Just Sleep Care Inc.
Health Privacy Policy
Effective Date: 07/27/2026
This Policy applies to Just Sleep Care Inc. and its affiliates and subsidiaries (“Just Sleep Care,” “we,” “us,” or “our”).
Application of Policy
This Policy describes how Just Sleep Care collects, uses, and discloses information, and the safeguards we use to protect it.
This Policy does not apply to the collection, use, retention, disposal, destruction, and protection of information by the original equipment manufacturer of your WatchPAT, other wearable device, or PAP device ("Manufacturer") through your use of that device. Manufacturers are subject to privacy legislation and professional requirements governing their own recordkeeping and management of information, regardless of the tools they use to collect, use, disclose, or hold that information. Once information from your device is received by Just Sleep Care Inc. for example, as part of your test results or clinical record it becomes subject to this Policy. Please direct any questions about how a Manufacturer independently treats your information to the Manufacturer directly.
What Personal Information Do We Collect?
Patient Data
If you are a patient, you may provide personal information to us — for example, when you attend our virtual clinic to complete a sleep assessment, sleep study or begin your therapy. We also require information from your physician, such as medical information relevant to the treatment of obstructive sleep apnea or other sleep disorders. We may collect this information in person, by phone or video, through our website, from the device Manufacturer's software, from your insurance company, or whenever you communicate with us in connection with our products and services. Information we collect is shared only among Just Sleep Care personnel (including certified contractors and subcontractors) who need it to provide our services and perform their designated functions.
You are not obligated to provide us with information or to participate in any of our services. Any information you provide directly to us is considered voluntary. If you choose not to provide certain requested information, this may limit our ability to provide our services to you.
The information we may collect from patients typically includes:
• Contact details: such as your name, e-mail address, and telephone number.
• Identification data: such as date of birth, gender, and provincial health number.
• Clinical and consultation information: notes about your consultations with us, and other information relevant to your care.
• Lifestyle information: such as sleep patterns, daily routines, and other information relevant to assessing and monitoring your sleep disorder.
• Health information: such as symptoms, prescriptions, and other medical conditions that your physician or you may share with us to assist in providing therapeutic services
• Financial information: such as financial account information (e.g., bank account or credit card number) to charge you for services, and insurance provider information to confirm reimbursement coverage.
• Device information: such as your prior and current PAP device serial number, and any other information you voluntarily provide to us in connection with your care.
Manufacturer Data
Information Manufacturers provide to us, and that we provide to them: your ongoing and consistent use of the products and services we provide is critical to successful therapy. To help ensure an optimal therapeutic experience, we and the Manufacturer have access to data from your PAP device that allows us to assess the quality and progression of your treatment.
How Do We Use Your Personal Information?
Patient Data
We typically use patient data for the following purposes:
• Assessment: to understand your current situation and whether you have obstructive sleep apnea and, if so, its severity.
• Monitoring: to help ensure you are receiving the optimal therapeutic experience to treat your obstructive sleep apnea or other sleep disorder, including business purposes such as data analysis, identifying usage trends, creating anonymized data sets for research and analytics, and determining the effectiveness of our services.
• Order Fulfillment: if you place an order through our online portal, we share your name, address, telephone number, and order details with our third-party logistics provider to fulfill your order.
• Marketing Activities: with your consent, we send commercial electronic messages (such as newsletters, promotions, research, white papers, and event invitations) in accordance with Canada's Anti-Spam Legislation (CASL). Every marketing message includes a working unsubscribe mechanism, and you may withdraw your consent at any time.
Health and other sensitive personal information is subject to additional safeguards, including restricted internal access on a need-to-know basis. Where we intend to use your health information for a purpose beyond providing your treatment — for example, for research or marketing — we will obtain your express opt-in consent before doing so.
Manufacturer Data
We typically use Manufacturer Data:
• to store and update your details in our database (including adherence and usage data related to your PAP device) so that we can contact you regarding your treatment and provide you with services;
• to send you information about our services, promotions, research, and other information relevant to your use of a PAP device, in accordance with your marketing preferences;
• to perform certain legal obligations; and
• with your expressed consent, to help tailor the information and offers we send you. Declining this use will not affect your access to treatment or support.
Data Collected via Our Website
This section applies to personal information we collect and process through our website in the usual course of business, such as scheduling appointments, answering questions, promoting our services, and marketing activities. Information You Provide to Us Certain parts of our website may ask you to voluntarily provide personal information — for example, your contact details to complete surveys, subscribe to marketing communications, submit inquiries or communicate with us. We may also collect personal information offline, such as when you attend one of our events. You are not obligated to provide this information; if you choose not to, this may limit your ability to participate in certain services. How Do We Use Website Information? We typically use personal information collected through our website to: (i) respond to your requests; (ii) inform you about matters related to treatment; (iii) administer, protect, and improve our website and services; (iv) better understand the preferences of our visitors; (v) compile aggregated usage statistics; (vi) provide marketing and promotional communications in accordance with your preferences; (vii) analyze usage trends and improve our website services; (viii) to authenticate you as a website user and personalize your experience.
How We Share Your Information
We may share your personal information in the following ways:
• Within Just Sleep Care operations: your information is maintained on our secure corporate database, accessible only to the Medical Team who need it.
• With medical professionals who we understand are assisting in the treatment of your sleep apnea or other sleep disorder.
• Where required or permitted by law — for example, in response to a court order, subpoena, search warrant, or a lawful request from a government or regulatory authority, or where necessary to comply with a legal obligation.
• With Manufacturers or other third-party service providers who need to access or process your information for the purposes described in this Policy.
• With a potential buyer (and its agents and advisers) in connection with a proposed purchase, merger, or acquisition of any part of our business, provided we require the buyer to use your information only for the purposes disclosed in this Policy.
• With service providers who send marketing communications on our behalf. These providers are contractually restricted to using your information solely to deliver our communications and may not use it for their own purposes.
• With any other person, with your consent.
We do not use your information for purposes that are incompatible with those set out in this Policy.
Your Data Protection Rights
You have the following data protection rights:
• Access, correction, and deletion: you may access, correct, update, or request deletion of your personal information at any time by contacting us using the details below. We will respond to your request within 30 days of receipt, as required by Canadian privacy law. If we need additional time, we will notify you of the extension and the reason for it. Consistent with applicable law, when asked to remove a record, we will retain minimal personal information to prevent future contact and to keep a record of information previously disclosed.
• Opt-out of marketing: you have the right to opt out of marketing communications at any time by contacting us as outlined below.
• Withdraw consent: where we have collected and processed your personal information with your consent, you may withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing conducted before your withdrawal, nor processing conducted on other lawful grounds. If you withdraw consent, we will no longer follow up with you about your therapy or ongoing care and will consider our patient relationship with you at an end.
• Complain to a regulator: you have the right to complain to the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca, or to the applicable provincial privacy regulator, about our collection, use, or disclosure of your personal information.
We respond to all requests to exercise data protection rights in accordance with applicable law, and we do not discriminate against individuals for exercising their legal rights.
How Long Do We Keep Your Personal Information?
We retain your personal information for as long as needed to provide your treatment, and for a period afterward as required by applicable health-records retention rules in your province generally ten years after your last interaction with us. After that period, we securely destroy or anonymize your information. If you have questions about how long we retain your personal information, contact us using the details below.
How Do We Keep Your Personal Information Secure?
We take appropriate technical and organizational measures such as encryption, access controls, and staff training to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, at a level of security appropriate to the risk of processing your information.
Notwithstanding these safeguards, we cannot guarantee the security or error-free transmission or storage of information. Risks inherent in electronic transmission and storage including interception, loss, corruption, unauthorized access, and delay can be minimized but not eliminated. If a breach occurs that affects your personal information, we will notify you and the appropriate authorities as required by applicable law.
Breach Notification
In the event of a breach of security safeguards involving your personal information that poses a real risk of significant harm, we will notify you and report the breach to the Office of the Privacy Commissioner of Canada, as required by law. We maintain records of all breaches of security safeguards in accordance with applicable law.
Applicable Law
This Policy is intended to comply with applicable Canadian privacy law. Where we hold health information as a custodian under Alberta's Health Information Act (HIA), that Act governs our collection, use, and disclosure of your health information. For personal information not governed by HIA, the Personal Information Protection and Electronic Documents Act (PIPEDA) or substantially similar provincial legislation (such as Alberta's Personal Information Protection Act) applies, to the extent required by law. This Policy is also intended to comply with Canada's Anti-Spam Legislation (CASL) with respect to our electronic communications with you.
How to Contact Us
Please contact us with any comments, questions, complaints, or suggestions regarding this Policy.
Email: support@justsleepcare.com
Attention: Just Sleep Care Privacy Officer
Just Sleep Care Inc.
Changes to This Policy
This Policy was last updated on the Effective Date noted above. We will post any changes on this page and update the date accordingly. Please check this page periodically to stay informed of our current privacy practices.
