Alere Wellbeing, Inc. (“we”, “us” or “our”) takes steps to ensure we meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation.  The purpose of this privacy policy (the “Privacy Policy”) is to inform the participants in our programs (“you” or “your”) how we use, disclose and protect personal information you provide to us.   Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation.  This Privacy Policy applies to our use and disclosure of personal information provided to us by participants in Canada.  This Privacy Policy does not apply to information that is not personal information.
 
Although our services are related to your health, Alere Wellbeing is not a medical treatment provider and our staff cannot provide medical treatment, diagnosis, or monitoring.  Alere Wellbeing programs should not be relied upon as a substitute for professional medical advice. Alere Wellbeing programs are intended to assist you with personal health improvement efforts through coaching, education and instruction.  Always continue to seek the advice of your doctor with any questions you may having regarding your medical conditions.
 
Personal Information Provided by Participants
Information you provide to Alere Wellbeing in the course of our delivering health related products and services to you may include personal information such as:  name, address, email address, telephone number, and other contact information; date of birth and gender; employment information, including the name of your employer and your employee ID number; personal health information relating to your enrollment and treatment in Alere Wellbeing’s programs, including but not limited to your medical history, family history, medication usage, the name of your healthcare provider; and such other identifiable information you may provide by any means, such as by telephone, online or by mail.
 
Use and Disclosure of Personal Information
Alere Wellbeing may use and share your personal information for the following purposes, including to: 
·       carry out our operations and assist with the administration and support of our business activities, including transferring personal information to third party agents or service providers (including affiliates of Alere Wellbeing acting in this capacity) that perform services on our behalf or otherwise use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy;
·       contact you or carry out your requests for health related products and services regarding your treatment in Alere Wellbeing’s programs; 
·       verify your eligibility and collect or otherwise enforce accounts , including the management of payment activities, employee/member incentives, billing or administering your health benefits;
·       develop and evaluate our programs, products and services;
·       assess and respond to feedback, questions, comments, requests, inquiries, or complaints;  
·       defend and bring legal actions; and
·       otherwise with consent or as permitted or required by law.
 
Other Uses and Disclosures of Personal Information
Alere Wellbeing may also use and disclose your personal information in the following circumstances:
 Research.  Alere Wellbeing may conduct research approved by an Institutional Review Board (“IRB”), a committee that protects participants’ rights and oversees research.  If you consent to take part in the research, the personal information collected about you (including, for example, your name, date of birth and medical history) may be reviewed by Alere Wellbeing and its representatives.  In conducting research, an identifier other than your name, (e.g., unique participant identification number) will be used to preserve your anonymity.  This de-identified information may be shared with other institutions connected with a research project for the purposes of analyzing the data, and may also be used to report adverse events.  In some instances, with IRB approval, Alere Wellbeing may conduct research using de-identified information without obtaining your consent.
 
Business Transactions.  Personal information may be used by Alere Wellbeing and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Alere Wellbeing or our business or assets, for the purposes of evaluating and/or performing the proposed transaction.  Assignees or successors of Alere Wellbeing or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.
 
Legal, Regulatory.  While your personal information is located outside Canada it is subject to the laws of the jurisdiction in which it is retained, including laws that may require disclosure of personal information to foreign government authorities, oversight agencies, public health authorities, health regulatory agencies, and government officials.  Alere Wellbeing may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, security and other related requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to Alere Wellbeing or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).

Consent
Consent to the use and disclosure of personal information you provide us may be given in various ways.  Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested).  You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any.  Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).  Generally, by providing us with personal information, we will assume that you consent to our use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time you provide the information. 
You may withdraw your consent to our use and disclosure of personal information you provide at any time, subject to contractual and legal restrictions and reasonable notice, except to the extent we have already made disclosures in reliance upon your consent.  Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services.  Further, where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Policy or otherwise at the time you provide the information, and you may not be permitted to withdraw consent to certain necessary uses and disclosures of the personal information. 

Security
Alere Wellbeing is located in the United States and your personal information will be collected, used, disclosed, stored and processed in the United States for the purposes described in this Privacy Policy.  We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.  Authorized employees, agents and mandataries of Alere Wellbeing who require access to your personal information in order to fulfil their job requirements will have access to your personal information. Alere Wellbeing service providers are located in the United States, and we take reasonable contractual or other measures to protect your personal information processed or handled by service providers.
 
Access, Correction and Contacting Us
Alere Wellbeing may establish and maintain a file of your personal information for the purposes described above, which will be accessible at our offices at 999 3rd Avenue, Suite 2100, Seattle, Washington, USA 98104.  If you wish to request access or correction of your personal information in our custody or control, you may write to our Privacy Officer at the above address. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.  If you wish to make inquiries or complaints or have other concerns about our Privacy Policy, our personal information practices, or if you would like more information about our policies and practices regarding service providers outside Canada, you may contact us as described above.  You may also contact us at the following program numbers: Quit for Life® Program: 1-866-QUIT-4-LIFE (1-866-784-8454), Weight Talk® Program: 1- 855-WGT-TALK (855-948-8255). 
Privacy Policy Changes
This Privacy Policy may be revised from time to time.  If we intend to use or disclose personal information for purposes materially different or not described in this Privacy Policy we will revise this policy.   We urge you to request and review this Privacy Policy frequently to obtain the current version by visiting our website at www.alerewellbeing.com or contacting us as described above.  Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes.  This Privacy Policy is effective as of March 20, 2013