Privacy Policy

Last modified: June 2025.

Right at Home Canada (hereinafter referred to as “we”, “us”, “our”, or the “Company”) respects customer privacy and is committed to protecting it by complying with its privacy policy (the “Privacy Policy”).

This Privacy Policy applies to all individuals who utilize our services, including but not limited to nursing, personal support, homemaking and other in-home care services (the “Services”).

This Privacy Policy describes:

• How we collect use, disclose, and protect the information you provide to us.
• Describes the types of information we may collect from you in the course of providing the Services.
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy is incorporated into, and subject to, our further terms and conditions as set forth on our website including, without limitation, our terms pursuant to the links titled Website Accessibility, Online Accessibility Statement, Sitemap, Disclaimers, Cookie Policy and Do Not Sell My Information (the “Terms and Conditions”) which can be found on our website at https://www.rightathomecanada.com. Any capitalized terms used but not defined in this Privacy Policy take the meaning ascribed in our Terms and Conditions.

We will only use your personal information (“PI”, as further defined below) and personal health information (“PHI”, as further defined below), when applicable, in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the PI and PHI that we collect about you is adequate, relevant, not excessive, and only used for the purposes which it is collected or purposes otherwise disclosed to you.

This Privacy Policy applies to PI, PHI, and other information we collect from you obtained:

During the provision of Services to you, including through oral disclosures with our staff. In some instances, PHI and PI may be collected through the use of artificial intelligence-powered audio recording technology (the “Technology”) developed by our partner, Sensi.AI, which assists in the provision of the Services. If the Technology is used during the provision of Services to you, a separate acknowledgement and consent shall be provided for your review and approval before such Technology is utilized.

In email, text, and other electronic or written messages between you and the Company.

Through the utilization of third parties by the Company. If we provide your PI and/or PHI to third parties we require that third parties are contractually obligated to keep PI and PHI confidential and secure, and use it only for the purposes for which we disclose it to them, and to process the PI and/or PHI with the same standards set out in this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, storing, using and disclosing information. If you do not agree with our policies and practices, we may not be able to provide with the Services or any portion thereof. By utilizing the Services, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy. This Privacy Policy may change from time to time. Modifications to this Privacy Policy will be made available through our website (https://www.rightathomecanada.com) with the date of the latest version and will comply with applicable laws. By continuing your use of the Services after we make changes to our Privacy Policy, you acknowledge you have read and understood the updated Privacy Policy and agree to be bound by the changes therein. We may also communicate changes through other electronic means such as email, in-person or by any other means from time to time.

We collect and use various types of information from and about you, including but not limited to:

Personal Information (“PI”). Includes data that reveals something personal about an identifiable individual and is protected by law, such as given name, surname, date of birth, mailing address, e-mail address, telephone number, mobile phone number, Internet protocol address used to connect your computer to the Internet, user name or other similar identifier, and any other identifier that can be used to contact you. This definition encompasses PHI. We collect PI to provide you with the Services, including, but not limited to:

When you sign up and/or utilize the Services and during the provision of the Services, we collect your name, home address, and PHI as reasonably necessary, amongst other data, including data collected by the Technology if such Technology is part of your Services. When you send us messages, feedback, questions, or leave comments with us, we collect your contact information and the content of your communications. When you file a complaint with the Company, we collect your name, email address, mailing address, phone number, and information about the reason for your complaint and the resolution sought.

Personal Health Information (“PHI”). We also collect relevant PHI in the provisions of the Services. PHI includes identifying information about an individual in any form, where the information:

Relates to the physical or mental health of the individual, including family health history; Relates to the provision of health care to the individual or identifies healthcare providers; Includes a service plan for the individual; Pertains to payments, healthcare eligibility, or coverage; Concerns the donation of body parts or substances, or is derived from testing or examination; Includes the individual’s health number or identifies their substitute decision-maker; or Any other information about an individual that is included in a record containing any of the above information.

Non-Personal Information. We may also collect information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from PI and PHI.

2. HOW WE COLLECT INFORMATION ABOUT YOU

The Company uses different methods to collect your information, including but not limited to, through:

Direct interactions with you when you provide it to the Company, for example, by filling in forms, communicating with staff or corresponding with us regarding use of the Services.

Direct interactions when you use the Services, for example, when a Company staff member assists you at your home or any other location that Services may be rendered.

Automated technologies or interactions, if the Technology is being utilized in the provision of the Services, PI and/or PHI will be collected automatically through artificial intelligence-powered audio recording.

Interactions with your legal representatives or guardians, if you have such legal representatives or guardians and the information is provided to us for purposes of providing you with the Services.

Information You Provide to Us

The information the Company collects directly from you on or through provisions of the Services may include:

• Information that you provide by filling in forms online or in-person prior to or during the provision of Services. This includes information provided at the time of registration, application or approval. We may also ask you for information when you report a concern regarding the provision of the Services or to change the level or type of Services.
• Records and copies of your medical history, care needs, or correspondence if you or your legal representatives or guardians provide such information to us.
• Information that you provide through direct interactions with our staff.
• Information We Collect Through Automatic Data Collection Technologies.

If included in the Services provided to you, the Technology analyzes audio data collected from one or more audio processing devices installed in a client’s home and with the assistance of artificial intelligence technology, identifies patterns and anomalies that may indicate changes in an individual’s health as well as provide insights into possible instances where care is needed. Should you wish to use RAH’s services that involve the Technology, a separate acknowledge and consent form will be provided to you.

3. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any PI and/or PHI:

• To provide you with the Services or with information regarding the Services on behalf of the Company and its affiliates.
• To fulfill 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.
• To provide you with notices about your inquiries or applications relating to the Company’s Services, if applicable.
• To carry out our obligations and enforce our rights arising from any contracts with you and to comply with legal requirements.
• To notify you about changes to the Services or any other products or services we offer.
• To continually improve and personalize the Services we provide you.
• To respond to your questions, comments, and concerns.
• To perform quality assurance, marketing, and business analysis.
• To organize promotional activities.
• To provide you with surveys with regards to the Services, in accordance with applicable laws or with your consent (if required).
• To optimize management and administration of our business.
• To maintain compliance with our internal policies and procedures.
• To protect against fraud or error.
• To comply with legal and auditing requirements.
• To investigate breaches of the Privacy Policy and the Terms and Conditions.
• To collect debts owed to us by you, if applicable.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Additionally, we may use and disclose PI and/or PHI we have collected from you when we believe such use or disclosure is permitted, necessary, or appropriate under applicable laws including laws outside your country of residence, to comply with legal processes, to respond to requests from public and government authorities including public and government authorities outside your country of residence, to enforce the terms of the agreements for our products and services, to protect our rights, operations, and property, to allow us to pursue available remedies or limit damages that we may sustain. We may also transfer your PI and/or PHI and other information to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, brands, affiliates, subsidiaries, or other assets.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose PI and/or PHI that we collect or you provide as described in this Privacy Policy:

• To emergency personnel or healthcare personnel as may be required from time to time.
• To contractors, service providers, and other third parties we use to support our business or the provision of the Services and who are contractually obligated to keep PI and/or PHI confidential, use it only for the purposes for which we disclose it to them, and to process the PI and/or PHI with the same standards set out in this Privacy Policy.
• To an acquirer, successor, or assignee, in accordance with applicable law, in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PI and/or PHI held by the Company about our customers and users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• For any other purpose, with your consent.

We may also disclose your PI and/or PHI:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our Terms and Conditions and other agreements
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• If we provide your PI and/or PHI to third parties for the purposes of communicating with you directly, we require that third parties are contractually obligated to keep PI and/or PHI confidential and secure, and use it only for the purposes for which we disclose it to them, and to process the PI and/or PHI with the same standards set out in this Privacy Policy. We do not authorize third-party providers to disclose your PI and/or PHI to unauthorized parties.

In this context, such third-party partners are acting on their own behalf. We do not control their practices regarding your PI and/or PHI. This Privacy Policy does not govern any third-party products and services, which are subject to their own contracts and privacy policies with the relevant third-party partner. These third-party partners may also be the subject of an additional contract with us.

5. STORING AND TRANSFERRING YOUR PI AND/OR PHI

We may transfer PI and/or PHI that we collect or that you provide as described in this Privacy Policy to emergency personnel, healthcare personnel, contractors, service providers, and other third parties we may use to support our business who use it only for the purposes for which we disclose it to them, and to process PI and/or PHI with the same standards set out in this Privacy Policy.

Your PI and/or PHI may be stored and processed in Canada and/or in the United States (“U.S.”) and thereby subject to privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the U.S. may be able to obtain access to your PI and/or PHI through U.S. law. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Privacy Policy and applicable Canadian privacy legislation.

You are encouraged to contact us to obtain further information about our policies regarding service providers outside of Canada.

By agreeing to use the Services, you consent to our information transfer, storage, and processing practices

6. DATA SECURITY

The security of your PI and/or PHI is very important to us. We use physical, electronic, and administrative measures designed to secure your PI and/or PHI from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet or electronic storage is not completely secure. Although we do our best to protect your PI and PHI, there are inherent risks involved in the transfer and storage of data, and we cannot guarantee absolute security. In the event of a data breach or leak effecting your PI or PHI, the Company will notify you of such breach.

7. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, the Company will only retain your PI and/or PHI 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 PI and/or PHI 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.

8. ACCESSING AND CORRECTING YOUR PI AND/OR PHI

It is important that the PI and/or PHI we have on file about you is accurate and current in order to provide you with the Services. Please keep us informed if your PI and/or PHI changes. By law you have the right to request access to and to correct the PI and/or PHI that we have on file about you.

You can review and challenge the accuracy and completeness of your PI and/or PHI and have it corrected as appropriate by sending a request to our Privacy Officer at [email protected].

If you want to withdraw consent to the use of your PI and/or PHI you may also send us an email to [email protected] to delete any PI and/or PHI that you have provided to us, to the extent such data is within our control.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the PI and/or PHI 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 PI and/or PHI that we hold about you, or we may have destroyed, erased, or made your PI and/or PHI anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your PI and/or PHI, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your PI and/or PHI, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their PI and/or PHI.
• Information that is prohibitively expensive to provide.
• If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected].

9. WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your PI and/or PHI, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us via email using the contact information in the “Contact Us” section of our website. However, before we implement the withdrawal of consent, we may require proof of your identity or quality. Please note that if you withdraw your consent we may not be able to provide you with the Services or any portion thereof. We will explain the impact to you at the time to help you with your decision.

10. CHANGES TO OUR PRIVACY POLICY

The Privacy Policy is current as of the “updated” date which appears at the top of this Privacy Policy. It is our policy to post any changes we make to this Privacy Policy with a notice that the Privacy Policy has been updated on the Company’s home page at (https://www.rightathomecanada.com). If we make material changes to how we treat our users' PI and/or PHI, we will notify you by email to the primary email address specified in your account or through a notice on our website’s home 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 and this Privacy Policy to check for any changes.

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at:

• Dani DePetrillo
• Phone toll-free number at 1-855-983-4663 during regular business hours
• Email: [email protected]

We have procedures in place to receive and respond to complaints or inquiries about our handling of PI and PHI, our compliance with this Privacy Policy, and with applicable privacy laws. To discuss our compliance with this Privacy Policy please contact our Privacy Officer using the contact information listed above.