HEALTHX CANADA INC.
PRIVACY POLICY
Last Updated: June 17, 2026
HealthX Canada Inc. (“HealthX”, “we”, “us”, or “our”) is committed to protecting personal information and maintaining strong privacy, security, and data governance standards.
This Privacy Policy explains how HealthX collects, uses, discloses, stores, safeguards, retains, and processes personal information when you access or use our website(s), online forms, booking-request pages, referral pages, promotional pages, verification forms, communications, services, and platform, including any HealthX-operated or HealthX-authorized patient engagement, marketing, referral, verification, or reward process (collectively, the “Platform”).
By using the Platform, submitting information to HealthX, booking through HealthX, communicating with HealthX, participating in a HealthX promotion, or submitting reward verification information, you agree to the practices described in this Privacy Policy.
This Privacy Policy should be read together with HealthX’s Terms of Use and any applicable promotion-specific terms.
- Applicable Privacy and Related Laws
HealthX is committed to complying with applicable privacy, consumer, anti-spam, advertising, and data-protection obligations, including, where applicable:
the Personal Information Protection and Electronic Documents Act (“PIPEDA”);
applicable provincial privacy laws;
Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”), where applicable;
Canada’s Anti-Spam Legislation (“CASL”), where applicable;
applicable consumer protection laws;
applicable gift-card, advertising, and deceptive-marketing rules; and
other applicable Canadian laws and regulations.
Nothing in this Privacy Policy limits any rights or protections that cannot legally be waived under applicable law.
- HealthX’s Role
HealthX is a marketing, referral, promotional, and patient engagement platform that helps connect individuals with independent dental clinics, dental professionals, healthcare clinics, and other participating service providers (“Providers”).
HealthX is not a healthcare provider, dental provider, medical provider, dental office, insurer, dental benefit plan, treatment coordinator, or clinical advisor.
HealthX does not provide dental services, medical services, clinical advice, diagnoses, prescriptions, treatment planning, second opinions, dental benefit determinations, insurance advice, or treatment recommendations.
Any dental, healthcare, or professional services you receive are provided solely by the Provider you choose or attend.
Providers are independent businesses and/or independent regulated professionals. Providers are responsible for maintaining clinical records and complying with their own professional, privacy, health privacy, billing, insurance, and regulatory obligations.
HealthX generally operates as a marketing and technology platform and not as a health information custodian. However, where HealthX processes personal health information on behalf of a Provider, or in circumstances where health privacy laws apply, HealthX will use reasonable safeguards and process such information only as permitted by law and applicable agreements.
- Privacy Governance and Accountability
HealthX maintains privacy governance practices designed to protect personal information and support responsible data handling.
HealthX’s privacy governance practices may include:
internal privacy policies and procedures;
staff privacy and confidentiality training;
role-based access controls;
vendor and service-provider review;
contractual privacy and confidentiality obligations for service providers;
data minimization practices;
security safeguards;
incident response procedures;
privacy complaint handling; and
periodic privacy and security reviews.
HealthX has designated a Privacy Officer responsible for overseeing privacy compliance, privacy complaints, access or correction requests, breach response, vendor privacy safeguards, and personal information handling practices.
- Categories of Personal Information We May Collect
HealthX may collect the following categories of personal information, depending on how you use the Platform:
Identity Information
Examples include your name, email address, phone number, and other contact details.
Booking and Referral Information
Examples include clinic selected, Provider selected, preferred appointment time, requested service category, booking request details, referral status, appointment coordination information, and communication history.
Promotion and Reward Information
Examples include promotion selected, reward eligibility information, reward status, submission date, verification status, gift-card delivery information, and information needed to administer promotional incentives.
Verification Information
Examples include non-clinical proof of visit documentation, clinic name, visit date, patient name, attendance confirmation, new-patient status, and whether the applicable promotion criteria were met.
No-Combination and Eligibility Information
Examples include information needed to determine whether a HealthX promotional incentive was combined with another discount, promotion, coupon, rebate, gift card, clinic credit, reduced-fee offer, new-patient special, student discount, senior discount, uninsured-patient discount, Provider-issued promotion, or other incentive.
Communication Information
Examples include emails, text messages, form submissions, support inquiries, complaint records, dispute communications, and consent or unsubscribe records.
Technical and Device Information
Examples include IP address, browser type, device information, operating system, pages visited, referral source, website interaction data, timestamps, cookie identifiers, and general analytics information.
Fraud Prevention and Security Information
Examples include duplicate submission indicators, suspicious activity signals, inconsistent documentation, abuse-prevention records, system logs, and information required to investigate suspected misuse of the Platform or promotions.
Legal and Compliance Information
Examples include records needed for legal compliance, dispute handling, tax/accounting purposes, audit logs, regulatory responses, and enforcement of HealthX’s Terms of Use or Promotion Terms.
- Information HealthX Does Not Intentionally Collect
HealthX does not request or require users to upload clinical or diagnostic documentation for reward verification.
Users should not upload:
dental X-rays or radiographic images;
clinical treatment notes;
dental charts;
diagnostic findings;
treatment plans;
medical histories;
prescription information;
health card information;
insurance documents showing detailed procedure-level clinical information;
laboratory reports;
specialist reports;
medical imaging;
photographs of clinical conditions unless specifically requested for a lawful and necessary purpose; or
any other sensitive health information not specifically requested by HealthX.
If HealthX identifies that unnecessary, excessive, clinical, diagnostic, or sensitive health information has been submitted, HealthX may delete, redact, restrict access to, or decline to review that information.
HealthX may retain a limited record that prohibited or unnecessary information was submitted and removed, where reasonably necessary for fraud prevention, legal compliance, audit purposes, or dispute handling.
- Purposes for Collection, Use, and Processing
HealthX may collect, use, and process personal information for the following purposes:
to operate and improve the Platform;
to receive and process booking requests;
to coordinate referrals or appointment requests with Providers;
to communicate with users;
to provide customer support;
to administer HealthX promotions;
to verify reward eligibility;
to confirm attendance and eligibility with Providers;
to determine whether a HealthX incentive was combined with another discount, promotion, coupon, rebate, clinic credit, reduced-fee offer, new-patient special, or other incentive;
to prevent fraud, abuse, duplicate submissions, and misuse of promotions;
to process, issue, or coordinate rewards through third-party reward vendors;
to investigate complaints, disputes, chargebacks, reversals, verification issues, and suspected abuse;
to maintain records required for business, accounting, tax, legal, and compliance purposes;
to send service-related, transactional, administrative, and reward-related communications;
to send commercial electronic messages where permitted by law;
to measure advertising and marketing performance;
to analyze website usage and improve user experience;
to protect Platform security;
to enforce HealthX’s Terms of Use and Promotion Terms;
to comply with applicable laws, court orders, regulator requests, or legal processes; and
for other purposes disclosed at the time of collection or permitted by law.
HealthX does not use personal information to make clinical decisions or treatment recommendations.
- Consent
HealthX collects, uses, and discloses personal information with your consent, where required by law.
Consent may be express, implied, or otherwise permitted by law, depending on the circumstances and sensitivity of the information.
By submitting information to HealthX, using the Platform, booking through HealthX, participating in a promotion, submitting verification documentation, or communicating with HealthX, you consent to HealthX collecting, using, disclosing, and processing your personal information for the purposes described in this Privacy Policy, the Terms of Use, and any applicable Promotion Terms.
You may withdraw consent where permitted by law, subject to legal, contractual, fraud-prevention, dispute-resolution, accounting, and recordkeeping requirements. Withdrawing consent may limit HealthX’s ability to provide services, process booking requests, verify rewards, issue rewards, resolve disputes, or communicate with you.
- Provider Verification
For reward verification, HealthX may contact the applicable Provider to confirm limited administrative information.
Provider verification may include:
patient name;
clinic name;
visit date;
attendance status;
new-patient status;
whether the applicable promotion criteria were met;
whether the Provider confirms eligibility;
whether another discount, promotion, coupon, reduced-fee offer, special offer, or other incentive was applied; and
other non-clinical information reasonably necessary to verify reward eligibility.
User-submitted proof, including invoices, receipts, walkout statements, screenshots, booking confirmations, or statements of account, does not automatically establish eligibility.
HealthX does not request clinical treatment notes, diagnostic findings, X-rays, treatment plans, medical histories, prescriptions, or detailed clinical records from Providers for reward verification.
Providers remain responsible for their own privacy, health privacy, professional, billing, insurance, and regulatory obligations.
- No-Combination and Promotion Eligibility Verification
HealthX promotional incentives cannot be combined with any other discount, promotion, coupon, rebate, gift card, clinic credit, referral reward, loyalty reward, reduced-fee offer, new-patient special, student discount, senior discount, uninsured-patient discount, family or friends discount, employer discount, third-party offer, Provider-issued promotion, marketing offer, or any other incentive or benefit unless HealthX expressly confirms otherwise in writing.
HealthX may collect, use, or verify information reasonably necessary to determine whether this no-combination rule has been satisfied.
If HealthX determines that a HealthX promotional incentive was combined with another discount, promotion, incentive, or benefit, HealthX may deny, cancel, reverse, or recover the reward in accordance with the Terms of Use and applicable Promotion Terms.
- Communications, Email, SMS, and CASL
HealthX may communicate with you by email, SMS/text message, phone, online form, or other electronic methods for purposes such as:
booking requests;
referral coordination;
appointment-related communication;
support inquiries;
verification requests;
reward status updates;
promotion administration;
fraud prevention;
policy updates;
legal or compliance notices; and
customer service.
Where HealthX sends commercial electronic messages, HealthX will comply with Canada’s Anti-Spam Legislation, including applicable consent, sender identification, and unsubscribe requirements.
You may unsubscribe from commercial electronic messages where required by law. However, HealthX may still send non-commercial, transactional, legal, service-related, reward-related, verification-related, or account-related messages where permitted by law.
HealthX may retain consent and unsubscribe records to demonstrate compliance with applicable laws.
- Third-Party Service Providers and Subprocessors
HealthX may use third-party service providers and subprocessors to support Platform functionality and business operations.
These service providers may include:
form processing providers, such as Jotform or similar vendors;
cloud hosting and storage providers;
email and SMS communication providers;
website analytics providers;
advertising and marketing measurement platforms;
fraud-prevention and security tools;
customer support tools;
reward and gift-card fulfillment vendors;
professional advisors;
accounting, tax, and legal service providers; and
other operational vendors.
HealthX requires service providers to maintain reasonable privacy and security safeguards and contractual confidentiality obligations appropriate to the nature of the information they process.
HealthX does not authorize service providers to use verification information or personal information for unrelated purposes.
- Reward Vendors and Gift-Card Providers
HealthX may use independent third-party reward providers, merchants, gift-card vendors, or fulfillment platforms to issue promotional rewards.
To fulfill rewards, HealthX may share limited information reasonably necessary for delivery, such as your name, email address, reward type, reward amount, and fulfillment status.
Gift cards and other rewards may be subject to the issuing vendor’s own terms, privacy policy, and conditions.
HealthX is not responsible for a reward vendor’s independent privacy practices, systems, outages, delivery failures, merchant acceptance, balance issues, replacement policies, or unauthorized use after delivery, except where required by law.
- Disclosure of Personal Information
HealthX may disclose personal information to:
Providers, for booking coordination, referral coordination, attendance confirmation, promotion verification, and eligibility confirmation;
third-party service providers and subprocessors;
reward vendors and gift-card fulfillment providers;
analytics, advertising, and measurement providers, subject to HealthX’s safeguards and this Privacy Policy;
professional advisors, including legal, accounting, tax, compliance, and insurance advisors;
regulatory authorities, law enforcement, courts, tribunals, or government agencies where required or permitted by law;
successors or potential successors in connection with a business transaction, merger, acquisition, financing, restructuring, or sale of assets, subject to appropriate confidentiality protections; and
other parties with your consent or where permitted by law.
HealthX does not sell personal information.
HealthX does not knowingly sell, disclose, or share clinical treatment records, diagnostic findings, treatment plans, radiographic images, or detailed health information with advertising platforms for targeted advertising.
- Advertising, Analytics, Cookies, and Tracking Technologies
HealthX may use cookies, pixels, tags, analytics tools, advertising tools, and similar technologies to operate the Platform, measure website usage, understand campaign performance, improve user experience, prevent fraud, and support marketing.
These tools may collect general website and device information such as:
IP address;
browser type;
device type;
operating system;
pages viewed;
links clicked;
referral source;
session duration;
approximate location derived from IP address;
cookie identifiers; and
general interaction data.
HealthX configures advertising and analytics tools to avoid collecting clinical or treatment-specific information.
HealthX does not intentionally share the following with advertising or analytics providers:
clinical treatment information;
diagnostic findings;
treatment plans;
dental charts;
radiographic images;
appointment reasons;
medical histories;
prescription information; or
detailed health record data.
Users can control cookies through browser settings. Blocking cookies may affect Platform functionality or user experience.
- Cookie Categories
HealthX may use the following categories of cookies and similar technologies:
Essential Cookies
Used for basic Platform functionality, security, form operation, session management, and fraud prevention.
Performance and Analytics Cookies
Used to understand how users interact with the Platform, measure site performance, and improve functionality.
Advertising and Measurement Cookies
Used to measure advertising performance, understand campaign effectiveness, and improve marketing.
Preference Cookies
Used to remember certain user preferences where applicable.
HealthX may update its cookie and tracking practices from time to time.
- Cross-Border Processing and Storage
Some HealthX service providers may process or store personal information outside Canada, including in the United States or other jurisdictions.
Where personal information is processed or stored outside Canada, it may be subject to the laws of those jurisdictions, including lawful access by courts, law enforcement, national security authorities, or regulators.
HealthX requires vendors to maintain appropriate contractual, privacy, confidentiality, and security safeguards consistent with applicable privacy laws.
- Data Minimization
HealthX limits collection, use, and disclosure of personal information to what is reasonably necessary for the purposes identified in this Privacy Policy, the Terms of Use, applicable Promotion Terms, or as otherwise permitted by law.
HealthX does not operate as a clinical record repository.
HealthX does not request clinical documentation for reward verification.
Users should avoid submitting unnecessary, excessive, or sensitive information.
- Data Retention
HealthX retains personal information only as long as reasonably necessary for the purposes described in this Privacy Policy or as required or permitted by law.
Retention periods may vary depending on the nature of the information, legal requirements, fraud-prevention needs, dispute risk, accounting obligations, and operational requirements.
Typical retention practices may include:
Account and Contact Information
Retained while required for service delivery, support, legal compliance, or business recordkeeping.
Booking and Referral Information
Retained as reasonably necessary for referral coordination, support, dispute handling, compliance, and business records.
Verification Uploads
Retained until verification is complete plus a reasonable fraud-prevention, dispute-resolution, legal, and accounting period.
Reward Fulfillment Records
Retained as reasonably necessary for reward administration, fraud prevention, accounting, tax, legal, and compliance purposes.
Technical Logs
Retained for a limited period for security, debugging, analytics, and performance monitoring.
Consent and Unsubscribe Records
Retained as reasonably necessary to demonstrate compliance with CASL and other applicable laws.
Complaint and Dispute Records
Retained as reasonably necessary to investigate, respond to, resolve, defend, or document the issue.
HealthX may retain de-identified, aggregated, or anonymized information for analytics, business intelligence, fraud prevention, and service improvement, provided it no longer identifies an individual.
- Deletion, Redaction, and Correction
You may request access to, correction of, or deletion of your personal information by contacting HealthX.
HealthX may require identity verification before fulfilling a request.
HealthX will respond within legally required timeframes.
HealthX may refuse, limit, or delay a request where permitted or required by law, including where information must be retained for legal compliance, fraud prevention, dispute handling, accounting, tax, security, business recordkeeping, or enforcement of the Terms of Use or Promotion Terms.
If HealthX identifies unnecessary clinical, diagnostic, or sensitive health information, HealthX may delete, redact, restrict access to, or decline to process that information.
- Security Safeguards
HealthX uses administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, disclosure, alteration, or destruction.
Safeguards may include:
access controls;
role-based permissions;
secure storage;
staff privacy and security training;
vendor security review;
contractual confidentiality obligations;
logging and monitoring;
incident response procedures;
data minimization practices; and
internal privacy policies.
No system, transmission method, or storage method is completely secure. HealthX cannot guarantee absolute security.
- Breach Response
If HealthX becomes aware of a privacy or security incident involving personal information, HealthX will take steps appropriate to the circumstances, which may include:
investigating the incident;
containing or mitigating risk;
assessing whether personal information was affected;
notifying affected individuals where required by law;
notifying regulators where required by law;
notifying other organizations or government institutions where required or permitted by law;
documenting the incident; and
taking corrective measures where appropriate.
- User Responsibilities
You are responsible for:
providing accurate and current information;
ensuring you have authority to submit any information you provide;
not uploading unnecessary clinical or sensitive information;
not submitting another person’s information without proper authority or consent;
keeping your email and contact information current;
monitoring your email, spam, and junk folders for HealthX communications;
not submitting false, altered, misleading, or fraudulent documentation;
not attempting to claim a reward while receiving another discount or promotion contrary to HealthX’s Terms of Use or Promotion Terms; and
not using the Platform in a way that violates applicable laws or another person’s rights.
- Children and Minors
The Platform is not intended for use by children without parental or guardian consent.
If a minor uses the Platform, a parent or legal guardian may be required to provide consent, submit information, communicate with HealthX, or participate in verification.
HealthX may refuse to process information or reward submissions involving a minor if appropriate consent or authority cannot be confirmed.
- Third-Party Links and External Sites
The Platform may link to third-party websites, Provider websites, scheduling systems, forms, payment systems, reward vendors, or other external services.
HealthX is not responsible for the privacy practices, security practices, content, policies, or terms of third-party websites or services.
Users should review the privacy policies and terms of any third-party services they use.
- Business Transactions
HealthX may disclose or transfer personal information in connection with a proposed or completed business transaction, including a merger, acquisition, financing, restructuring, sale of assets, corporate reorganization, insolvency, or similar transaction.
Where required by law, HealthX will use reasonable efforts to ensure that the recipient handles personal information consistently with this Privacy Policy or provides notice of any material changes.
- Privacy Impact and Risk Assessment Practices
HealthX maintains privacy risk management practices and may periodically review:
data collection practices;
vendor data processing risks;
new technology deployments;
advertising and analytics configurations;
security safeguards;
promotion workflows;
reward verification workflows; and
retention practices.
HealthX may conduct internal or external privacy and security assessments when introducing new services, technologies, vendors, or workflows that may affect personal information.
- Privacy Complaints
If you have concerns about HealthX’s privacy practices, you may contact HealthX’s Privacy Officer.
HealthX will:
review the complaint;
investigate where appropriate;
respond within a reasonable timeframe;
take corrective action where required; and
document the matter where appropriate.
If your concern remains unresolved, you may contact the applicable privacy regulator.
- Access, Correction, and Data Subject Requests
You may request access to personal information HealthX holds about you.
You may request correction of inaccurate or incomplete information.
You may request deletion of personal information where permitted by law.
To protect privacy and security, HealthX may require identity verification before fulfilling a request.
Requests may be refused, limited, or delayed where permitted or required by law, including where fulfilling the request would reveal another person’s information, compromise security, interfere with fraud prevention, affect legal privilege, interfere with an investigation, or conflict with legal, accounting, regulatory, or dispute-resolution obligations.
- Updates to This Privacy Policy
HealthX may update this Privacy Policy from time to time to reflect:
regulatory changes;
legal changes;
technology changes;
service changes;
vendor changes;
promotion changes;
security updates;
business changes; or
changes to HealthX’s data handling practices.
Changes take effect when posted on the Platform with an updated Effective Date or Last Updated date, unless otherwise stated or required by law.
Your continued use of the Platform after changes are posted means you accept the updated Privacy Policy.
- Contact Information and Privacy Officer
HEALTHX CANADA INC.
Email: INFO@HEALTHXCANADA.COM
Address: Toronto, Ontario, Canada
Privacy Officer Contact:
Email: INFO@HEALTHXCANADA.COM
Mailing Address: Toronto, Ontario, Canada
For privacy-related requests, access requests, correction requests, deletion requests, complaints, consent questions, reward verification privacy questions, or security concerns, contact: INFO@HEALTHXCANADA.COM