Privacy Policy

Last Modified: August 6, 2025

We at Spurose Inc. (“us,” “we,” “our” or “Spurose”) respect your privacy, and we are committed to protecting it by complying with this policy (our “Privacy Policy”) and being transparent about our privacy practices.

In this policy, we explain how we collect, use, process, and share your personal information when you communicate directly with us or within our platform, as well as when you access and use the websites, applications, and other offerings provided we provide in connection with the platform offered through www.Spurose.ca (collectively, the "Services").

When we talk about your "information" in this Privacy Policy, we are referring to personal information about an identifiable individual (which includes personal information that can be used on its own or with other information to identify, contact, or locate you) and information about an identifiable individual's health or healthcare, as applicable.

As we explain in our Terms of Service, our Privacy Policy applies to anyone using our Services (whether paid or unpaid), but it does not apply to third parties' privacy practices and policies. These third parties (including Providers) should have their own privacy policies and practices, which are their responsibility.

To provide better detail about our privacy practices, we also make distinctions between "Providers" and "Customers" in this Privacy Policy, and you can find out what those terms mean in our Terms of Service.

If you have any questions, concerns or requests relating to this Privacy Policy, please contact us at privacy@Spurose.ca (our "Contact Information").

The Types of Information We Collect About You & How We Collect Them.

We collect different information about different users, depending on how you engage with our Services. For example, if you are a Customer, the information we collect and use will be different from what's collected from our Providers.

Below, we describe what information we collect, and - where appropriate - we offer examples about how those differ depending on what type of user you are.

1. Information About You (That You Provide Directly to Us).

When you engage with our Services or communicate with us directly, we collect the information you provide. From time to time, we may also ask you about your experience engaging with our Services or your interest in products and services relating to our Services, and we collect the information you provide in response.

a. If you are a Customer,

we typically collect (i) contact information, including your name, date of birth, email, phone number and address; (ii) Emergency Contact information, including the name and phone number of your Emergency Contact, as well as your relationship with that person; and (iii) information about your mental health history, current concerns and therapy goals. Please note that you are responsible for the Emergency Contact information you provide and obtaining the appropriate consent to provide it.

b. If you are a Provider,

we typically collect (i) contact information, including your name, date of birth, email, phone number and address; (ii) information about your qualifications and your practice, including your professional licenses, where your practice is located, and any images you choose to upload to the Services; and (iii) the Customer notes and reviews you upload or otherwise transmit through the Services.

2. Information About Your Access and Use of Our Services.

We may collect information about when you log in to our Services and how you interact with the Services, which can include information about the Services' features you use and how you interact with them. For example, this can occur when you report issues with our Services through troubleshooting channels or when you leave a review about us and our Services. We also automatically track certain information about your use of the Services, which you can read more about in the Cookies & Automated Technologies section below. This applies to Customers and Providers alike.

3. Information You Provide Through Interactive Features.

You may provide information to us through interactive features we make available to you. For instance, if we offer you the opportunity to engage with certain software (like Stripe, which facilitates payments between Customers and Providers) and you provide information about yourself while engaging with that software, your information may be shared with that third-party software and us. This applies to Customers and Providers alike.

4. Other Information from Third-Party Sources.

We may receive information about you from other sources, such as the software providers you use to access or engage with our Services or the third-party sources you instruct us to collect information from. This information can include information that identifies your connection type, settings, operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. Additionally:

For Customers, this information can also include marketing, demographic information and contact information (like your name and email address). Additionally, if you connect your virtual calendar to our Services (e.g. to create reminders for your meetings with Providers), we will collect the information you provide.

For Providers, this information can also include information about your professional licenses, in addition to the information types collected from Customers (noted immediately above).

5. Non-Personal Information.

We may also collect non-personal information when we receive information directly from you or from third-party sources. Non-personal information is information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual (such as 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 personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific feature of our Services. This applies to Customers and Providers alike.

We do not intend for children under the age of 18 to use our Services, and we do not knowingly collect information about individuals under the age of 18. If you are under the age of 18, please do not use or provide any information to us. If you believe we might have any information from or about a child under 18, please contact us using the Contact Information above.

How We Use Your Information

We collect and use your information for the following purposes:

• To provide the Services to you, which includes sharing your information with Providers.
• To provide customer support and improve the Services.
• To provide you with the information, products or services that you request from us or our service providers.
• To provide you with notices and information relevant to your use of our Services.
• To improve our offerings and customer experience.
• To comply with applicable laws and obligations or to enforce our legal rights.
• For any other purpose with your consent.

Where you have provided your consent to the collection, use, and transfer of your information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact us using the Contact Information (detailed above). Please note that if you withdraw your consent, we may not be able to provide you with access to and/or use of our Services and other offerings.

In any case, we will not sell your information.

Emergency Contact Information

Customers can add Emergency Contact information to their accounts. An "Emergency Contact" is someone that a Customer designates, who can assist Providers and Customers when a Customer has an emergency. Emergency Contacts are often family members or close friends, and Customers have the opportunity to provide contact information, as well as relationship information, relating to their Emergency Contacts.

When a Customer provides an Emergency Contact, they agree that a Provider may contact that person in the event of an emergency. Customers are responsible for obtaining consent to share their Emergency Contact's information with us and with Providers, and that an Emergency Contact's information may be used in the event of an emergency.

Data Security & Retention

Protecting your information is important to us. That is why we take steps to protect your information from unauthorized access, destruction and misuse. For example, all the information we collect is encrypted and stored on secure servers, and all the steps we take to protect your information will be commensurate with the sensitivity of the information we collect and reasonable in the circumstances.

To further protect your data, we will not store your data for longer than we need it unless you agree otherwise or the law permits us to keep the information for a longer period of time. Please note that if you delete your account or you ask us to delete your information, we will delete your information or account (as applicable) within 30 days, subject to any legal requirements requiring or permitting us to continue storing this information. If we anonymize your data, however, you agree we may use that anonymized information as we choose and keep the data for longer periods of time. Any requests regarding information held by Providers should be communicated to Providers directly (since their privacy practices and obligations are their own).

Nevertheless, despite our efforts, using the internet is never risk-free. As a result, we cannot guarantee the security of your data, and – ultimately – you use the internet at your own risk.

Cookies & Automated Technologies

We use automated technologies to help us improve your user experience. To do that, we may store your preferences, remember you for future visits to our Services, or otherwise gather information about how our Services are used.

Our automated technologies may include browser cookies, flash cookies, or web beacons, and we may use them to collect information about your devices and internet use.

A cookie is a small piece of data – a text file – that a website asks your browser to store on your device to remember information about you, such as your language preference or login information, that can later be retrieved to identify you when you return to our Services.

For example, we may collect data about the tools and mechanisms you use to access our Services (including your IP address, browser, or operating systems), and we may collect information about your visits to our Services (such as location data, web traffic data and what you do with our Services).

Our automated technologies may also collect information about your online activities over time or on others' websites, using methods like behavioral tracking. If you wish to opt out of behavioural tracking, please contact us using the Contact Information outlined above.

When we use automated technologies (like cookies), the information we collect is generally statistical in nature. Nevertheless, it may include personal information or otherwise be associated with the information we collect, as described in this Privacy Policy.

If you wish to disable our cookies, you can typically disable them by changing your browser settings. In most modern browsers, you can block or delete cookies by clicking Settings > Privacy > Cookies.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.youradchoices.ca.

Before deciding to delete our cookies, please note that some of our cookies are necessary to access the essential features of the Services, and we recommend that you leave cookies enabled. If you choose to disable our cookies, some of our Services' functionality may no longer be available to you.

When We Share Your Information with Others

We may share your information when one of the following circumstances applies:

With Your Consent.

We may share your information with others with your consent or to fulfill the purpose for which you provided the information.

If you are a Customer, for example, you consent to us sharing your information with the Providers that use our Services. Likewise, if you provide Emergency Contact information, you agree that we may share information with your Emergency Contact.

If you are a Provider, for instance, you consent to us sharing your information with the Customers that use our Services, which is a core feature of our Services.

For Business Purposes.

We provide information to vendors and service providers to help us provide the Services to you. Examples of our service providers include hosting or infrastructure providers, our customer relationship management providers, email providers, collaboration tools, Stripe (for payment processing) and other service providers we use to provide our Services.

For Corporate Transactions.

We may share information with actual or prospective acquirers, their representatives, and other relevant participants in the event of a merger, a reorganization of our business, or another similar transaction.

For Legal Reasons.

We may share your information if we believe that it is necessary to comply with any legal obligation or process, such as responding to a government or regulatory request. Likewise, we may share your information if we believe that it is necessary to enforce our rights or the rights of our customers or users.

Who We Share Your Information With

We may disclose statistical and anonymized data collected from Services users as we choose, but we limit how your information is disclosed. We limit how we share your information, only providing it to the following:

• With Providers, if you engage with the Services as a Customer.
• With Customers, if you engage with the Services as a Provider.
• With your Emergency Contact, if you engage with the Services as a Customer.
• Our affiliates, successors or, if we change our business or corporate structure, the ultimate operator of our Services.
• Contractors, service providers, and others that support our business by providing the software we need to deliver our Services to you.
• Others with whom you consent or otherwise direct us to share your information with.
• Governmental authorities or courts, as required by law, or as is necessary to protect your rights, our rights, or the rights of others.

International Processing, Transferring and Storing Your Information

We may choose to process, transfer or store your information in countries different from where you live. These countries may have different privacy laws, and their laws may be less comprehensive than the privacy legislation applicable to our relationship with you. Nevertheless, we will implement appropriate technical and organizational measures to ensure our contractors and service providers protect your data.

By using our Services or providing your information to us, you agree to us processing, transferring, or storing your information in other countries. You may obtain more information about our international processing, transfer and storage practices using the Contact Information noted above to contact our designated Privacy Officer.

Accessing and Updating Your Information

We strive to keep the information we collect accurate and current, and we invite you to contact us when your information has changed. Privacy laws applicable to our relationship with you may give you the right to request access to the information we collect about you and often allow you to correct outdated information.

While you usually have the ability to update and correct much of the important information associated with your account, if you require further access or assistance with correcting your information, please contact us using the Contact Information above. Likewise, please contact us if you have any concerns or complaints about how we use or collect your information.

Please note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Additionally, in accordance with our data retention practices and applicable law, we may destroy or limit access to certain information we collect about you. Nevertheless, we will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information that is part of a formal dispute resolution process.
• Information that is subject to a legal privilege or cannot be released because of a court order
• Information that could reasonably be expected to result in a risk of serious bodily harm

If we are unable to provide you with access to your information, we will explain why (subject to applicable law about these sorts of disclosures).

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. Should we make any significant changes to our Privacy Policy and how we engage with your information, we will notify you. We also encourage you to periodically review our Privacy Policy to check for updates. The date the Privacy Policy was last revised is identified at the top of the page. Your continued access and use of the Services will be deemed to be your acceptance of Privacy Policy.