Privacy Policy

Effective Date of Policy: December 2, 2025

Last Updated: December 2, 2025

Elix Health Inc. ("we," "our," or "us") respects your privacy and is committed to protecting it through this Privacy Policy.

This Privacy Policy describes:

How we collect, use, disclose, and protect the personal information and personal health information of our customers and website and platform users (“you”).
The types of information we may collect from you or that you may provide when you visit our website (www.elixhealth.ca) (the “Website”) and use our services (the “Services”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information and personal health information in accordance with this Privacy Policy, unless otherwise required by applicable law. We take steps to ensure that the personal information and personal health information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Our privacy commitment is based on the Personal Information Protection Act (British Columbia) (“PIPA”) and the ten principles contained in the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We respect your privacy and are committed to protecting it by complying with applicable Canadian privacy laws.

This Privacy Policy governs your access to and use the Services, including any content, functionality, and services offered therein, whether as a guest or as a registered user. This Privacy Policy applies to personal information and personal health information that we collect in connection with the Services and in email, text, forms, or other electronic messages between you and us.

This Privacy Policy also applies to any service providers, practitioners, employees, contractors, and agents collecting, using, or disclosing personal information or personal health information on our behalf.

Our Website or our platform through which we provide the Services (the “Platform”) contains links to external third-party websites, plug-ins, services, social platforms, or applications. Activating these links or connections might let the third party gather or share your data. If you use a link to a third-party site or interact with a third-party plugin, be aware that they operate under their own privacy policies. We are not responsible for, nor do we endorse, these policies. We have no control over third-party websites. We recommend that you review the privacy policy of any website you access.

Please read the Privacy Policy carefully before you start to use or access the Services or the Website. It is our policy to comply with all applicable Canadian privacy laws and regulations relating to your privacy, as set out in our Terms and Conditions, accessible here:

https://www.elixhealth.ca/terms-of-use. Carefully review this Privacy Policy to grasp how we manage, process, and store your personal information and personal health information.

By using and accessing the Services, you accept and agree to be bound and abide by the Privacy Policy. If you disagree with our methods and policies, you must not access or use the Services or the Website. By interacting with any portion of the Services or the Website or selecting "I Accept" on any necessary consent form to access or use the Services or the Website, you confirm your comprehension, agreement, and consent to these privacy practices described in this Privacy Policy.

Occasionally, we may update this Privacy Policy. Your continued access or use of the Services or the Website after we make such changes indicates that you accept and consent to these changes, so please check this Privacy Policy periodically for updates. In the event of significant alterations, we'll provide prior notice and seek your consent before implementing new ways to handle your personal information and personal health information.

Information We Collect About You

We collect and use several types of information from and about you, including:

(a) Personal Information

(i)Under PIPA, “Personal Information” is any information about an identifiable individual, but does not include contact information or work product information.

(ii) Under PIPEDA, “Personal Information” is any information about an identifiable individual, but does not include the name, title, business address, or telephone number of an employee of an organization.

(iii) We collect personal information that we can reasonably use to directly or indirectly identify you, such as your name, phone number, email address, mailing address, guardian contact, emergency contact, and any other identifier we may use to contact you.

(b) Personal Health Information

(i) Under PIPEDA, “personal health information” means information with respect to an individual, whether living or deceased, that:

(A) concerns their physical or mental health;

(B) concerns any health service provided to them;

(C) concerns the donation by them of any body part or bodily substance of theirs or information derived from testing or examining such body part or bodily substance;

(D) is collected while providing health services to them; or

(E) is collected incidentally to providing health services to them.

(ii) We collect personal health information, such as your family doctor, physical and mental health data, information to understand any information necessary to provide the Services to you.

(iii) If you will be receiving Services from us, we will ask you to review and sign an additional consent that discloses the risks and conditions for the collection and use of your personal health information to provide the Services.

Prior to accessing the Services, you may be required to verify your identity before your first appointment. This process may involve providing a photo of a valid government-issued identification document. This image, if shared via our secure and encrypted system, becomes part of your medical record and is used exclusively to confirm your identity. A licensed pharmacist or other regulated health professional who is in good standing with their respective College or licensing body, and who is authorized to the Services to you (each, an “Authorized Provider”) may compare the image on your identification with you during subsequent audio or video visits to ensure accurate verification. From time to time during your access to the Services, you may be asked questions to confirm your identity. If you prefer not to upload a copy of your government-issued identification, you will be asked to present it during video sessions as needed. Copies of identification used for verification can be deleted from our records upon your written request, except where retention is required by law or regulation.

Why Do We Collect Personal Information and Personal Health Information?

We collect personal information and personal health information from you to provide the Services to you (which includes virtual health consultations through Authorized Providers), to improve our overall performance, and to provide you with offers, promotions, and information. The information that you share may include sensitive information, such as physical health or mental health data, information revealing race or ethnic origin, information revealing religious or philosophical beliefs, or data about your sex life or sexual orientation. During the Services, the Authorized Providers will collect and record certain personal information and personal health information pertinent to providing the Services.

We collect your information to record and support your participation in the activities you select. If you register to download any content relating to our Services or sign up for information about the Services or for any newsletter, we collect your information. We use this information to track your preferences and to keep you informed about the Services you have selected to receive and any related products or services.

How Do We Collect Personal Information and Personal Health Information?

We collect personal information and personal health information only by lawful and fair means and only collect personal information and personal health information that is reasonably necessary for the legitimate purposes identified and for which consent has been obtained.

We use different methods to collect your information, including through:

(a) Direct Interactions. Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.

(b) Website and Platform. Our Website and the Platform, each of which provides various places for users to provide information. We collect information that users provide by filling out forms on the Website or the Platform, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a product or service via the Website or the Platform.

(c) Email. If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our Website or the Platform or sign up through any of our forms using your email.

(d) Third-Party Services. We collect and process personal information and personal health information during intake using the Jane App for the purpose of booking, scheduling, billing, and charting. We also collect and process personal information and personal health information while providing online coaching services using the Jane App. From time to time, we may collect and process personal information and personal health information for the purpose of session planning. We also collect and process personal information and personal health information for delivering recommendations for natural health products sold and distributed by Fullscript. All payment transactions are handled securely by third-party services providers. When you provide payment information for the Services, it is transmitted directly to these providers through encrypted channels. We receive confirmation of payment status but do not retain full payment card details. Payment information is used by third-party services providers solely for processing transactions, issuing refunds where applicable, preventing fraud, and complying with legal, regulatory, and financial obligations. We may retain limited transaction records, such as receipts or payment confirmations, only as necessary to meet legal and accounting requirements.

(e) Automated Technologies or Interactions as you Navigate through the Website and the Platform. We may use automatic data collection technologies, including Google Analytics, to collect certain information about your equipment, browsing actions, and patterns. This will generally include information about your location, your traffic pattern through our Website or the Platform, and any communications between your computer and our Website or the Platform. Among other things, we will collect data about the type of computer you use, your Internet connection, your IP address, your operating system, and your browser type. The information we collect automatically is used for statistical data and will not include personal information or personal health information. We use this data to improve our Website, the Platform and our service offerings. To the extent that you voluntarily provide personal information and personal health information to us, our systems will associate the automatically collected information with your personal information and personal health information.

(f) Cookies and Pixels. Similar to other commercial websites, our Website and the Platform utilize a standard technology called “cookies” and server logs to collect information about how our Website and the Platform are used. Cookies are a small file placed on the hard drive of your computer. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our Website or the Platform, and websites visited just before and just after our own, as well as your IP address. We reserve the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites to tailor the advertising messages users see while visiting that social media website. We reserve the right to use these pixels in compliance with the policies of the various social media sites.

Third Party Use of Cookies

Some content or applications, including advertisements, on the Website and the Platform are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website and the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. You can opt out of several third-party ad servers' and networks' cookies simultaneously by using an opt out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Choices about How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information and personal health information that you provide to us. There are mechanisms to provide you with the following control over your information:

(a) Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of our Website or the Platform may not be accessible or may not function properly.

(b) Email Policies. We are committed to keeping your email address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as required by law.

All emails sent by us will comply with the Canada’s Anti-Spam Legislation (“CASL”), including clearly stating who the email is from and providing clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further email communication from us. Users who no longer wish to receive our newsletter or promotional materials may opt out of receiving these communications by clicking on the unsubscribe link in the email.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information and personal health information, for purposes of presenting our Website, the Platform and the contents of each to you, fulfilling the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it, providing you with information, providing you with offers for services, providing you with information about your subscriptions and services, carrying out any contract between you and us, administering our business activities, improving our Website and the Platform, our Services, marketing, or customer relationships and experiences, notifying you about changes to our Website, the Platform or any services that we offer or provide through it, providing customer service, making available other services to our customers and prospective customers, and for any other purpose with your consent.

From time-to-time, we may use the information you provide to us to:

(a) make you offers to purchase products and services provided by third parties in exchange for a commission to be paid to us by such third parties. Should you opt to take part in such promotions, the third parties will receive your information; and

(b) display advertisements to you that are tailored to your personal characteristics, interests, and activities.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Disclosure of Information

We will not disclose your personal information or personal health information for any purpose other than those outlined in this Privacy Policy or as otherwise permitted or required by law, unless we obtain your express consent. We disclose only the minimum amount of personal information and personal health information necessary to fulfill the identified purpose.

As a general rule, we do not sell, rent, lease or otherwise transfer any information collected either automatically or through your voluntary action.

We may disclose personal information and personal health information that we collect or that you provide as described in this Privacy Policy as follows:

(a) For continuity of care purposes, we may share your personal information and personal health information among your Authorized Providers and others who are directly involved in the provision of the Services to you.

(b) We may share your personal information and personal health information, including recordings of any sessions with Authorized Providers, externally and securely with advisors or providers as needed for consultations or supervision necessary to provide our Services and internally and securely with members of our team of review of our Services and educational purposes, which may include practitioners, employees, contractors, advisors, and agents that we work with to provide the Services to you. We may share information internally with practitioners, employees, contractors, advisors, and agents, using the Jane App.

(c) We may share your information, including personal health information, internally, with members of our team, and externally, with the Jane App and Fullscript, for the purpose of intake, booking, scheduling, billing, and facilitating the Services.

(d) In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information and personal health information held by us about our customers and users is among the assets transferred.

(e) To fulfil the purpose for which you provide it.

(f) For any other purpose disclosed by us when you provide the information.

(g) With your consent.

We may also disclose your personal information or personal health information:

(h) To a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and us.

(i) When legally compelled to do so when we, in good faith, believe that the law requires it, or for the protection of our legal rights, or when compelled by a court or other governmental entity to do so.

(j) To enforce or apply our Terms and Conditions (accessible here: https://www.elixhealth.ca/terms-of-use) and other agreements, including for billing and collection purposes.

(k) If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

Transferring Your Information

We may transfer personal information and personal health information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website and Platform improvement and optimization) and who are contractually obligated to keep personal information and personal health information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information and personal health information with the same standards set out in this Privacy Policy.

Because some of our practitioners are located outside of British Columbia, we may transfer such information outside of provincial borders.

We may process, store, and transfer your personal information and personal health information in and to a different province or foreign country during the provision of the Services to you. These different provinces and foreign countries may have different privacy laws that may or may not be as comprehensive as British Columbian or Canadian law, as applicable. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that province or country may be able to obtain access to your personal information and personal health information through the laws of the other province or foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Privacy Policy and applicable Canadian privacy legislation.

By submitting your personal information and personal health information or engaging with the Website or the Platform, you consent to this transfer, storage, or processing.

Security Measures

The security of your personal information and personal health information is very important to us. We use appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information and personal health information. Such measures will vary depending on the sensitivity, amount, format, nature, and storage of the personal information and personal health information and will involve, as applicable, physical, organizational, and electronic security measures, including premises security, restricted file access, technological safeguards including security software and firewalls to prevent unauthorized computer access, and password and security policies. We use an off-site storage facility provided by Jane App to process, store, and dispose of your personal information and personal health information. More information on Jane App’s security measures can be found on its Privacy Policy, accessible here: https://jane.app/legal/privacy-notice, and in Jane App’s Security FAQ, accessible here: https://jane.app/guide/security-faq.

Further security measures that we use include, but are not limited to, the use of locked filing cabinets (in the event we print any hard copies), the use of headsets during videoconference calls, the use of private rooms with a closed door during videoconference calls, and the conduct of business in facilities that are only accessible to persons with authorization to access such spaces.

In communicating with us, you should be aware that email is not a fully secure medium. We will use appropriate security measures when destroying your personal information and personal health information, such as by shredding documents and deleting electronic files.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information and personal health information, we cannot guarantee the security of your personal information and personal health information transmitted to our Website or the Platform. Any transmission of personal information and personal health information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website or the Platform.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information and personal health 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. Under some circumstances we may anonymize your personal information and personal health information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Consent Policies

Where you have provided your consent to the collection, use, and transfer of your personal information and personal health information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our Privacy Officer at info@elixhealth.ca. Please note that if you withdraw your consent, we may not be able to provide you with a particular service. We will explain the impact to you at the time to help you with your decision.

A) Standard Consent Policy

We will obtain your meaningful, express consent to collect, process, or disclose personal information and personal health information, except where we are authorized to do without express consent. Consent can be provided in writing, or it can be implied where the purpose for collecting using or disclosing the personal information or personal health information would be considered obvious and you voluntarily provide personal information or personal health information for that purpose. Consent may also be implied where you are given notice and a reasonable opportunity to opt out of your personal information or personal health information being used for marketing of new services or products and you do not opt out.

Subject to certain exceptions, you can withhold or withdraw your consent for us to use your personal information and personal health information by issuing written notice to our Privacy Officer. Your decision to withhold or withdraw your consent to certain uses of personal information or personal health information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist you in making the decision.

By taking all of the following actions, you provide consent to receiving the Services and to our procedures outlined in this Privacy Policy with respect to handling your personal information and personal health information:

(a) Reading and accepting our Terms of Use (accessible here: https://www.elixhealth.ca/terms-of-use), as may be updated from time to time.

(b) Reading and accepting our Privacy Policy, as may be updated from time to time.

B) When Consent Is Not Required

We may collect, use or disclose personal information or personal health information without your knowledge or consent in the following limited circumstances:

(a) When the collection, use or disclosure is permitted or required by law.

(b) In an emergency that threatens an individual's life, health, or personal security.

(d) When we require legal advice from a lawyer.

(e) For the purposes of collecting a debt.

(f) To protect ourselves from fraud.

(g) To investigate an anticipated breach of an agreement or a contravention of law.

Where we are prohibited from disclosing personal information or personal health information despite a request from someone authorized to do so, because disclosure could reasonably be expected to threated the safety, physical health, or mental health of an individual other than the person who made the request, or where disclosure can reasonably be expected to cause immediate or grave harm to the safety or the physical health or mental health of the individual who made the request, we will not make such disclosure.

Accessing and Correcting Your Information

It is important that the personal information and personal health information we hold about you is accurate and current. Please keep us informed if your personal information or personal health information changes. You are responsible for informing us promptly of any changes to your personal information or personal health information, such as updates to your contact details, medical history, or current medications. Failure to provide accurate or current information may limit our ability to deliver appropriate services. By law you have the right to request access to and to correct the personal information and personal health information that we hold about you. A request to access, correct, change, or request removal of personal information or personal health information must be made in writing to our Privacy Officer with sufficient detail to identify the personal information or personal health information being sought. Requests will be processed within 30 business days.

We will respond promptly to any request that you make to our Privacy Officer for access to your personal information or personal health information and will advise you of the cost, if any, prior to the retrieval of such records or information. We will not respond to requests for access to personal information or personal health information that are frivolous, vexatious or repetitious.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information or personal health information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information or personal health information that we hold about you, or we may have destroyed, erased, or made your personal information or personal health information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information or personal health information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer, Ray Siu, at info@elixhealth.ca.

Changes to This Policy

Elix Health may update this Privacy Policy from time to time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account, through a notice on the Website home page, or via the Platform.

We include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website or the Platform and this Privacy Policy to check for any changes.

Questions, Concerns and Contact

If you have questions about this Privacy Policy, or wish to access, correct, or withdraw consent for your data, or if you would like to access, correct, change, or request removal of your personal information or personal health information, you may contact our Privacy Officer, Ray Siu, as follows:

Email: info@elixhealth.ca

Phone: 237-757-5697

A request to access, correct, change, or request removal of personal information or personal health information must be made in writing to our Privacy Officer with sufficient detail to identify the personal information or personal health information being sought. We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information and personal health information, our compliance with this Privacy Policy, and with applicable Canadian privacy laws. To discuss our compliance with this Privacy Policy, please contact our Privacy Officer using the contact information listed above.

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