with all laws, regulations, industry guidelines and codes including but not limited to Health Canada, ASC, Rx&D and PAAB as well as all anti-corruption policies.

PROVIDING ACCESS
You have a right to access your personal information held by us. Upon written request and authentication of identity, we will provide you with your other personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom such information has been disclosed.

We will make personal information available within 30 days or provide written notice where additional time is required to fulfill the request.

COMPLAINTS
Upon your request, we will provide information regarding our complaint procedures.

Any inquiries, complaints or questions regarding this policy or our compliance with privacy legislation should be directed in writing to our privacy officer as follows:

Name: Natalie Yeadon
Email: [email protected]