Privacy Policy

Lifestyle Evolution inc. D/B/A WellAware Care on its own behalf and on behalf of its affiliates and/or wholly owned subsidiaries (collectively referred to as “WAC”, “we”, “us”, or “our”), makes certain information available to you and facilitates your access to various services including, but not limited to, remote patient monitoring and the analytics derived from your data. 

While facilitating your access to the Services, WAC collects, uses, and discloses your personal information. WAC values our members, including you (“you”), and we respect your privacy. We are required by law to maintain the privacy of the personal information we collect about you and to provide you with notice of our legal duties and privacy practices. 

This Notice of Privacy Practices (“Notice”) describes the kinds of personal and medical information we collect, use, and disclose about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. This Notice also describes how you may access the information WAC has about you and the rights you have with respect to your personal information. Please review this Notice carefully. 

WAC must abide by the terms of this Notice while it is in effect. This Notice will remain in effect until WAC replaces it. WAC reserves the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable law. If WAC changes the terms of this Notice, you will be provided with an updated Notice and asked to agree to it before continuing to use WAC Services. If the provisions of this Notice conflict with any other privacy policies of WAC, then the provisions of this Notice shall prevail. 

Personal Information Collected and Maintained 

For the purposes of this Notice, personal information (“Personal Information”) is any information that may be used to identify you such as name, address, phone number, email, and includes your Personal Behavioral Information (“PBI”). 

When you use our Services, whether through our secure websites or mobile applications (“Platforms”), telephone, or any other manner, we collect the following types of Personal Information about you: 

Personal Information WAC Automatically Collects about You 

When you register and log in to the Platforms, WAC automatically collects certain information concerning the type of devices that you are using to access our Platforms. 

Personal Information You Provide to WAC 

During the course of you using the Services, you will provide, and WAC will collect, your PBI. PBI includes your past, present or future fall history, presence detection and sleep history including key vital sign metrics, such as RPM (respirations per minute) and BPM (beats per minute). The PBI WAC will collect during your use of the Services includes but is not limited to: 

• Name 
• Address 
• Birth date 
• Email address 
• Telephone number 
• Presence including length of time in a room 
• Quality of Sleep including vital signs 
• Fall history including current falls 

Personal Information WAC Collects About You From Other Sources 

Uses and Disclosures of Personal Information

As the provider of the WAC Services, WAC may use your PBI when supporting its clients, who are healthcare providers, through the provision of the following services: 

• Enabling healthcare providers to use telemedicine components of the system to facilitate care provided to the patient. 
• Safeguarding the PBI stored, processed, and managed in the system. 
• Limiting use of PBI to only the purposes identified by WAC’s clients in agreements and ensuring that staff only access the least amount of PBI required to meet the identified purpose. 
• Logging and reviewing events and activities such as access to PBI 
• Maintaining an enterprise-wide privacy program to support WAC’s compliance with the requirements of PBIPA and its regulations as well as our agreements with healthcare providers. We follow recognized standards in privacy, security, and information management to safeguard your PBI more broadly. 

Outside of the items above, WAC may use and disclose your PBI in connection with its management and operations, such as: 

• Providing customer service. 
• Training, conducting quality review assessments and performing improvement activities. 
• Care coordination and disease management. 
• For auditing, medical review, legal services, accounting, insurance, business planning, business management and other general administrative activities. 
• To develop new products or features and enhance our Services including the Platforms. 
• Ensure the proper functioning of our websites and Platforms. 
• For information technology services and cloud services. 

Disclosures to Third Party Service Providers 

For any of the above purposes, WAC may engage third parties to perform the function on its behalf. If any such third party must have access to your PBI in order to perform the Services, WAC will require that third party to enter into an agreement that binds the third party to the use and disclosure restrictions outlined in this Notice. Additionally, we will make sure the third party retains the Personal Information only for as long as is minimally necessary or as required by law. 

Your Rights with Respect to your Personal Information

Right to Access Personal Information

You have the right to obtain a copy of the PBI that WAC maintains about you. To access a copy of your PBI, you must submit your request in writing to WAC. WAC may impose a fee for the costs of copying, mailing, labor, and supplies associated with your request. WAC may deny your request to inspect and/or copy your PBI in certain limited circumstances. If that occurs, WAC will inform you of the reason for the denial, and you may request a review of the denial. 

Right to Correct Personal Information

You have a right to request that WAC amend your PBI if you believe it is incorrect or incomplete. You must submit your request in writing to WAC and provide a reason to support the requested amendment. WAC may, under certain circumstances, deny your request by sending you a written notice of denial. If WAC denies your request, will inform you of the reason for the denial, and you may request a review of the denial. 

Right to Withdraw Consent.

You At any time, you may draw your consent for us to collect, use, and disclose your PBI as outlined in this Notice. However, withdrawal of consent is subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your PBI as may be required to provide you with access to our Services, and to the extent required or permitted by law. If you refuse to provide us with PBI, or later contact us to withdraw your consent for us to use and disclose the PBI we have already collected, you may not be able to use our Services including our Platforms. At your request, we will delete your PBI unless we are required to retain it to meet our legal or regulatory obligations including provincial retention guidelines for healthcare providers. 

Right to ask questions or file a complaint.

If you have any questions or comments or wish to make a complaint about this Notice or WAC’s privacy practices, you have the right to contact us and speak to someone about your concern. 

If you wish to exercise any of these rights, ask questions about our privacy practices, make a complaint, or report a privacy or security violation, please contact us at: 

By Mail: Privacy Officer 

Lifestyle Evolution inc. 

110 Great Road 

Ste: 2-3-3 Box B-7 

Littleton, Ma 01460 

By Email: privacy@leiots.com  

By Phone: 978-506-5189 ext. 102 

If you contact us to exercise any of the rights above, we will respond to your request within a reasonable time and at no cost to you. 

Security of Your Personal Information 

We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards that are designed to protect the security and privacy of your Personal Information against loss, theft, and unauthorized access, disclosure, use or modification. Please note, however, that while we try to create a secure and reliable Platform for members, the confidentiality of any communication or material transmitted to or from the Platforms or via e-mail cannot be guaranteed. 

We limit access to your personal information within the Company to individuals on a need-to-know basis. WAC will retain your Personal Information only for a time and to the extent necessary for the purposes for which it was collected as described in this Notice and for reasonable backup, archival, audit, legal or other similar purposes. 

Cross Border Transfer of Personal Information

Personal Information may be transferred, processed, and retained on servers in countries outside of Canada, including the United States. 

• • If you use the remote patient monitoring services while you are located in Canada, your PBI will be stored on servers in Canada or the United States. 
  • If you use the remote patient monitoring services while you are located in the United States, all your PBI will be stored on servers in the United States and may be accessed by individuals in the United States and Canada.