Welcome to the Tenzr Health Platform, designed to help Health Care Providers provide Clients with a tailored health program to achieve specific health goals.
This Privacy Policy describes how we collect, use, protect and share information about you which we obtain when you access and use our Platform, including when you register for the Platform, communicate within the Platform, configure and use the Platform, or submit questions or feedback. This privacy policy also governs the collection and use of information when you use our Website or any of our Apps, in relation to use of our Platform, although we may provide additional notice and choice options within the specific medium itself.
In addition, this Privacy Policy applies to information that we obtain when you communicate or interact with us outside of the Platform, including by e-mail, telephone, and otherwise.
Please read this Privacy Policy carefully to understand how we will treat your information before you access or use our Platform or communicate with us outside of the Platform.
By accessing or using our Platform or communicating with us outside of the Platform, you are accepting and consenting to the practices described in this Privacy Policy, which may be updated and amended from time to time. If you do not agree to the terms of this Privacy Policy, you must not access or use our Platform or communicate with us.
Definitions
For purposes of this Privacy Policy, the following defined terms mean:
App: Any application (including a PC, Mac, iPad, Android Tablet, iOS, Android OS, or other platform application available freely, or restricted in distribution) owned or operated by Tenzr Health. References to the “App” include all features, functionality, tools and Content available on or through each such application.
Content: All information, videos, text, photos and other content provided or made available by Tenzr Health on or through the Platform, including information, videos, text, photos and other content relating to physical conditions and/or exercise regimens.
Communication: Any communication conducted between the User and Tenzr Health.
Tenzr Health, Tenzr, we, us, Company: Tenzr Canada Inc d.b.a Tenzr Health, and our officers, directors, employees, contractors, sponsors and agents. Additionally, if applicable, our affiliates, service providers and licensors, and their respective officers, directors, employees, contractors and agents.
Platform: All Apps, Sensors, Content, and Websites, made available to the User by Tenzr Health, including any related services, and any software and technology used to provide any of the foregoing.
Sensor: All electronic sensing devices and accessories made available to you by Tenzr Health.
Tablets: All Tablet computers (e.g. iPads) and accessories made available to you by Tenzr Health.
Kit, Hardware, Hardware Kit: All Sensors, Tablets and associated accessories made available to you by Tenzr Health.
User, you, your: All persons that access or use the Platform, including the Client and/or the Health Care Provider. References to “access” and/or “use” of the Platform (and any variations thereof) include the acts of accessing or browsing the Website or App, accessing or using the Content and accessing or using the Hardware.
Client: Users on the platform who are receiving treatment from a Health Care Provider on the platform.
Health Care Provider: Users on the platform currently providing or intending to provide treatment to a Client on the platform.
Website: Any Website owned or operated by Tenzr Health (including the Website currently located at www.tenzrhealth.com). References to the “Website” include all features, functionality, tools and Content available on or through each such Website.
Personally Identifiable Information (PII): Information which may personally identify a User. Personally Identifiable Information may be retained as part of records required by Health Care Providers, even if a User’s account access is removed.
Non-Personally Identifiable Information: Information which can not be used to personally identify a User.
Health Information: Information defined as Health Information by the United States Health Insurance Portability and Accountability Act and its implementing regulations (“HIPAA”), and/or Medical information as defined by the Canadian Personal Information Protection and Electronics Documents Act (PIPEDA), or the Health Information Act (HIA) as defined by the Office of the Information and Privacy Commission of Alberta for Alberta users.
Overview
We collect and store information in an electronic format. The treatment and use of information depends on its type.
We consider Personally Identifiable Information to include data that can personally identify you, such as name, phone number, and email address. Non-Personally Identifiable information is information that can not be used to personally identify you. Non-Personally Identifiable Information combined with Personally Identifiable information is also treated as Personally Identifiable Information.
Health Information refers to information defined as Health Information by the United States Health Insurance Portability and Accountability Act and its implementing regulations as each may be modified from time to time (“HIPAA”), and/or the Medical information as defined by the Canadian Personal Information Protection and Electronics Documents Act (PIPEDA), or the or the Health Information Act (HIA) for Alberta users.
We will only use Health Information as allowed under HIPAA, PIPEDA, and HIA, as permitted in an agreement with an applicable customer, or as explained in this Privacy Policy. To the extent that we need to comply with HIPAA, we do. However, not every use of our Platform may be subject to HIPAA. In instances where HIPAA does not apply to a particular use of our Platform, we will follow the terms of this Privacy Policy and respect your rights as set out in this Privacy Policy.
We will not ask for or request information such as government identifiers, or financial information, except in connection with payment. Please do not provide this information to us, including through emails, feedback forms or otherwise.
Collection of Information
Information Collected Directly from Users
We collect and store information that Clients and Healthcare Providers provide directly to us, including when registering for the Platform, submitting information and updates about a Client’s condition, responding to a survey, contacting us with questions or comments, or providing other feedback.
For Clients, this information includes:
First and Last Name
Email
Phone Number
Diagnosis
Health Care Provider(s) Name
Medical Insurance Plan
If Clients do not provide us with this information or do not authorize their Healthcare Provider to provide us with this information, Clients will be unable to access and use the Platform.
For Healthcare Providers, this information includes:
First and Last Name
Email
Phone Number
If Healthcare Providers do not provide us with this information, they will be unable to access and use the Platform.
Information Collected During Use of the Platform
Health Information
We collect and use the Client’s Health Information when Users access and use our Platform, to enable the use and appropriate functioning of the Platform. For example, we may collect and use the Client’s range of motion measurements and pain scores to customize a healthcare program. You consent to us using your Health Information for these purposes and any related purposes as explained in this Privacy Policy or through your use of the Platform.
Health Information collected through the Platform is retained as part of the Client’s record with their Health Care Provider and may continue to be stored even if the Client’s access to the Platform is removed.
Technical Information
We collect and store certain technical information when you access, browse and use our Platform. This technical information helps us operate our Platform and provide access to you and includes standard information about visits and system capabilities, such as:
Information about your use of the Platform (including date, time and duration of access;
Pages you view, Content you select to view, length of time viewing Content
Information we need and use to facilitate your use of our Platform (including providing access to third-party websites and services), such as URL requests, destination IP addresses, or device configuration details
Page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), your engagement with certain variable/dynamic elements of a page and methods used to browse away from the page
Information about the device(s) you use to access our Platform, including MAC address, IP address, browser type and version, location, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers
We may also collect information using cookies and beacons
Use of Information
We use your information for various purposes, including operating the Platform, managing your access, sending relevant information, contacting you about account activity, generating reports, complying with laws, fulfilling contractual obligations, notifying you of changes, protecting the Platform's security, and as otherwise described during information collection.
All Information
We collect and may use and disclose any of the information we collect, to:
Allow us to operate our Platform, including payment processing, Platform administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes
Manage your access to our Platform
Send you information that enables you to use our Platform
Contact you directly about activity on your account
Create reports for our affiliates, licensors, service providers and Users or prospective Users that may include aggregate information about the use of various aspects of the Platform
Comply with laws and regulations
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection
Notify you about changes to our Platform
Protect the integrity and maintain the security of our Platform, including secured areas of the Platform
In any other way that we describe when you provide the information
For any other purpose for which you may provide consent
Maintain records associated with Users as required to support Health Care Providers in delivering care, including after account access has been removed
Personally Identifiable Information
We may use your information, including Personally Identifiable Information, to:
Respond to your requests, feedback or questions, including by telephone, text (SMS) or email
Provide you with information about Content, products or services, from us or third parties, that may interest you; and send you emails about usage, updates, information, or alerts regarding our Platform
For research purposes after it has been de-identified, following applicable legal or regulatory requirements
As otherwise permitted under any applicable laws
Non-Personally Identifiable Information
We may use technical information or non-Personally Identifiable Information to:
Evaluate and improve our Platform and present Content in the best way for you and for your device(s)
Measure or understand the effectiveness of the Platform we serve to you and other Users like you
For research purposes, following applicable legal or regulatory requirements
By using our Platform, you consent to use your information for these purposes.
Sharing of Information
We will share information between Health Care Providers and Clients on the platform to operate and provide appropriate functioning of the Platform. This includes:
Sharing Client information with the Healthcare Provider associated with the Client on the Platform;
Sharing Client information with other Healthcare Providers in the same facility as the Healthcare Provider associated with the Client.
We may share information, including Personally Identifiable Information, with our licensors, service providers and agents to the extent reasonably necessary to operate and provide our Platform to you.
We may share any information, including Personally Identifiable Information and Personal Health Information with:
Our subsidiaries and affiliates
Our service providers and subcontractors to the extent reasonably necessary to enable us to operate and provide our Platform to you
A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personally Identifiable Information held by us about our Users is among the assets transferred
You, upon your written request.
We may also disclose your Personally Identifiable Information:
To comply with any court order, law or legal process, including responding to any government or regulatory request. If we receive a request from a governmental entity to provide it with your Personally Identifiable Information, we will make reasonable attempts to notify you of such request, to the extent reasonably possible and legally permissible.
To investigate potential unauthorized access or misuse of our Platform or otherwise enforce our Terms of Use or other agreements; to protect our assets or rights, including for billing and collection purposes
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tenzr Health, our Users or others, including exchanging information with other companies and organizations for fraud protection and credit risk reduction
For any other purpose disclosed by us when you provide the information
We may share Non-Personally Identifiable Information, aggregate or anonymous data:
With analytics, search engine, or other service providers that help us improve or assess the performance (including the commercial performance) of, our Platform
With other Users or prospective Users of the Platform
To advertisers and advertising networks to select and serve relevant advertisements.
We will not sell your Personally Identifiable Information to or share your Personally Identifiable Information with third parties for the third party’s direct marketing purposes.
Personal data and Health Information stored on the Platform is controlled by the applicable Health Care Provider. Tenzr Health processes such data on behalf of the Health Care Provider to provide the Platform.
Requests for deletion of personal data are subject to the policies and legal obligations of the applicable Health Care Provider.
User Rights over Data
If you have an account on this Platform, you may request:
Access to your personal data
Correction of your personal data
Removal of your account access to the Platform
Upon request to remove an account, we will remove your ability to access the Platform (including login credentials), however personal data may continue to be retained within the Platform as required by the applicable Health Care Provider, and in accordance with applicable laws and regulations.
If a User wishes to request deletion of their personal data, such requests must be directed to their Health Care Provider, who is responsible for determining data retention requirements. We may retain certain information as required for administrative, legal, security, or regulatory purposes.
Your Choices
You may have the opportunity to receive certain communications from us related to our Platform, including marketing communications. If you provide us with your email address to receive communications, you can opt out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Platform. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.
The accuracy of the information we have about you is very important. Users may update, review, or correct their information at any time by contacting us at hello@tenzrhealth.com.
Securing Your Information
Tenzr Health prioritizes the security of your information and has implemented reasonable administrative, technical and physical safeguards against alteration, loss, unauthorized access, use, modification or disclosure. However, no system can guarantee complete security, so Tenzr Health cannot ensure or warrant that your information, including Personally Identifiable Information, is fully protected. Your use of the Platform and Communication with us carries inherent risks.
You are responsible for protecting your User ID(s) and password(s) and for the security of information that you transmit to us over the internet.
We will notify people in case of data breach.
Not Suitable For Children
Our Platform is intended for use by individuals 13 years of age or older. We do not knowingly collect information from individuals under the age of 13 years without parental consent.
However, if you are a parent, legal guardian, or personal representative of a minor child, you may, in compliance with the Terms of Use, use our Platform on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated following this Privacy Policy. If we learn that we have received any information from an individual under the age of 13 without parental consent, we will take steps to remove the data as permitted by law.
If you believe an individual under 13 years of age has provided us with Personally Identifiable Information without parental consent, please contact us at hello@tenzrhealth.com or by postal mail at the contact information listed in the Contact section.
Links to Third-Party Sites
Our Platform may include links to third-party websites and services, which have their privacy policies. This Privacy Policy applies only to our Platform. We are not responsible for the policies or practices of third parties. Before using or submitting personal data to any linked websites or services, please review their respective privacy policies.
Our Platform may contain links to third-party websites and services, including those of our partners. Please note that these websites and services may have their privacy policies. This Privacy Policy applies to Tenzr Health and our Platform only. We do not accept any responsibility or liability for the policies or practices of any third parties. If you choose to access any websites or services linked from our Platform, please check the applicable policies before you use or submit any personal data to such website or service.
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time to align with changes to our business practices and/or changes to our legal requirements.
Your continued use of the Platform or Communication with us after the updated Privacy Policy has been posted (or any other indication of your consent) will constitute your acceptance of the updated Privacy Policy.
Alberta Health Information Act (HIA)
For Users located in the Province of Alberta, Canada, the collection, use, and disclosure of health information may be governed by the Health Information Act, RSA 2000, c H-5 ("HIA"), administered by the Office of the Information and Privacy Commissioner of Alberta (OIPC).
Custodians and Affiliates
Under the HIA, Health Care Providers using the Platform who qualify as "custodians" (as defined under the HIA) are responsible for the health information they collect, use, and disclose through the Platform. Tenzr Health acts as an "affiliate" of such custodians when processing health information on their behalf to provide the Platform.
Tenzr Health will only collect, use, and disclose health information of Alberta residents in accordance with the purposes authorized under the HIA and as directed by the applicable custodian.
Collection and Use of Health Information
Health information about Alberta residents collected through the Platform is collected for the purposes of providing, supporting, and improving health services to Clients, as authorized under the HIA. This may include:
Providing health services and managing the care of the Client
Planning and delivering health services
Compiling statistical information for health system management purposes
Other purposes as authorized by the applicable custodian or as permitted under the HIA
Disclosure of Health Information
Health information about Alberta residents will only be disclosed in accordance with the HIA. This includes disclosures:
To the custodian and their authorized affiliates for the provision of health services
As required or authorized under the HIA or other applicable law
With the consent of the individual, where required
Access and Correction Rights Under the HIA
Alberta residents have the right to request access to their own health information held by a custodian, and to request correction of that information, in accordance with the HIA. Such requests should be directed to the applicable Health Care Provider (custodian).
If a custodian refuses an access or correction request, the individual may file a complaint with the Office of the Information and Privacy Commissioner of Alberta (OIPC). More information is available at: https://oipc.ab.ca/legislation/hia/.
Safeguards
Tenzr Health implements administrative, technical, and physical safeguards to protect the health information of Alberta residents against unauthorized collection, use, disclosure, or disposal, in accordance with the requirements of the HIA.
Complaints
Individuals who believe their health information rights under the HIA have been violated may contact:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 - 6 Avenue SW
Calgary, Alberta T2P 3W2
Phone: 403-297-2728 | Toll-free: 1-888-878-4044
Website: https://oipc.ab.ca/legislation/hia/
Privacy Impact Assessment Annual Review
We conduct an annual controls review whenever a significant change to the system, data flows, or applicable regulatory requirements occurs, to confirm that the controls described in the Privacy Impact Assessment (PIA) remain accurate and effective. Where significant differences are identified between the current system and the PIA, Privacy and Compliance shall assess whether a PIA amendment or new PIA submission is required.
Data Retention
We hold onto PHI data for at least 10 years.
Contact
If you have any questions, comments, or requests regarding this Privacy Policy or how we handle your personal information, please contact our Privacy Officer:
Gautam Sadarangani
Tenzr Health, Inc.
Email: gsadarangani@tenzrhealth.com
Mailing Address: 1001 W Broadway, Vancouver, BC V6H 4B1, Canada
Alternatively, you may reach us at hello@tenzrhealth.com for general inquiries related to privacy.
version 1.1 updated 2025/09/15
version 1.2 updated 2025/05/04