PLATEFORME WELLVERVE INC.
Privacy Policy
Canada & United States
Effective Date: April 23, 2026
Privacy Officer Contact:
privacy@wellverve.com | wellverve.com/privacy
1. Introduction
WellVerve Inc. ("WellVerve," "we," "us," or "our") operates a clinical-grade AI platform that supports licensed healthcare practitioners in delivering personalized, evidence-based supplement protocols.
We are committed to protecting the privacy and security of personal information entrusted to us by patients, practitioners, and platform users.
This Privacy Policy explains how we collect, use, disclose, store, and protect personal information — including sensitive health data — in connection with our platform, services, and website (collectively, the “Services”). It applies to users in Canada and the United States.
WellVerve operates across both jurisdictions and is designed to meet applicable Canadian and U.S. privacy requirements, including Quebec Law 25 and relevant U.S. healthcare and state privacy frameworks.
2. Scope & Definitions
Personal Information: Any information that identifies or can reasonably be linked to an individual.
Health Information: Sensitive personal information relating to physical or mental health.
De-identified Data: Data processed to remove direct identifiers and reduce re-identification risk using industry-standard methods.
Practitioner: A licensed healthcare professional using the platform.
Platform: WellVerve’s clinical AI system and associated services.
3. Information We Collect
3.1 Information You Provide
Identity & Contact: Name, email, phone number, address, date of birth
Practitioner Credentials: License details, professional registration, clinic affiliation
Account Information: Login credentials, preferences
Clinical Data: Health history, symptoms, lab results, medications, supplements, dietary data
Payment Information: Processed via compliant third-party providers (we do not store full card numbers)
Communications: Messages, inquiries, and feedback
3.2 Information Collected Automatically
Device & Technical Data: IP address, browser, device identifiers
Usage Data: Pages visited, session activity
Cookies & Tracking Technologies (see Section 9)
3.3 Information from Third Parties
With appropriate authorization:
EHR/PMS systems
Laboratories and diagnostic providers
Credential verification services
Referring practitioners or clinics
3.4 Sensitive Information
Due to the clinical nature of our Services, we process health information, which is subject to heightened protections.
4. Legal Basis for Processing
We process personal information only where permitted by law, including:
Consent (e.g., clinical data, marketing, RWE participation)
Performance of a contract (platform access and service delivery)
Legal and regulatory obligations
Legitimate interests, where applicable and balanced with user rights (e.g., platform improvement, security)
We do not use personal information for materially different purposes without appropriate consent or legal basis.
5. Use of Personal Information
5.1 Platform Operations
To operate and deliver Services, including:
Generating practitioner-reviewed supplement protocols
Supporting practitioner-patient workflows
Producing clinical outputs and reports
5.2 AI & Decision Support Transparency
WellVerve uses artificial intelligence to support clinical insights.
AI outputs are decision-support tools only
Final decisions remain with licensed practitioners
No fully automated medical decisions are made without human oversight
5.3 De-identified Data & Research
We may use de-identified, aggregated data for:
Platform improvement and model training
Research and publication
Licensing to life sciences and research organizations
De-identification is performed using industry-standard methods, including risk-based assessments to reduce the likelihood of re-identification.
5.4 Marketing & Communications
With consent where required, we may send:
Service updates
Clinical resources (for practitioners)
Product information
Users may opt out at any time.
6. Disclosure of Personal Information
6.1 Authorized Disclosures
We do not sell personal information. We disclose information only as necessary:
Practitioners and clinic administrators within care relationships
Service providers under contractual protections (e.g., cloud, payments)
Integrated systems authorized by users
Legal and regulatory authorities when required
Business transactions (e.g., mergers), with equivalent protections
With user consent
6.2 Data Licensing (De-identified Only)
WellVerve licenses de-identified, aggregated datasets for research and life sciences use.
No identifiable personal information is shared
Strict contractual prohibitions on re-identification
Use limited to research and pharmacovigilance
Separate, explicit patient consent is obtained
6.3 Cross-Border Transfers
Personal information may be processed in Canada or the United States. By using the Services, users acknowledge cross-border data handling.
7. Data Retention
We retain personal information only as long as necessary:
Clinical data: In accordance with applicable medical record retention laws
Account data: While accounts remain active and for a reasonable period thereafter
Legal obligations: As required by law or regulatory requirements
De-identified data: May be retained indefinitely for research and analytics purposes
8. Security Safeguards
We implement safeguards appropriate to the sensitivity of the data, including:
Encryption (AES-256 at rest; TLS 1.2+ in transit)
Role-based access controls and least-privilege access
Multi-factor authentication
Segregated system architecture
Regular security testing and audits
HIPAA-compliant vendor agreements where applicable
No system is completely secure. We notify affected individuals and authorities of breaches as required by law.
9. Cookies & Tracking Technologies
We use cookies to operate and improve Services:
Strictly Necessary: Authentication, security
Functional: Preferences and settings
Analytics: Platform performance (e.g., PostHog or similar tools)
Marketing: Only with consent
Users may manage preferences via browser settings or our cookie controls.
10. Your Rights
Depending on your jurisdiction, you may have the right to:
Access your personal information
Correct inaccurate data
Request deletion (subject to legal obligations)
Withdraw consent
Data portability (where applicable)
Opt out of secondary uses, including RWE datasets
File complaints with regulators
Requests may be submitted to: privacy@wellverve.com
Response timelines:
Canada (PIPEDA): ~30 days
Quebec (Law 25): ~15 business days
U.S. state laws: up to 45 days (extendable where permitted)
11. Consent
11.1 Practitioners
Practitioners agree to Terms of Service and Data Processing Agreements and are responsible for obtaining valid patient consent.
11.2 Patients
Patients are informed of:
Platform functionality and AI usage
Data collection and purposes
De-identified data use and opt-out rights
Cross-border processing
Separate, explicit consent is obtained for inclusion in de-identified datasets. Opt-out is available at any time.
12. Quebec Residents (Law 25)
Quebec residents have additional rights, including:
Data portability
Rights related to automated decision-making
Enhanced breach notification protections
WellVerve conducts Privacy Impact Assessments (PIAs) where required.
13. United States Residents
13.1 HIPAA
Where applicable, WellVerve acts as a Business Associate and complies with applicable agreements.
13.2 State Privacy Laws
Residents of California and other states have rights consistent with Section 10. We do not sell personal information.
14. Minors
Our Services are not directed to individuals under 18. We do not knowingly collect data from minors without appropriate consent.
15. Third-Party Services
We are not responsible for third-party privacy practices. Users should review their policies independently.
16. Changes to This Policy
We may update this Policy periodically. Material changes will be communicated via:
Website updates
Email notifications
In-platform notices
Continued use constitutes acceptance where permitted by law.
17. Contact — Privacy Officer
For any privacy-related inquiries:
Plateforme WellVerve Inc.
Approved by: Stephanie El-Chakieh
Title: Privacy Officer
Date: April 23, 2026