Maple Corporation Privacy Policy

The following provides the meaning of certain terms used in this Policy. If not defined below, the capitalized words and phrases in this Policy have the same meaning as in Maple's Terms of Use.

"Maple Platform" means, collectively, the hardware, software, applications, websites, Content, products and services owned and/or operated by us to enable the provision of remote Healthcare Services to Users, among other purposes.

"Information" means, collectively, "Personal Information" (information about an identifiable User as further defined in Applicable Law) and "Personal Health Information" or "PHI" (information about an identifiable User's health or healthcare as further defined in Applicable Law).

A "User" is an individual registered to use the Maple Platform, including, unless otherwise specified, as part of a customized program provided by a third party. A "PCH User" is a User also registered to use Loblaw's PC Health application. Unless we make a distinction, "Users" means all Users.

Health professionals ("Authorized Providers") are, collectively, "Authorized Physicians" (physicians registered to practice medicine in a province or territory of Canada) and "Authorized Non-Physician Providers" (regulated health professionals other than physicians registered to practice in a province or territory of Canada) who are registered to use the Maple Platform to provide "Healthcare Services" within their scope of practice to Users. An Authorized Provider provides Healthcare Services through a "Consultation," which includes a review by the Authorized Provider to determine if the Healthcare Services requested by the Users are ones that can be provided on the Maple Platform.

"Applicable Law," in relation to Maple, Authorized Providers, or Users, means the laws and regulations, including privacy laws and regulations, to which each is subject.

"Content" means general information about health-related topics posted on the Maple Platform, access to which is not the delivery of Healthcare Services and does not replace and cannot be relied upon as Healthcare Services.

If you are an Authorized Provider, your arrangement with Maple - your rights and obligations and those of Maple - is set out in the agreement between you and Maple or, if you are providing Healthcare Services on behalf of a third party organization that has contracted with Maple, in the agreement between you and the third party organization with which you are associated.

If you are a User, the arrangement between you and Maple - your rights and obligations and those of Maple - is set out in the Terms of Use and, where applicable, supplementary Terms. The Terms of Use for PCH Users may differ from those for other Users to take into account supplementary Terms for use of the PC Health application.

This Policy describes Maple's management of Information, including the purposes for which we collect, use and disclose Information and the safeguards we use to protect Information. This Policy does not apply to the collection, use, retention, disposal, destruction, or protection of Information by Authorized Providers through the Maple Platform. The Authorized Providers who provide care to Users through the Maple Platform are responsible at law for the Information that they collect, use, disclose, and store via the Maple Platform. Please direct any questions you may have about how an Authorized Provider will treat your Information to the Authorized Provider.

The following is an overview of how the Maple Platform generally functions and how Maple collects and uses Information. The details of how the Maple Platform functions may vary by Consultation and Authorized Provider.

Healthcare Services

Authorized Providers collect Information about you (or any Registered Dependent, as defined below) that you provide before or during a Consultation. They may collect this Information in different ways, including through discussions with you during the Consultation, via text messages with you before the Consultation, or when you enter or upload Information to the Maple Platform before the Consultation. Authorized Providers also have access to other Information about you through the Maple Platform. This includes Information that you provide in your consultation request; Information you've entered or uploaded to profiles and medical records; Information created during your earlier interactions through the Maple Platform with other Authorized Providers; the name, email address, phone number, gender identity, date of birth and province/territory that you provided when you registered with Maple; and your emergency contact's name and contact information (if you have chosen to add an emergency contact to your account). Authorized Providers use this Information to provide you with Healthcare Services. As noted above, they must comply with the privacy legislation and medical record-keeping obligations to which they are subject. Authorized Providers may create Information in the Maple Platform, such as prescriptions, sick notes, and notes about your Consultation. They may export or print copies of your Information.

Authorized Providers may, but are not required to, email or text your emergency contact if they believe that you are presenting with a healthcare emergency. You are responsible for advising your emergency contact that you are providing their name and contact information to Maple and Authorized Providers, and for obtaining any necessary consent from your emergency contact for the provision and use of that information in connection with the Maple Platform.

Wellness Services

You have the option to sign up to receive Wellness Services from Maple, such as our Recommendations service, which sends you preventative health recommendations based on your health profile. If you sign up to receive one or more of our Wellness Services, you will be invited to provide Information about yourself (or any Registered Dependent) as part of your Maple Health Profile. This may include, for example, Information about your health and wellness interests, your demographic data, and your health history. Maple will collect this Information and use it to provide you with any Wellness Services for which you sign up. The data created through your use of our Wellness Services is used to further enhance and tailor your experience by suggesting similar Wellness Services to you that you may be interested in. For example, if a User who chooses to receive a Wellness Service related to dermatology, we may recommend other dermatology-related Wellness Services to them.

Other Services

Maple provides services that support the provision of Healthcare Services. These services may include receiving, reviewing, and scanning or otherwise uploading laboratory test results to the Maple Platform; faxing prescriptions to pharmacies; obtaining referrals for consultations with specialists; and collecting Information required for scheduled appointments (such as health card numbers or information from referral letters). Maple provides some of these services to Authorized Providers (for example, the receipt and preliminary review of laboratory results) and some to Users (for example, faxing prescriptions and arranging referral to specialists). These services require the use of Information.

Maple may also provide services through the Maple Platform that are healthcare-related but not Healthcare Services (such as navigational services to assist you to access Healthcare Services on the Maple Platform). Unless otherwise advised, Maple Personnel will deliver these services.  Maple Personnel receive privacy and security training and commit to complying with Maple's obligations in connection with Information, as described below in the section on Safeguarding Information.

Other Collections and Uses of Information

Maple uses Information to the extent necessary to develop, evaluate, improve, provide, and support the Maple Platform and its various services. We may also use Information for loss prevention, to prevent fraud, and to comply with legal requirements. We do not collect or use Information if non-identifying information will suffice. We do not record the audio or video portions of Consultations.

For more information about how Maple collects and Uses Information when you create your Maple account, use our Healthcare Services, and use our Wellness Services, please see the section of this policy entitled "More information on how we collect and use your information".

Third party service providers

Maple uses third party software and service providers for a variety of services, such technical, operational, and marketing services.  For example, our live User support chat (through which Users may get troubleshooting and related technical assistance) is provided through a third party service provider. We require our third party service providers to limit their use of Information to what is necessary for their services. We also require them to have security measures in place that are appropriate for the protection of Information. Some of our service providers operate from outside of Canada, which means that Information they use to provide their services to us will be subject to the laws of other jurisdictions and may be available to foreign government authorities under lawful orders and laws applicable in those jurisdictions.

For additional details about Maple's third party service providers, please see https://www.getmaple.ca/subprocessors/.

Third party payers

As described in the Maple Platform Terms of Use, by authorizing someone else (a "Third Party Payer") to pay the Fees and/or Membership Fees for your Healthcare Services or Wellness Services, you are representing to Maple, and Maple will rely on your representation, that you consent to Maple:

1. using the email address provided to us by the Third Party Payer to communicate with you regarding the Maple Platform and Healthcare Services or Wellness Services;
2. disclosing to the Third Party Payer that you have requested Healthcare Services or Wellness Services, to permit Maple to process payment for the Healthcare Services or Wellness Services; and
3. notifying the Third Party Payer of any changes to or termination of your access to the Maple Platform.

If you have questions about the Information shared between us and Third Party Payers, please contact us as indicated below.

Emergency contacts. We may disclose Information to emergency contacts as described above.

Third parties, on consent. We may disclose Information to third parties with User consent. For instance, we may disclose Information to the extent needed to an insurer or other Third Party Payer for the purpose of facilitating payments and benefits plans.

Compliance, Fraud Prevention. We disclose Information to the extent required to comply with Applicable Law, including to respond to a subpoena, order, or similar obligation to produce information; and to establish or exercise Maple's legal rights, including to defend against legal claims and to detect, investigate, suppress, prevent or take action regarding illegal or prohibited activities, such as suspected fraud and threats to the reputation or safety of any person.

Business transactions. We may disclose Information for the purposes of conducting required due diligence or the completion of a business transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including agreements and notice requirements that apply to the disclosure of Information for such transactions.

Unless we notify you otherwise, we will retain your Information on the Maple Platform until you (or Maple) close your Account. On termination, for a limited time, you will be able to print or copy your Information held in the Maple Platform, except for any private notes of Authorized Providers. Any request for access to an Authorized Provider's notes should be made directly to the Authorized Provider outside of the Maple Platform. If you are having trouble finding the provider you consulted with, our Customer Support team may be able to help. Please contact us directly at support@getmaple.ca.

After the time period during which you may print or copy your Information has ended, we will securely delete the Information associated with your Account, except for any Information that Maple is required to retain under Applicable Law or Information required by an Authorized Provider in connection with Healthcare Services. Maple will delete the latter once the Authorized Provider makes a copy of the Information or terminates their account with Maple. When Information is deleted, it is removed from our active database. Any Information that remains in our backup is securely stored and isolated from any further processing until deletion is possible.

You can access your Information or that of your Registered Dependents by logging in to your Account at https://app.getmaple.ca/login.

You may update or otherwise correct your Information at any time, except Information that an Authorized Provider has viewed or created. Any request to update or correct Information that an Authorized Provider has viewed or created should be made directly to the Authorized Provider outside of the Maple Platform.

The Maple Platform enables you to make choices to enhance the protection of your privacy. For example:

• You may enable two-factor authentication on your Account to help prevent unauthorized access. If you enable two-factor authentication, then to log into your Account, in addition to entering your password, you will have to enter a code that we send separately to your mobile number. This added security means that a third party would need both your login information and your mobile phone to access your Account.
• You have the option of using audio, chat, or video for your Consultations.
• When requesting a Consultation, you may choose to withhold Information, for example Information contained in your healthcare records, from the Authorized Provider. Please be aware that Authorized Providers may be unable to provide you with Healthcare Services as a result. They will advise you of the implications of your choice.
• You may choose whether to receive communications from Maple by email or SMS.
• You can check your login history when you access the Maple Platform.

Please contact us directly at support@getmaple.ca if you require assistance with these options or more generally have questions about how to use the Maple Platform. To protect your privacy, we may request information to verify your identity when you contact us.

We permit Maple personnel ("Personnel," which includes our employees, contractors and subcontractors) to access Information only to the extent necessary to perform their designated functions. We require Personnel to complete privacy and security training and to commit to protecting Information by complying with our policies, procedures and Applicable Law.

We store your information in electronic format within Canada, using computer systems with restricted access and that are housed in facilities using physical security measures.

More generally, we have in place appropriate physical, technological, and organizational safeguards, including access controls, to protect Information against loss, theft, and unauthorized access, use and disclosure. Notwithstanding the safeguards we employ and our commitment to protecting Information, we cannot guarantee the security or error-free transmission or storage of Information. There are risks inherent in the use of electronic means to transmit and hold information in electronic format. These risks can be minimized but not eliminated by the use of appropriate security measures, such as the measures Maple employs. These risks include interception, loss, corruption, unauthorized access to, use and disclosure of Information, and delay in the availability of Information.

You play an important role in protecting and the privacy of your Information. We ask you to do the following.

• Create a strong and unique password for your Account using Maple's password strength estimator and update your password periodically.
• Do not share your Account or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please do not provide it and contact us if you receive such a request.
• Log out of your Account as soon as you finish using it, especially if you share the device you use to access the Maple Platform with anyone else.
• Password-protect your device with a strong and unique password.
• Choose a quiet, private location from which to receive Healthcare Services.

Maple obtains the authorization of Authorized Providers to collect and use non-identifiable data about their use of the Maple Platform ("Data"). This may include, for example, non-identifiable information about the number of consults carried out by Authorized Providers on the Maple Platform or the symptoms most commonly treated by Authorized Providers using the Maple Platform. Maple may use Data to monitor the compliance of Users and Authorized Providers with the Maple Platform terms of use, to make the use of the Maple Platform more accessible and enhance the Maple Platform experience for Users and Authorized Providers, and to design optional surveys for Users. We may also use or disclose Data for  internal product development purposes or for duly approved research projects. We will not use Data to re-identify Users or for any other purpose prohibited by Applicable Law. 

The Maple Platform and Maple's email messages and marketing materials use "cookies" and other technologies such as pixel tags and web beacons. We use these technologies to better understand the use of the Maple Platform, analyze trends, and administer, personalize and improve the Maple Platform user experience for Users and Authorized Providers. For more information about our use of cookies and your ability to accept or decline our use of cookies, please refer to our Cookie Policy, posted at https://www.getmaple.ca/cookie-policy/.

The Maple Platform may contain links to websites that we do not own or operate. The provision of these links is not an endorsement of or referral to the linked websites. We provide the links solely for your convenience. We strongly encourage you to review the privacy policies and terms of use applicable to any website you visit. This Policy does not apply to linked sites or pages and we are not responsible for the content or privacy practices applicable to them or used by their operators.

Maple last updated this Privacy Policy ("Policy") on March 3, 2025. We post the current version of the Policy at www.getmaple.ca/privacy. We reserve the right to amend the Policy at any time to account for changes in Applicable Law, our practices and the Maple Platform. Please check to see if we have amended the Policy since you last used the Maple Platform to ensure you are aware of (and agree to) our current privacy practices.

If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance Officer. Please include your name and contact information if you would like us to respond to you.

Maple Corporation
ATTN: Roxana Zaman - Chief Compliance Officer
privacy@getmaple.ca
(888)-886-4724
201-225 Richmond Street West
Toronto, Ontario
M5V 1W2

The following table gives you more information on how and for what purposes Maple collects and uses Information when Users create their Maple accounts, use Maple's Healthcare Services, or use Maple's Wellness Services.

When you create your Maple Account:

Healthcare Services

Wellness Services

In addition to receiving Maple's Healthcare Services, you have the option to sign up to receive Wellness Services from Maple, such as our Recommendations service, which sends you preventative health recommendations based on your health profile. If you sign up for a Wellness Service, your Information will be used as described below. If you do not sign up for any Wellness Services, this chart does not apply to you.