PRIVACY NOTICE
Introduction
Thrive Health (“Company”, “we” or “us”) is committed to respecting individual privacy and protecting the Personal Information that we collect, use and disclose.
This Privacy Notice is designed to provide transparency regarding our privacy practices with respect to the use and disclosure of the Personal Information we collect when you use a Thrive Health product and related services (“Product”) or when you otherwise interact with us.
Please read this Privacy Notice carefully. By using the Product or otherwise interacting with us, you consent to the collection, use and disclosure of Personal Information in accordance with the terms of this Privacy Notice. If you do not want us to collect, use or disclose your Personal Information in the ways identified in this Privacy Notice, you should not use the Product.
Scope of this Privacy Notice
We offer the Product to individual end users and to organizational users, such as hospitals and other healthcare providers. Depending on how the Product is used and who is using it, we may collect, use and disclose Personal Information either directly on behalf of individual end users (including to help individual users manage and access their health records or share their health records with organizational users), or on behalf of organizational users.
This Privacy Notice does not apply to the extent we process Personal Information in the role of a processor or service provider on behalf of our customers who are organizational users, such as hospitals or other healthcare providers. It is that customer’s privacy statement that applies; we conduct such activities strictly in accordance with our customer’s instructions and pursuant to our contractual arrangements with the customer. If you are a patient or consumer with an existing relationship with one of our customers, you should refer to the customer’s website to understand their privacy practices and policies.
Personal Information
“Personal Information” is information about an identifiable individual and includes but is not limited to contact information (email address, phone number), personal health information, name, age, and gender. To the extent that this information is collected or provided through the Product and can be used to identify an individual, we will treat it as Personal Information in accordance with this Privacy Notice.
Personal Information does not generally include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.
Collection of Personal Information
We may collect, use and disclose different types of Personal Information, depending on our relationship with you.
Collection of Personal Information via the Product
When using the Product, you will be asked to provide certain Personal Information. The specific information collected depends on the functionality you use within the Product. The categories of Personal Information we may collect include:
- identifiers and demographic information (such as name, age, date of birth, and gender);
- contact information (such as email address, phone number, and mailing address);
- account and authentication information (such as the credentials you use to access the Product);
- health information (such as allergies, medications, immunizations, medical conditions, family medical history, lab results, symptoms, and descriptions or images you choose to share about a health concern, and medical documents or records you upload);
- information generated through your use of the Product (such as interactions with features, content you create or submit, and preferences you set); and
- technical and usage information (such as device identifiers, log data, and information about how you access and interact with the Product).
We will use this Personal Information primarily to provide the functionality you use within the Product. We may also use information generated through your use of the Product and technical and usage information to improve our products and services. If you consent, we may also use your demographic and health information for research purposes in limited circumstances. We use your contact information to communicate with you about your use of the Product and to send you information on our products or services that may be of interest to you. The purposes for which we use Personal Information are described in more detail below.
You may refuse to supply Personal Information to us but be aware that this can prevent you from engaging in certain activities in relation to the Product.
Collection of Personal Information via www.thrive.health
We may collect certain Personal Information that you voluntarily provide when using www.thrive.health, including through webforms and other interactions on the site. This information may include, but is not limited to:
- First and last name
- Email address
- Phone number
- Job title
We collect and use this information for the purpose of communicating with you in connection with your request.
De-Identified Information
We may remove personal identifiers from your Personal Information and maintain and use it in a de-identified form or combine it with other information to generate aggregated information. Other information includes but is not limited to technical information about the device, system and application software that you use to access the Product. We may use this de-identified information for any purpose internally, such as to improve our products and services and perform statistical analyses and generate data related to how users use our Product.
Consent
You have control over how your Personal Information is used and disclosed and you can give or withdraw your consent at any time and without penalty.
We may collect, use and disclose your Personal Information with your consent. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the Personal Information in question. Generally, we will seek your consent at the time we collect your Personal Information, either orally, electronically, or in writing.
If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their information as described in this Privacy Notice.
At any time and without penalty, you can withdraw your consent to the use and disclosure of your Personal Information and delete your account. You can delete your account directly within the Product through your account settings. If you need assistance, email support@thrive.health and we will process your request.
In certain circumstances, we may collect, use and disclose your Personal Information without your consent to the extent permitted or required by law.
Using Personal Information
We will use your Personal Information to provide you with the Product and all related services, products, and functionalities that you sign up for, and for the other purposes described above. We may also use Personal Information to:
- Assist you with technical support issues. Most technical issues can be resolved without our support team viewing your Personal Information.
- Comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect ourselves and other individuals from harm.
- For other purposes that you may consent to from time to time.
Sharing Personal Information
The functionality of the Platform may allow you to share your Personal Information with other organizations. We may also disclose your Personal Information to a third party for the purposes identified below. We do not sell your Personal Information.
Personal Information is only shared through the Product with organization(s) of your choice, by accepting an invitation from an organization, using an organization’s registration code, or signing up in any similar way through the Product. An organization could be a doctor’s office, hospital, your employer, a business you are visiting, a foundation you engage with, a caregiver or support worker, or an allied health care provider. Your Personal Information will not be shared with any other organization via the Product without your consent. We make every effort to ensure that you are aware of what Personal Information is being shared with each organization and to ensure that the receiving organization receives only the Personal Information that you have consented to sharing. Once in receipt of your Personal Information, the receiving organization is solely responsible for ensuring your Personal Information is available to the appropriate people within their organization.
We may also disclose your Personal Information when we believe such disclosure is required or permitted by law. We may disclose your Personal Information to other third parties in relation to a merger, acquisition, or any form of business transaction. Your information may be provided to the entities and advisors involved, for the purposes of determining whether to proceed with the transaction and, where applicable, to conclude the transaction. Your information may be transferred to a successor business as part of the process of assigning all or part of our assets to the successor business.
Retaining Personal Information
We keep your Personal Information for as long as necessary to fulfill the purposes for which it was collected, or until you ask us to delete it.
If we use Personal Information to make a decision that directly affects you, we will retain that Personal Information for at least one year after making that decision so that you have a reasonable opportunity to request access to it.
Subject to the above, we will retain Personal Information only as long as necessary to fulfill the identified purposes or as permitted or required by law. Because one purpose is to assist you with the management of your Personal Information, including the personal health information that you provide when using our Product, we will keep your Personal Information until you delete your account or let us know that you no longer require our assistance.
Accuracy of Personal Information
You are responsible for keeping your Personal Information up to date and accurate.
We rely on you to ensure that the Personal Information you provide while using the Product or a related Service is accurate, complete and up-to-date. You are welcome to make changes, request deletion or corrections to Personal Information at any time by updating your account and information in the Product and its settings.
Safeguards
We take reasonable steps to protect your Personal Information. We train our team to follow privacy and security best practices.
We maintain appropriate storage and processing practices and security measures in an effort to protect your Personal Information from unauthorized access, collection, use, disclosure, copying, modification or disposal or destruction. We train our team to follow privacy and security practices.
Using contracts, we require that any third party acting on our behalf in respect of your Personal Information maintains reasonable and appropriate safeguards.
We will review and update our security policies and controls as technology changes in an effort to ensure ongoing Personal Information security, however, please bear in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you share with us.
It’s important to guard your privacy when you are online. If our Products or related Services contain links to other websites, this Privacy Notice does not govern those websites. Whether we have posted those links or other organizations or individuals have, you should read their privacy policies and make an informed decision about whether you want to use those websites or their services.
Location of Services
Your Personal Information is generally stored in Canada. To enable or support our platforms, we make use of certain third-party service providers to perform a variety of services on our behalf, such as data storage, payment card processing, marketing, and technical support. Some of these service providers may process your Personal Information outside of Canada. When your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada, and those laws may require disclosure of your Personal Information to authorities in that country.
For more information about our policies and practices regarding service providers outside of Canada, contact us at privacy@thrive.health.
Individual Privacy Rights
You may access, make corrections to, or delete the Personal Information we hold about you at any time directly within the Product through your account settings. If you need assistance, email support@thrive.health and we will process your request, subject to limited exceptions. Upon written request, we will also provide you with a list of individuals or entities (e.g., third party service providers) to whom we have disclosed your Personal Information, if applicable. We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Please contact our Privacy Officer at privacy@thrive.health for additional information.
If we are processing your Personal Information on behalf of our customer, we may refer your access or correction request to that customer.
Tracking Technologies
We use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our Product and website and your interaction with our emails. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage.
We use this information to facilitate the use of our Product and website, for our business or analytical purposes (including to collect application usage metrics to better understand how our Products are being used and to improve our Product), and to personalize web pages according to your choices and interests.
We may also use this information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our Product and website, and across third-party websites or service offerings when you leave our Product or website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests.
To accept or decline cookies associated with our website, you may adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. Some areas or features of our Product and website rely on cookies and may not work if you delete or decline cookies.
Opting Out of Marketing Communications
You can opt-out of marketing communications.
If you no longer want to receive email updates about our products and services, you may opt out by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt out by contacting us directly at support@thrive.health. If you opt out from receiving these emails, we may still need to send you communications about your use of our Product or services, or other matters.
Changes to this Privacy Notice
We may make changes to this notice. We will notify you of any changes and/or modifications to our information practices when appropriate.
We may update this notice to reflect changes to our information practices. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification if appropriate). Prior versions of this Privacy Notice are archived for your review here.
We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices and to contact us if you have any questions or concerns.
Questions and Complaints
You can email privacy@thrive.health for more information.
You may send your privacy-related questions, concerns or complaints to our Privacy Officer who is responsible for ensuring our compliance with this notice and with the appropriate privacy legislation.
Email: privacy@thrive.health
Mailing Address:
250 - 25th Street West Vancouver, British Columbia V7V 4J1
If our Privacy Officer is unable to resolve your concern, you may also write to the Information and Privacy Commissioner of British Columbia, Information and Privacy Commissioner of Ontario or equivalent for your province.
Last updated: May 21, 2025