Last Updated: January 31, 2022

Your privacy and safety of your personal information is important to Tutela. It is our priority to keep your information safe and secure.

Tutela Care Ltd. and its corporate affiliates ("Tutela", "we", "us", "our") respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you. Based on applicable privacy and data protection principles common to Canada, we have developed this privacy policy (the "Policy") to explain our practices for processing your personal information.

This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, "process") and how you may correct, update and access your personal information that you provide as a user of our website, operated at, the Tutela apps, and other locations from time to time (collectively the "Service").

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using our Services, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the collection, use and processing of your personal information in Canada in accordance with this Policy and as may be further identified when the personal information is collected.

If you do not want us to collect, use or process your personal information in accordance with this Policy, please do not access or use any of the Service or our services or otherwise provide any personal information to us.

Personal Information

For the purposes of this Policy, "personal information" means any identifiable information about an individual, including but not limited to an individual's name, home address, telephone number, social insurance number, gender, income, family status, and personal health information, except any other information otherwise exempted by the applicable laws of Canada. For example, in Canada (outside of Quebec), personal information does not include any business contact information that is processed solely to communicate with that person about his or her employment or profession. To the extent that this information is collected or provided through the Service and can be used to identify an individual, we will treat it as personal information in accordance with this Privacy Policy

While using the Service, you may be asked to provide certain personal information including medical history, description of health conditions and summary of wishes. We only collect personal information that we need to provide you with the Services and functionality for which your sign up. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Ensuring Accuracy of Personal Information

We rely on you to ensure that the personal information you provide while using the service is accurate, complete and up-to-date.

Cookies and Log-Files

Our Services may use "cookies" and similar technologies like single-pixel GIFs and web beacons. A "cookie" is a text file that is sent between a user's internet browser and the site being visited.

We use cookies to improve your experience while using our Service, for example, to keep you signed in. Your browser needs to allow this type of cookie to use our Service. A cookie does not damage your system and only identifies your browser, not you personally.

Another type of cookie that is used on websites is one which allows the website operator to see a user's browsing activity across different sites, for example, to personalize ads and see which site you visited immediately before you visited the current site. We do not use this type of cookie.

We may use cookies to collect information such as your browser type and version (for example, Safari or Google Chrome) and your IP address. We may also derive the general geographic area associated with an IP address.

We do not share any cookie information with third party marketing providers that will or can be used to deliver marketing about us to you while you visit other sites on the internet.

If you do not wish to receive cookies, you may be able to disable them. This may provide you with enhanced anonymity, but it will also affect the functioning of our Service.

To the extent that our Service contains links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party websites.

Information about Minors

This Service is intended solely for users who are not minors (19 years of age or older). We do not knowingly collect personal information about any minor. No such minor, nor any parent or guardian as it relates to such minor, should submit such minor's personal information to us through the Service or otherwise for any reason and under any circumstances.

Purpose for Which Personal Information is Processed

When using the Service, you will be asked to provide certain personal information including age, gender, medical history, and other health records. We will process this personal information to provide you with the services, products, and functionalities for which you sign up, to improve our products and services and to send you information on our products or services that may be of interest to you. We may also use your personal information to assist you with technical support in relation to the Service.

We may collect and use your personal information for other purposes, with your consent. We will communicate the purposes for which personal information is being collected before or at the time of collection. You may refuse to supply personal information but note this may prevent you from engaging in the full activities of the Service. We will only process your personal information for the Purposes we communicate and will not otherwise process your personal information.

We may remove the identifiers from your personal information process such information in a de-identified form that may be combined with other information to generate aggregated information. Other information includes but is not limited to technical information from use of our Service and its peripherals. We will ask for your consent before sharing this de-identified information with a third party, such as for research purposes. We may use this de-identified information for any purpose internally, especially to improve our products and services and perform statistical analyses and generate data related to how users use our Service.

Disclosure of Your Personal Information

Your personal information is only shared through the Service with medical and legal professionals or other viewers (the "Professionals") of your choice and only to the extent for which you grant permissions. Your personal information will only be shared with those Professionals you select from the Service and to the extent you allow through the Service. Your personal information will not be shared with any other Professional through the Service without your consent. We make every effort to ensure that you are aware of exactly what data is being shared with each authorized Professional and to ensure that the receiving Professional receives only the information they are given consent to. Once in receipt of your information, the receiving Professional is solely responsible for ensuring your personal information is available to only the appropriate people within their teams or organizations.

In addition to the above, ‪we may disclose your information to third parties in relation to a merger, acquisition, or any other form of sale of some or all of our assets or business. In relation to such a transaction, your information may be transferred to a the successor business and the successor business may use and disclose the your information for the proposes described in this Policy.

We will not use or disclose your personal information for any additional purpose unless we obtain your consent to do so. We do not sell your personal information.

Legal Basis for Processing Your Personal Information


We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express with clear options to say "yes" or "no", such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. By using our Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Service or otherwise provide any personal information to us.

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by deleting your account with the Service and stopping use of the Service.

Other Legal Bases

Aside from consent, we may also process your personal information under other legal bases, as permitted by the applicable laws.

Security of Personal Information

The security of your personal information is important to us. We protect personal information using physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee and do not provide any guarantees with respect to the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

Requests for Access to and Correction of Personal Information

Applicable privacy laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law.

We rely on you to ensure that your personal information that is provided while using the Service is accurate, complete and up to date. You may request that we change or delete your personal information in our possession.

Upon written request to the address indicated in Section 10 below, we will also provide you with a list of Professionals, individuals, or other entities to whom your personal information has been disclosed

CASL Policy

We are committed to compliance with Canada's Anti-Spam Legislation ("CASL"). Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a "CEM") that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity. We do not send CEMs without having obtained either your express consent (expressly acknowledged by you) or having your implied consent (sending CEMs specific to the Services and our relationship with you). We will not send you CEMs which are for any purpose other than those CEMs necessary and specific to the Services and our relationship with you.

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 10 below.

Retention of Your Personal Information

We generally keep personal information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes or as otherwise necessary to comply with applicable laws or protect our interests. As one purpose of the Service is to assist you with the management of your personal information, including the personal health information that you provide when using our Service, we will keep your personal information until you delete your Service account or let us know that you no longer require our assistance.

Updates or Changes to this Policy

This Policy was last updated in 29th June 2021. We will occasionally update this Policy and revise the "last updated" date appearing in this paragraph.

If we make any material changes we will either (a) notify you by email (sent to the email address listed in your account), or (b) provide a notice on the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that this Policy is posted or on the date as specified in the notification. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.

Contact Information for Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer by emailing

If you are not satisfied with our Privacy Officer's response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.