Privacy Policy

As a valued patient/customer we understand you rely on Reel Outline to safeguard and ensure responsible collection of information. To do so, we are committed to the following:

1. We will be transparent about how we handle your personal information and our privacy policy
2. We will protect your personal information in a secure and responsible manner.

Your privacy is important to us at REEL Outline (referred to herein as “REEL”, “we”, “our”, or “us”) and we are committed to protecting all personal information and data disclosed by our users in the course of their access to and use of our website https://reeloutline.com/ (the “Site”).

This Privacy Policy outlines how REEL collects, uses, retains and protects your personal information and data.

REEL reserves the right to revise this Privacy Policy at its sole discretion. Any such revisions will be posted to the Site. It is the responsibility of the User to ensure that they are aware of and understand the current Privacy Policy. Continued access or use of our Site and/or our Services constitutes acceptance by the User of the current Privacy Policy.

SCOPE OF THIS POLICY

This privacy policy applies to all Users of the Site.

As a convenience to our Users, REEL may include links to trusted third party websites for service providers or products including but not limited to medical clinics, pharmacies, and other healthcare service providers. Please be advised that these third-party sites have separate and independent privacy policies. REEL is not responsible or liable for the content and/or activities of these linked sites.

DEFINED TERMS

The following additional terms are used throughout this policy:

Health Service – any health care related service (as defined by relevant legislation) that is provided to a Patient by a Health Service Provider, irrespective of whether that service is delivered through the Reel Outline Platform and Services or by other means.

Health Service Provider – any qualified and authorized provider of Health Services including but not limited to pharmacies and clinics contracting to make use of the Platform to deliver Health Services to patients.

Materials – any content, materials, questions, options, results, reports, or information found on or provided by the Platform, as a result of any data, including but not limited to Patient Data provided by you.

Content – means any information, communication or expression created by REEL or made accessible via the Site and/or through our Services. Content includes, but is not limited to, comments, ideas, data, text, video, audio, images, graphics, designs, drawings, animations, logos, trademarks, copyrights, and intellectual property.

Patient – any individual who receives Health Services from a Health Service Provider.

Minor – any person under the age of majority in the jurisdiction.

Patient Representative – a person authorized to act on the patient’s behalf to manage the patient’s prescriptions and Health Services.

Patient Data – information about an identifiable Patient entered into the Platform by a Health Service Provider.

Personal Information (PI) – means information about an identifiable individual, including any “Personal Information” as such term is defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any substantially similar privacy legislation.

Personal Health Information (PHI) – means information about an identifiable individual that may be collected when you engage a Health Service Provider for a Health Service as such term is defined in applicable legislation such as the Personal Health Information Protection Act (Ontario) (“PHIPA”) and any substantially similar privacy legislation.

Health Insurance Portability and Accountability Act (HIPAA) – means the process of ensuring that all organizations and individuals that handle Protected Health Information (PHI) adheres to the standards set by the Health Insurance Portability and Accountability Act (HIPAA). This includes implementing and maintaining policies and procedures related to physical, network, and process security measures.

Non-Personal Information (NPI) – means information from which all personally identifiable information is removed, which as a consequence is neither Personal Information or Personal Health Information and does not identify you. In accordance with the Privacy Policy and applicable privacy legislation, information must be de-identified where necessary by REEL before it falls under the definition of NPI.

Services – means all services made available by or through REEL Outline, including but not limited to services accessed through the Content or the Site.

Site – means https://reeloutline.com/, its related webpages, Healthcompass Rx, its related webpages, and/or mobile applications.

User – means any individual or entity who accesses and/or utilizes the REEL Site and its Services.

Platform – the Reel Outline user platform for Health Service Providers also referred to as (REEL).

Privacy – an individual’s right to retain control over the collection, use and disclosure of their personal information.

User Generated Content (UGC) – any content whatsoever that you submit, create, upload, transfer, or otherwise make available by access to the Site or through the Services, including but not limited to messages, information, comments, feedback, images, data or in-media screenshots, videos, audio or other content posted in any public or private area within the Site or Platform.

OBTAINING CONSENT

REEL will obtain consent before or when we collect, use, or disclose Personal Information (PI) and Personal Health Information (PHI) about you, except where otherwise required or permitted by applicable privacy legislations.

You can provide consent to the collection, use, and disclosure of Personal Information and Personal Health Information about you expressly, implicitly, or through an authorized representative, as required by applicable law.

You can withdraw consent at any time, with certain exceptions, with your Health Service Provider or by contacting us at info@reeloutline.com.

You may also choose not to provide us with your Personal Information or Personal Health Information. However, if you make this choice, we may not be able to provide you with the Services you request.

By providing personal health information to your health service provider and consenting to the use of Reel Outline as part of receiving a health service from them, you authorize your health service provider to use the Reel Outline platform and site and upload patient data specific to you and you agree that the health service provider and their affiliate(s), including Reel Outline, may collect your personal information and personal health information and you consent to the use, disclosure, and transfer of your personal information and personal health information to facilitate receiving this service, in accordance with the health service provider’s privacy policies and as permitted or required by law.

WHAT INFORMATION DO WE COLLECT?

Through your access to and use of the Site, we may collect the following types of information:

Personal Information (PI)

Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) defines “Personal Information” as “information about an identifiable individual” which may include, but is not limited to:

• Your first name and last name
• Your email address
• Your residential address
• Your precise geolocation
• Your telephone number
• Your date of birth
• Your provincial health card information or personal health number
• Your medication and/or prescription information
• Your personal and family medical history including allergies, occupation, employment status, etc.
• Name and contact information of your primary care physician and/or current pharmacy
• Your medical insurance information
• Your payment and other related billing information
• Information pertaining to any private health benefits accounts/services.

Personal Health Information (PHI)

Ontario’s Personal Health Information Protection Act (“PHIPA”) defines “Personal Health Information” as identifying information about an individual’s substitute decision maker or any healthcare provider or that relates to an individual’s:

• physical/mental health
• provision of health care
• payments or eligibility for health care or health care coverage
• personal health history or family health history
• plan of service within the meaning of the Home Care and Community Services Act, 1994
• health number
• substitute decision maker
• donation of any body part or bodily substance or is derived from the testing or examination of any such body part or bodily substance

Non-Personal Information (NPI)

Non-personal information is information that cannot be used to identify or contact an identifiable individual which may include, but is not limited to:

• Your gender
• Your age
• Your postal code
• Your Non-precise geolocation information (i.e. your city)

Usage Data

Usage data refers to information that is not personally identifiable which is collected automatically from the device you use to access our Site. REEL only makes use of such information for internal resource management and planning purposes. Usage data may include but is not limited to:

• The IP address of your device
• Browser type, browser version and mobile operating system (if applicable) being used by your device
• The pages you visit on our Site
• How much time you spend on our Site
• Other diagnostic data

At all times, your decision to provide or withhold your personal and/or non-personal information remains voluntary. You may choose not to provide REEL with certain information through your use of our Content, Site and/or Services. Please note that your decision to withhold certain information may affect our ability to deliver Services as requested or to suggest appropriate alternatives. If we are unable to accommodate your request based on the information that you have provided, we may ask for additional information to better accommodate your needs, however your decision to provide or withhold such information remains entirely voluntary.

WHAT DO WE USE YOUR INFORMATION FOR?

We use information collected via our Site for a variety of business purposes including, without limitation, for the fulfillment of our contract with you, for compliance with our legal obligations, and with your consent for administrative, analytical, research, optimization, security and other purposes as more particularly described below:

(a) to develop, enhance, market, sell or otherwise provide information, products, services, new features and functionality that you have requested, including the Services;

(b) to send you administrative information related to our Site and/or Services, including any changes to our terms, conditions and policies, confirmations, technical notices, updates, security alerts, etc.;

(c) to identify usage trends so as to improve our Site and/or Services, and to inform the creation and implementation of future Services to be offered;

(d) to respond to your feedback and/or customer service inquiries about the Services;

(e) to process transactions for the Services;

(f) to facilitate account creation and manage your user account with REEL;

(g) to deliver personalized content and advertising, surveys, offers and other promotional materials tailored to your needs, preferences, interests or general location and to otherwise enhance your experience when viewing Content and using our Site and/or Services (note that you may opt out of promotional communications at any time);

(h) to troubleshoot problems with the Site and/or Services;

(i) to enforce our Terms of Use;

(j) to protect against unlawful activities such as fraud or other misuse of the Site, Content and/or Services or for other security reasons;

(k) for any other purpose to which you consent or that is otherwise permitted or required by law; and

(l) to compile statistics.

By providing your information through the access and use of our Site, Content and any of our Services, you acknowledge and agree that we may use your information for the purposes set out in this Privacy Policy.

DISCLOSURE OF INFORMATION

Your Personal Information will not be shared, transferred, sold or exchanged to third parties, except for our subsidiaries, affiliates and Health Service Providers that we engage to provide Services on our behalf, including but not limited to pharmacists, nurse practitioners/nurses, physicians, physician assistants, dieticians, certified respiratory educators, and certified diabetes educators and other healthcare clinicians provided that such third parties have agreed to comply with legally required privacy standards and they agree to use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose.

REEL will only provide those third parties with the Personal Information that they need to deliver the Services requested by you on behalf of REEL. We may also disclose your Personal Information to a third-party vendor whose products or services you have requested in order to deliver those products and services to you. Such third parties may keep and use your Personal Information whether or not you purchase their products or services. Your Personal Information will be subject to their privacy policies, so you should contact them directly for further information in respect of their policies.

Notwithstanding the foregoing, we reserve the right to disclose information, including Personal Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

In addition, we reserve the right to disclose Personal Information and Non-Personal Information in order to:

(a) enforce the Terms of Use;

(b) investigate and/or take action against unlawful activity, suspected abuse or unauthorized use of the Site and Services;

(c) protect and defend the rights or property of REEL; or

(d) act in urgent circumstances, including medical emergencies, to protect the safety or security of the public or users of the Site and/or Services.

HOW DO WE PROTECT YOUR INFORMATION?

As required by applicable privacy laws, REEL has implemented appropriate physical, technical and administrative safeguards to protect the information we obtain from being improperly accessed, collected, stolen, misused or modified by unauthorized third parties.

However, despite these safeguards and our efforts to secure your information, no electronic information storage or transmission via the Internet can be guaranteed to be completely secure. As such, REEL expressly disclaims, to the maximum extent permitted by law, any guarantee of security in connection with your Personal Information.

Users should always be aware that they access the Site at their own risk and should do so within a secure environment.

HOW WE DISCLOSE THE DATA WE COLLECT FROM YOU

We may disclose PI or PHI that we collect, or you provide as Patient Data, as described in this Privacy Policy, with our affiliates and subsidiaries who may be involved in delivering REEL Services, providing technical and administrative support, conducting internal research and analysis, and making improvements to the Platform, and our contractors, service providers, and other third parties affiliated with REEL.

These third parties are obligated to protect PI and PHI, and they are only given the information necessary to perform their designated functions. The collection and use of such information by third parties is subject to their own privacy policies.

These service providers include, without limitation:

• Stripe, a payment processing platform, owned by Stripe, Inc. whose privacy policy can be found here or at https://stripe.com/en-ca/privacy.

• REEL Outline’s back-end data infrastructure is built and stored using Amazon Web Services (AWS) cloud servers, ensuring PHIPA and PIPEDA compliance per specifications outlined in this white paper. This is the same infrastructure being used by the likes of world-renowned healthcare organizations such as the Canadian Pharmacist Association, 3M, and Thermofisher.

We may share aggregate or anonymized information, including NPI, with service providers, business partners, and other third parties, to the extent permitted by applicable law, including but not limited to for the purposes of evaluating the Services, research and analytical purposes, marketing, etc.

We take steps to keep NPI from being associated with you and we require our partners to do the same.

The choice to provide PI or PHI to your Health Service Provider is yours. If you do not wish for REEL to collect your PI or PHI through the use of the Platform or Site, you can choose not to provide it. However, your decision to limit or withhold certain details may limit the Services that REEL is able to provide the Health Service Provider. It is at all times your decision to provide, withhold, or withdraw your consent for the use of your PI or PHI.

HOW WE LIMIT COLLECTION, USE, DISCLOSURE, AND RETENTION

REEL collects PI and PHI only by fair and lawful means and only collects the necessary amount of information as required for the purposes of providing the Services and in accordance with this Privacy Policy.

REEL will use PI and PHI only for the reasons as set out in this Privacy Policy.

REEL will keep PI and PHI only as long as necessary for the identified purposes and as required by law.

REEL may share PI and PHI to affiliates, subsidiaries, and other third parties only for the purposes of providing Services as set out in this Privacy Policy.

We take steps to ensure security and limit access to PI and PHI, including contractual restrictions and training on confidentiality and privacy obligations.

Currently, REEL or our third-party service providers retain and store information collected by, or provided to us in the cloud and on secure servers in Canada.

Some of our third-party service providers may retain and store limited information outside of Canada in accordance with their respective privacy policies and as permitted by applicable data protection laws.

While we undertake measures to protect PI and PHI, when it is stored and/or processed in other jurisdictions, the laws of other countries may not provide the degree of protection for PI and PHI that is available in Canada.

You will be made aware of when and what information they are sharing outside of Canada and have the option not to share this information and engage these services.

INDIVIDUALS UNDER THE AGE OF 16

Generally, if you are under the age of 16, your parent, a children’s aid society, or another person who is legally entitled to give consent on your behalf, will act as your Patient Representative.

That person can consent to the collection, use or disclosure of your information, except in certain circumstances.

REEL does not knowingly collect or use any PI or PHI from individuals under the age of 16 unless provided by the Health Service Provider with the consent of the Patient Representative in accordance with the terms of this Agreement.

If you are 16 or older and capable of consenting, only you can consent to the collection, use or disclosure of your PHI unless you have designated a Patient Representative.

ACCESSING AND MAINTAINING ACCURACY OF YOUR PERSONAL AND PERSONAL HEALTH INFORMATION

Except as restricted by law, upon written request by you or an authorized representative, an individual will be informed of the existence, use, and disclosure of their PI and PHI and will be given access to that information.

An individual will be able to challenge the accuracy and completeness of the information and may request to have it amended.

REEL will keep PI and PHI in its possession or control accurate, complete, current and relevant, based on the most recent information available to REEL.

You are responsible for notifying REEL about the accuracy and completeness of your PI and PHI and may have it amended as appropriate.

SAFEGUARDS

The safety and privacy of PI and PHI is our top priority.

PI and PHI will be protected by security safeguards appropriate to the nature and format of the information being stored through physical, electronic, and administrative measures designed to secure PI and PHI.

We strive to protect PI and PHI from theft, loss, and unauthorized access, copying, modification, use, disclosure and disposal.

We conduct audits and complete investigations to monitor and manage our privacy compliance.

We ensure that all of our officers, directors, employees and agents protect your privacy and only use PI and PHI for the purposes to which you have consented.

We may transfer PI or PHI that we collect or that you provide as Patient Data as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business purposes and who are contractually obligated to keep Personal Information and Personal Health Information confidential, use it only for the purposes for which we disclose it to them, and to process the PI and PHI with the same standards set out in this policy.

There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, electronic, or administrative safeguards.

We follow all privacy and security requirements as outlined in legislation.

By sharing your PI and PHI with us, you acknowledge that your PI and PHI may be at risk should an external party breach our systems.

As required by law, we will inform you of any breaches which would create a reasonable risk of harm to you.

We will take reasonable steps to mitigate such risks and to prevent them from occurring again in the future.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE EXPRESSLY DISCLAIM ANY GUARANTEE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION AND PERSONAL HEALTH INFORMATION.

DATA INCIDENTS

A Data Incident involves an unauthorized access, use, or disclosure of PI or PHI, loss of PI or PHI, or other breach in the protection of your PI or PHI.

In the event of a Data Incident, we will investigate to assess whether the incident poses a risk of serious injury to you.

In these circumstances, you will be notified at the first reasonable opportunity.

QUESTIONS AND COMPLIANCE

We welcome your questions, comments, and requests regarding your Personal Information, Personal Health Information, this Privacy Policy and our privacy practices.

You may contact us as follows:

Email: info@reeloutline.com

If you feel we have not met our legal obligations under this policy or applicable privacy laws, the Commissioner can be reached as follows:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3 Canada

Website: http://www.priv.gc.ca

Toll-free: 1-800-282-1376
Phone: (819) 994-5444
Fax: (819) 994-5424
TTY: (819) 994-6591

CHANGES TO OUR PRIVACY POLICY

We reserve the right to revise this Privacy Policy at any time.

We will give you notice of such revisions by posting the revised Privacy Policy at www.reeloutline.com/privacy-policy and in REEL’s software solution, both the Administration and Clinical applications.

It is your responsibility to ensure that you are aware of the current Privacy Policy when you access or use the Site and/or Services.

If you continue to access or use any of the Site and/or Services after any revisions to this Privacy Policy are posted, you will be deemed to have accepted those revisions.

This policy was last modified on May 19, 2025.

HOW TO CONTACT US

Should you have any questions regarding this privacy policy, please contact us at:

Vesna Spadafora, Compliancy Officer

Phone: 519-965-5410
Email: info@reeloutline.com

You have the right to file a complaint with the Information and Privacy Commissioner.