Sensifai Health Inc. Privacy Policy and HIPAA Notice

Privacy Policy

Scope of this Privacy Policy

This Privacy Policy is designed to inform users of Sensifai Health Inc. (“Sensifai“) websites, mobile applications, and services, including but not limited to the EarlyCue mobile application (collectively referred to as the “Services“), about how we gather and use Personal Data in connection with your use of the Service.

This Privacy Policy applies only to individual end users of the Services, including, without limitation, patients, research subjects and participants, and similarly situated persons. Healthcare providers, researchers, institutions, and any other organizational or professional users should refer to their separate written agreements with Sensifai regarding their access to and use of the Services, including but not limited to the EarlyCue mobile application and platform.

“Sensifai,” “we,” “us,” and similar terms refer to Sensifai Health Inc. “You,” “your,” and similar terms denote you as a user of our Services. Sensifai is the controller of your personal data, and is responsible for the collection, processing and disclosure of your personal data as described in this Privacy Policy, unless expressly specified otherwise. This Privacy Policy details how Sensifai handles your Personally Identifiable Information (“PII“) and protected health information (“PHI“) (PII and PHI, collectively referred to as “Personal Data“) that Sensifai collects, receives, maintains, stores, or transmits, including information you provide or submit to our Service. Your Personal Data includes details that either individually identify you or are information linked to you or a device you use to access or use the Services.

Our Services are intended for users located in the United States of America, Canada, England and Israel only. Any information you provide, including any Personal Data, may be transferred to and processed by a computer server located within the United States.

Agreement to Terms

By accessing our Services, you agree to this Privacy Policy, our Terms of Service (available here), and our practices of gathering, using, and sharing your Personal Data as outlined herein. If you disagree with any part of this Privacy Policy or our Terms of Service, please refrain from using the Services and avoid providing us with any Personal Data.

By registering for or by visiting and/or using our Services, you:

  1. Explicitly consent to our collection, use, disclosure, and processing of your Personal Data in line with this Privacy Policy.
  2. Confirm that you’ve read and understood our HIPAA Notice, accessible below detailing how we might use and disclose PHI about you for reasons related to your health, payments, or healthcare operations and other legal purposes, in alignment with the Health Insurance Portability and Accountability Act of 1996, updated as required (“HIPAA“).

If there is any discrepancy between this Privacy Policy and the HIPAA Notice regarding PHI, the latter will prevail, to the extent HIPAA applies to you.

Protected Health Information (PHI)

Sensifai is committed to upholding the privacy and sanctity of PHI received from you during your use of or participation in the Services. PHI pertains to data about you that we obtain during your use of our Services, which could identify you (like your name, email, date of birth, or zip code) and relates to:

  1. Your past, current, or potential health status.
  2. Past, present or potential healthcare services provided to you.
  3. Past, present, or potential payments for your healthcare services.

This Privacy Policy elucidates how we safeguard your privacy when you interact with or use our Services. Federal and state laws may offer you additional rights concerning the access, usage, and disclosure of PHI. For a thorough understanding of your rights regarding PHI, kindly refer to our HIPAA Notice, which offers essential information about the usage and disclosure of your PHI.

The Personal Data We Collect

  • Name, sex, gender, age, contact details (including but not limited to email and phone number), social security number
  • Any other identifiers you provide
  • Physiological signals collected by and transmitted via third-party wearable devices

You are not required to provide all of the Personal Data mentioned above to interact with us. However, if you choose not to provide certain information to the extent it is necessary for us to provide the Services and fulfill our legal obligations, you may be limited in the use of features or functions of the Services.

We do NOT collect, process, or retain any form of geolocation or other location-based information. However, such data may be collected through third-party wearable devices used in connection with our Services. Sensifai does not own, operate, or control such devices, and does not endorse or make any representations regarding their functionality. Users are strongly encouraged to review the applicable privacy policies and terms of use governing those third-party wearable devices before using them. Sensifai disclaims all responsibility and shall not be liable for any incidental, indirect, consequential, or otherwise unauthorized disclosure, dissemination, or use of location-based information arising from or attributable to such third-party wearable devices or technologies.

How We Collect Personal Data

The following explains how we collect Personal Data about you, either with your consent or otherwise legally allowed:

  1. Direct Collection from You: We collect Personal Data from you
    • Through our Services, including but not limited to our website, apps, emails, and direct interactions
    • When you create an account or make a purchase with us
  2. Indirect Collection: We collect Personal Data about you
    • Through third-party wearable devices used in combination with our Services. Sensifai does not own, operate, or control any such wearable devices, and does not endorse, recommend, or express any preference for one manufacturer over another. Sensifai further disclaims all responsibility for the data practices, or security of such devices. Users are solely responsible for reviewing and complying with the applicable terms of use and privacy policies governing the use of any such third-party wearable devices.
  3. Automatic Collection – Cookies and Similar Technologies: We collect Personal Data, about you, via the following:
    • We use cookies, beacons, pixels, and other technologies to collect information automatically, which may contain Personal Data. When you use our Service, our servers or an authorized third party may place a cookie on your browser or device.
    • We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer or device when you close your browser software or turn off your computer or device. Persistent cookies remain on your computer or device after you close your browser or turn off your computer or device. Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set by using the opt-out tool at https://optout.networkadvertising.org/. You can also learn more about cookies by visiting https://allaboutcookies.org/, which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. Please note, however, that by blocking or deleting cookies used by us, you may not be able to take full advantage of the Service.
    • Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not currently alter our practices when we receive a “Do Not Track” signal from a visitor’s browser, except as specifically required by law. For information about “do not track” from The Future of Privacy Forum, click here.

How We Use Personal Data

We use, collect, process and disclose Personal Data to:

  • To provide our Service: We use, collect, process and disclose your Personal Data to enable us to operate and administer our Services, to process payment for the Services requested by you where applicable, and to perform any contract with you for the Services you request according to any applicable terms of service;
  • To communicate with you and respond to your inquiries and requests: If you contact us by any available means, we will use your Personal Data to the extent it is necessary to fulfill your request and communicate with you;
  • To manage your account (when applicable): We will use your Personal Data to manage your user account for the purpose of performing the contract with you according to any applicable terms of service and relevant national laws and regulations.
  • To comply with legal and regulatory requirements and to protect our rights, privacy, safety, or property: We will use your Personal Data when cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights and is necessary for our legitimate interests to protect against misuse or abuse of our Service and data hosted on our Service, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court order, or legal process, and/or to respond to lawful requests.
  • For analysis, improvement, and personalization of Service: We will use your Personal Data to analyze trends and track your usage of our Services, and interactions with emails to the extent this is necessary for us to develop and improve our Services, conduct market research, and provide our users with more relevant content and services; and
  • Where we need to use, collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide that required Personal Data when requested, we may not be able to perform the contract.

SMS Text Program

We operate a text message program (“Text Program“) as it is necessary to keep you informed and allow us to provide the services requested by you. The Text Program is subject to this Privacy Policy, as applicable. By opting into the Text Program, you consent to be sent periodic text messages to the telephone number you provided. By providing a telephone number to us, you confirm that you have the authority to grant us the right to send text messages to that telephone number.

You may opt out of receiving messages at any time by replying “STOP” to any message you receive. After this, you will no longer receive messages. Please note that opting out of the Text Program may result in you not receiving notifications regarding your health in a timely manner and prevent us from delivering our Services to you. You understand and acknowledge that you are solely responsible for any consequences, outcomes or losses resulting from your opting out of the Text Program. You can receive assistance or obtain more information at any time by contacting us at privacy@sensifai.health.

While the Text Program is free of charge, your wireless carrier’s normal messaging, data and other fees may apply. We are not liable for delayed or undelivered messages. Please contact your wireless carrier for information about your messaging plan.

Push Notifications

We may display push notifications on your mobile or third party wearable device or to keep you informed and allow us to provide the Services requested by you.

You may in most cases opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications,” and then changing the settings. Different device configurations, or updates to devices, may affect or change how these settings work. Please note, however, that by opting out of receiving push notifications, you may not be able to take full advantage of the App or receive updates regarding your booking and other services you requested in a timely manner. Your choice to opt out will not affect notifications placed by any other organization.


How and with Whom We Share Personal Data

We may share your Personal Data with:

  • Our subsidiaries and/or corporate affiliates
  • Third parties to whom you authorize us to disclose your Personal Data in connection with our Services, including employers, healthcare professionals, insurers, and health systems
  • Service providers working on our behalf, or providing services such as information technology support, website hosting, payment processing
  • Authorized law enforcement, regulatory or other government authorities, where required by applicable law, or pursuant to a valid subpoena or court order
  • Third parties to protect and defend our rights and interests, such as when needed for corporate audits, to investigate or respond to a complaint or threat, or to exercise our legal rights
  • Acquirer(s) of our business, in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.


Detailed information about the third parties we may share your Personal Data with is outlined hereinbelow. Detailed information about the third parties we may share your PHI with can be found in our HIPAA Notice.

We may also share your Personal Data internally within Sensifai. We may combine the Personal Data you have provided us with Personal Data we have collected about you through our various platforms, whether offline or online, or from other sources such as a wearable third-party device you use in connection with our Services, public databases, our third-party partners and vendors.

  1. With Healthcare Professionals and Health Systems
    • In accordance with bilateral agreements with healthcare professionals and health systems, to the extent permitted by applicable laws
    • As necessary for the provision of our Service
    • With your consent or at your direction

    This Privacy Policy does not address how your healthcare professionals or health systems will use and disclose Personal Data obtained using our Services. Sensifai specifically disclaims any and all liability in connection with any such third parties’ use of your Personal Data. It is each health system’s responsibility to use and disclose all Personal Data, in accordance with applicable laws and regulations, including but not limited to HIPAA.

  2. With Service Providers
    • With vendors, consultants, professional advisors and other service providers who need access to such information to carry out work on our behalf, pursuant to agreements that prohibit the service providers from using or disclosing Personal Data other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the Personal Data. This may include payment processors, data hosters, application developers, marketers, sales support and customer support.
  3. For Legal and Safety Reasons
    • If required by law, regulation, legal process, or governmental request
    • To enforce our rights, prevent fraud, or protect our network’s security
  4. Other
    • With your consent, or at your discretion
    • In the event of a sale of all or substantially all of our business or another similar transaction, to the extent permitted and in accordance with applicable laws and regulations, we may transfer or disclose Personal Data to a purchaser or prospective purchaser, who may collect, use and disclose such Personal Data for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Privacy Policy.


Sensifai DOES NOT sell Personal Data. We may disclose aggregate and anonymized statistics about our users in order to describe our business to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no Personal Data, and will not directly or indirectly identify any specific person.


Confidentiality and Security

Sensifai Inc. is dedicated to ensuring the security of your Personal Data. We’ve implemented appropriate administrative, physical, and electronic procedures aimed at safeguarding your Personal Data from unauthorized access and ensuring its correct use.

Utilizing industry-standard protective measures, including industry-standard encryption technologies, we strive to secure the information under our care from unsanctioned access, usage, and disclosure. When we interact with your Personal Data, we adhere to the privacy and security guidelines set by relevant laws, inclusive of HIPAA, where applicable.

Your user account is password-protected to uphold your privacy. For optimal security, avoid sharing your password and always log out after accessing your account.

By downloading our mobile application from platforms like Apple App Store or Google Play, they might identify you as a user of our Service.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. We cannot guarantee complete security due to unforeseen circumstances like unauthorized breaches or malfunctions.

In case of a Personal Data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the proper authority as soon as feasible following becoming aware of the breach. Notification may be delayed where requested by law enforcement for the purpose of an active criminal investigation, but notification will still be provided in the most expedient time and manner possible, subject to the circumstances.

If security concerns arise, please immediately reach out to the contact provided in this policy.

Data Retention

We will keep Personal Data provided by you only for as long a time as is reasonably necessary consistent with the original purpose of collection or such longer period as may be required by applicable law. We determine the appropriate retention period on the basis of the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means. Personal Data provided by you that is no longer required to fulfil the identified purposes will be promptly and securely destroyed, erased, or made anonymous in accordance with the applicable laws and regulations. Typically, we retain Personal Data for six years after your last interaction with us, though the period might vary based on contractual agreements or legal obligations.

Privacy Rights

To access, modify, or erase your Personal Data, or to understand our practices, connect with us at the provided email. Sometimes, we might not be able to fulfill certain requests due to operational or legal reasons. Please note that we may ask you to verify your identity before taking further action on your request. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question answer and other information.

  • Managing Your Information: You are responsible for keeping your Personal Data up-to-date. You can also ask us to correct inaccurate or incomplete Personal Data concerning you that you cannot update yourself.
  • Access to Your Information: You have the right to request information about the Personal Data we hold on you at any time. You can contact us via email at privacy@sensifai.health, and we will provide you with your Personal Data via email. If you require additional copies, we may need to charge a reasonable fee.


If you are a Californian resident, once per calendar year, you may request that we provide a list of companies to which we disclose your Personal Data for business purposes, and a list of the categories of such Personal Data that we share. You may request further information about our compliance with this law by contacting us. Please include “California Privacy Rights Request” in the first line of the description and your California mailing or street address. Please note that we are only required to respond to one request per client each year, and we are not required to respond to requests made by any other means, nor to requests made by non-California US residents.

  • Right to Erasure: If you no longer want us to use your Personal Data to provide you with the latest news about our Service and/or other helpful information, you can request that we erase your Personal Data by contacting us.


Please note, however, that we may retain some of your Personal Data as necessary for our legitimate interests, such as fraud detection and enhancing security. We may also retain and use your Personal Data to the extent necessary to comply with our legal obligations, such as keeping information for tax, legal reporting and auditing obligations, as well as professional obligations. Information you have shared with others (e.g. comments, community postings) may continue to be publicly visible. Additionally, some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers. Residual copies may also be kept in our backup systems. If we have shared your Personal Data with service providers, we will let them know about the erasure where possible.

Right to Object to Direct Marketing: Under certain scenarios, you may get marketing messages from us. If you have already given your consent, but you prefer not to receive promotional information from us, you may unsubscribe by using the unsubscribe link situated at the bottom of any promotional message you receive from us or by contacting us by email. However, you cannot unsubscribe from essential communications about your account.

  • Restriction of Processing: You can ask us to block or suppress the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or you object to us processing it, and we have no legitimate grounds that override yours. Such request alone does not stop us from storing your Personal Data.
  • Right to Portability: Whenever we process your Personal Data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your Personal Data transferred to you or to another party. This only includes the Personal Data you have provided to us.
  • Automated Decision-Making: In certain cases, our Services may use automated decision-making processes. This means that certain decisions are made based solely on automated processing, including profiling, without human involvement. Specifically:
    • Notifications: You may receive certain notifications (Push notifications, emails, text messages) automatically when our system detects certain variables.
    • Treatment Action Plans: In some scenarios, an action plan/treatment program prescribed by your healthcare professional may be started automatically by our system.

    Automated decisions are based only on the Personal Data you provide and the data generated through your use of our Services. We never use automated decisions to make legal or financial judgments about you.

    We rely on automated decision-making only where it is necessary for the timely and effective performance of our Services or where you have given us your explicit consent.

    When automated decisions are not strictly necessary for us to provide the Services, we will ask for your explicit consent before they occur. For example, you may be presented with a checkbox, toggle, or in-app setting that lets you decide whether the system can automatically initiate your treatment plan. You can change your choice at any time in your account settings or by contacting us at privacy@sensifai.health. Withdrawing consent will not affect any automated actions that were already carried out lawfully before your withdrawal and may effect the future performance of the Services.

    You have the right to obtain meaningful information about the logic involved in these automated decisions, contest an automated decision and/or request human review. If you wish to exercise these rights, please contact us at: privacy@sensifai.health

  • Consent Withdrawal: To the extent we base the collection, processing, and sharing of your Personal Data on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
  • Right to Limit the Use of Sensitive Personal Data: If you are a resident of a territory with laws that provide for a right to limit the use of sensitive Personal Data, as defined in the applicable law(s), you have the right to limit the use of your sensitive Personal Data to only those purposes that are necessary for us to provide the Service to you, by contacting us.


For comprehensive details about your PHI rights, refer to our HIPAA Notice.

Third-Party Links

Occasionally, we might include third-party links or showcase their content to enhance user experience. We do not govern these third-party sites, which have their own privacy protocols and practices. If you decide to access any third-party site linked within our Service, you do so entirely at your own risk. We make no representations, warranties, or guarantees regarding the quality, accuracy, reliability, or suitability of any products, services, or content offered by such third-party sites, and we do not endorse them in any way. We strongly recommend that you review the applicable terms and privacy policies of any third-party sites before engaging with them.

Privacy Concerning Minors

Sensifai doesn’t knowingly gather Personal Data from those below the age of majority in the jurisdication where such individual resides. If we learn that we have done so inadvertently, the data will be deleted promptly.

Policy Updates

This Privacy Policy may undergo periodic updates. Should significant changes affecting users be made, we will post the updated policy on our platforms, and notify you of such changes via other means consistent with applicable law(s).

Termination

Sensifai holds the right to discontinue any user’s access to the Services. Upon termination, your Personal Data will either be returned or destroyed or anonymized as per applicable laws.

Queries and Feedback

For any concerns or feedback related to this Privacy Policy or our Service, please contact Sensifai’s Privacy Officer at: privacy@sensifai.health

Sensifai Health Inc.
ATTN.: Privacy Officer
306-1061 rue Saint-Alexandre
Montréal (Québec) H2Z1P5 Canada

If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the competent supervisory authority.

By using our Service, you acknowledge that you have read and understand this Privacy Policy.


HIPAA NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

EFFECTIVE DATE: September 18, 2025

Who Abides by this Notice

Sensifai Health Inc. (“Sensifai“, “Company“) offers a digital health platform with insights sharable to health and medical researchers and healthcare professionals (referenced as “we,” “our,” or “us“) when you use our services, including the EarlyCue platform (the “Services“).

This is a unified declaration of our data privacy practices (“Notice“).

The parties adhering to this Notice include:

  • Health practitioners who cater to your needs via our Services, including the EarlyCue
  • Health professionals using our Services, including the EarlyCue platform and mobile application, to render remote coaching to you.
  • Our workforce, associates, and partners, inclusive of auxiliary support entities.


We will share users’ protected health information (“PHI“) as necessary to provide the Services and carry out payment as permitted by law. Should you have queries about this Notice, our contact details are available at the end of this document.

Our Pledge to Privacy

Preserving the privacy, integrity and authenticity of the PHI you entrust us with during your engagement with our Services is paramount. PHI encompasses health information about you which could be used to identify you and which we keep or transmit in electronic, oral, or written form. PHI includes identifiable details about you such as your name or address, your past, present, or future health conditions (whether physical, mental, or medical), past, present or future health care provided, past, present or future medications prescribed, or payment histories. This data is vital for furnishing high-quality care and meeting regulatory mandates.

By law, we’re obligated to uphold the privacy of PHI and acquaint you with our statutory duties and privacy protocols pursuant to the Federal Health Insurance Portability and Accountability Act (“HIPAA“). We are required to and will promptly notify you in the event of a breach of your PHI.

We are also required to inform you that there may be a provision of applicable law that relates to the privacy of your health information that may be more stringent than a standard or requirement under HIPAA. We follow applicable privacy laws when they are stricter or more protective of your PHI than HIPAA.

We are required to abide by the terms of this Notice for as long as it remains in effect. We reserve the right to change the terms of this Notice as necessary and to make a new notice of privacy practices for all PHI held by us. The revised notice will be available on request, in our office, and on our website. In the event of a material revision of the terms of this Notice, the revised notice will be sent to you via email, or you will receive notification that the revised notice has been posted to our website. A copy of any revised notice or information pertaining to a specific state law may also be obtained by mailing a request to the Privacy Officer at the address below.

The details within this Notice pertain to the records of the Services availed through Sensifai. Independent practices or notices might be adopted by your healthcare providers. We are happy to elucidate any aspect of this Notice to you or your kin.

Permissible Uses and Disclosures of Protected Health Information

Your PHI’s confidentiality is non-negotiable. With a robust framework of policies, procedures, and safeguards, we work tirelessly to protect your PHI. Below are categories showcasing varied ways we use and share your PHI internally and externally. Not every disclosure is listed, but all actions fall within these categories. Specific actions might also necessitate your express consent.

  1. With Your Authorization and consent: Except as outlined below, we will not use or disclose your PHI for any purpose other than treatment, payment or health care operation unless you have signed a form authorizing such use or disclosure. Upon your request, we might share relevant details. Such disclosures might need your written consent. If you wish for us to share your PHI with anyone or any organization, you may give us authorization in writing to do so.
  2. For Treatment: The most pivotal use of your PHI will be for treatment. PHI (like your medical history and symptoms) could be used or shared with healthcare providers like doctors or nurses so that they can deliver the right care to you. Moreover, we might use the PHI in order to send you reminders, notifications related to your health status, or other health insights. Other care providers, such as technicians, medical students, or hospital personnel involved in your care, might also access this information.
  3. For Payment: We will make uses and disclosures of your PHI as necessary for payment purposes. During the normal course of business operations, we may forward information regarding your medical procedures and treatment to your insurance company to arrange payment for the services provided to you. We may also use your PHI to prepare a bill to send to you or to the person responsible for your payment.
  4. For Healthcare Operational Needs and Activities: Your PHI will be used and disclosed as necessary, and as permitted by law for our healthcare operations. It helps in our organizational planning, streamlining administration, and enhancing the quality and cost-efficiency of care. Examples include quality checks, disease management initiatives, surveys, data compilation, and training — all with the purpose of improving treatment and patient care.
  5. Business Collaborations: At times, third-party business associates will assist us in delivering our services. Such entities, including quality assurance agencies or billing services, may access your PHI to complete their tasks. To secure your PHI, such associates will be required to commit to stringent data protection standards.
  6. Research: In limited circumstances, we may use and disclose your protected PHI for research purposes. In cases where your specific authorization is not required by law, your privacy will be protected by strict confidentiality requirements applied by an Institutional Review Board which oversees the research or by representatives of the research that limit their use and disclosure of your information.

Special Situations Where Disclosure Does Not Require Your Authorization at Sensifai

The below categories outline particular circumstances in which Sensifai may disclose or utilize your PHI without obtaining your explicit consent:

  1. Public Health Initiatives: Sensifai can share your PHI to:
    • Prevent or monitor diseases, injuries, or disabilities.
    • Report events like births and deaths.
    • Address reports of child, elder, or dependent adult abuse or neglect.
    • Address reactions to medications or issues with medical products.
    • Inform individuals about product recalls that might impact them.
    • Alert individuals who might be at risk of disease exposure or transmission.
    • Notify emergency responders about potential HIV/AIDS exposure, as aligned with applicable laws.
  2. Abuse or Domestic Violence Victims: Should we reasonably ascertain that you are facing abuse or neglect, your PHI can be shared with legal authorities or protective service agencies in line with applicable laws.
  3. Health Supervision Activities: For activities such as audits, inspections, investigations, and licensure, we might share your PHI with health oversight agencies.
  4. Legal Proceedings: During lawsuits or legal disputes, your PHI may be used or disclosed in alignment with court or administrative orders, subpoenas, or discovery requests.
  5. Engaging with Law Enforcement: We may provide your PHI to law enforcement:
    • In response to legal processes like warrants or subpoenas.
    • To aid in identifying or locating suspects or witnesses.
    • When discussing victims of crime under specific conditions.
    • When discussing potential criminal activities at Sensifai.
    • In emergencies to report details about a crime.
  6. Upon Passing: Your PHI can be provided to coroners, medical examiners, or funeral directors.
  7. Government-Related Functions: For specific governmental tasks, like military functions or intelligence activities, your PHI may be disclosed.
  8. Incarceration: If you are incarcerated or in police custody, your PHI might be shared if it is necessary for your healthcare or the safety of others within the correctional facility.
  9. Workers’ Compensation: If needed, and only where required by state law, we may share your PHI in line with workers’ compensation laws.
  10. As Mandated by Law: Outside of the scenarios mentioned above, we might need to share your PHI if other laws require it.


Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below (Situations Requiring Your Explicit Authorization at Sensifai), please contact us using the contact information below, and we will make reasonable efforts to follow your instructions.

In these cases, you have both the right and choice to tell us whether to:

  • Share information, such as your PHI, with your family, close friends, or others involved in your care;
  • Share information in a disaster relief situation;

If you are not able to tell us your preference, for example, if you are unconscious, we may share your information if we believe it is in your best interest, according to our best judgment. We may also share your information when needed to lessen a serious and imminent threat to health or safety.


Situations Requiring Your Explicit Authorization at Sensifai

For any other use of your PHI not covered above, we will obtain your written consent. If you previously authorized a specific use of your PHI and wish to revoke it, you can do so. We, however, cannot reverse any previous disclosures.

In the following cases, we will NOT share your PHI unless you give us your written permission:

  • Most sharing of a mental health care professional’s notes (psychotherapy notes);
  • Marketing purposes;
  • Selling or otherwise receiving compensation for disclosing your PHI.
  • Automated decision making that is not essential to the Services.


Your Rights Concerning Your PHI at Sensifai

You have specific rights concerning your PHI. To learn more or exercise these rights, contact Sensifai using the contact information provided below.

  • Right to Request Limitations: You can ask for limits on how we use and share your PHI:
    1. For treatment, payment, and healthcare processes.
    2. With people involved in your care or payment for your care.
    3. To identify your location and condition to people involved in your care or payment for your care.

    Although we’ll consider all restriction requests, we’re not obliged to agree, unless it concerns a health plan payment, and the PHI is about a service that has been fully paid for out-of-pocket. Please submit your requests in writing. If approved, we’ll abide by it unless there’s an emergency or prior disclosure.

  • Confidential Communications: You can request that we communicate with you about your PHI in a specific way or at a particular location (e.g., only at work). Submit this request in writing. We won’t ask why and will try to fulfill all reasonable requests.
  • Access to Records: You have a right to access the medical, health and billing files we maintain about you. While you can inspect and get copies of these, there might be rare times we might decline. If denied, you can ask for a review by another healthcare professional we pick. To access, write to us. If records are digital, you can request an electronic version or ask us to send it to a designated person/entity.
    • Costs: For paper copies, we will charge based on copying, mailing, and supply expenses. For electronic versions, any charges will be based on our labor costs.
  • Amending Records: You can request changes to your PHI in our records by writing to us and stating your reasons for making the request. You will need to sign your request or have a legal representative sign it. Rest assured that we will always give your request careful consideration. However, we may decline to accept the amendment if we believe the current information is accurate or due to another specific reason. You can then add a disagreement note to your records. We may include our reasons for refusal in your record as well. If we make the amendment, we may communicate the changes to others who work for us if we feel the notification is necessary.
  • Right to Addendum: You can append an addendum to your medical records.
  • Right to a Paper Copy: You have a right, even when you have consented to receive electronic notices, to obtain a paper copy of this Notice. To do so, please submit a request to the Support Office using the email below
  • Accounting of Disclosures: By writing to us, you can get a report of certain times we’ve shared your PHI with outside entities over the past six years. Specify the format you prefer to receive the accounting in (e.g., paper or electronic). The first request in any 12-month period will be free, but subsequent requests within a year might come with charges. You will not be charged the fee until after being notified of what it will be, and after being given an opportunity to rescind or modify your request.
  • Choose Someone to Act for You: If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your PHI.
  • Make a Complaint: You have the right to complain if you feel we have violated your rights by using the information provided below.
  • Not to be Subject to Retaliation: You have the right not to be subjected to retaliation for exercising your rights. We will not retaliate against you for filing a complaint or for exercising any of your rights.
  • Right to be Informed of Breaches: You have a right to be informed if there’s ever a breach of your PHI security. We are required by law to protect the privacy and security of your PHI through the use of appropriate safeguards. We will promptly notify you in the event a breach occurs involving or potentially involving your PHI and inform you of what steps you may need to take to protect yourself.


Minimum Necessary Protocol at Sensifai

In line with legal mandates, Sensifai ensures that any request or sharing of your PHI is limited to the minimum necessary information. This commitment helps safeguard your privacy.

Notice Amendments

Sensifai may update this Notice periodically. Updated terms will be applicable to all PHI.

Getting in Touch with Sensifai, Addressing Concerns or Filing Complaints

For more details on your privacy rights or any concerns about your privacy rights, to submit a request pursuant to this Notice, or if you believe your privacy rights have been violated, reach out to our Privacy Officer using the contact information hereinbelow.

Sensifai Health Inc.
Attn: Privacy Officer
Email: privacy@sensifai.health
Mailing Address:
306-1061 rue Saint-Alexandre
Montréal (Québec) H2Z1P5 Canada

For formal complaints, contact the U.S. Department of Health and Human Services, Office of Civil Rights. Rest assured, we will never retaliate against any complaints.