Our Commitment

Ecotone Health Insurance Inc. (“Ecotone,” “we,” “our,” or “us”) is committed to protecting your privacy and safeguarding the personal information entrusted to us.

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This Privacy, AI & Data Protection Policy explains how we collect, use, disclose, store, protect, and manage personal information in connection with our websites, insurance products, benefit plans, advisory services, and related communications.

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This policy applies to all Ecotone-operated websites and products, including:

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• ecotonehealth.ca;

• mytip.ca, including The Industry Plan;

• legacy-plan.ca, including The Legacy Plan;

• One by Ecotone and related Ecotone benefit solutions;

• any future Ecotone-operated websites, landing pages, forms, digital tools, or client communications.

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Ecotone complies with the Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial

privacy requirements, and the rules and expectations of the insurance regulators and councils in the provinces where Ecotone is licensed to conduct business.

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Ecotone Health Insurance Inc. is incorporated in Saskatchewan and authorized to conduct insurance business in Saskatchewan, Alberta, British Columbia, and Ontario.

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Personal Information We Collect

We collect personal information only for reasonable business, insurance, administrative, legal, and regulatory purposes.

Depending on your relationship with Ecotone, we may collect information directly from you, your employer, association, advisor, insurer, third-party administrator, claims administrator, or authorized representative.

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This may include:

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• name, mailing address, email address, phone number, and date of birth;

• province of residence and eligibility information;

• employer, association, membership, or group affiliation details;

• dependent and beneficiary information, where applicable;

• insurance application, enrollment, renewal, and cancellation information;

• coverage details, policy information, certificate numbers, and plan selections;

• claim-related information needed to administer or support coverage;

• communications with Ecotone, including emails, forms, call notes, and service inquiries;

• information needed to comply with legal, regulatory, insurer, or administrator requirements.

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We only collect the information reasonably necessary for the purpose identified.

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How We Use Personal Information

We use personal information to:

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• confirm eligibility for coverage;

• provide quotes, enrollment support, and policy service;

• administer, manage, and service benefit plans;

• communicate with you about your plan, application, renewal, coverage, billing, claims, or account status;

• support claims administration and coordination with insurers or third-party administrators;

• respond to inquiries, complaints, access requests, or service issues;

• maintain accurate business and compliance records;

• meet legal, regulatory, licensing, insurer, and contractual obligations;

• improve our internal processes, client service, website experience, and communication systems;

• send relevant plan education, renewal notices, service updates, and marketing communications where permitted by law.

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If we need to use your personal information for a new purpose that is not reasonably connected to the original purpose, we will request your consent unless otherwise permitted or required by law.

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Consent

By applying for coverage, requesting a quote, submitting information through our websites, communicating with Ecotone, or using our services, you consent to the collection, use, and disclosure of your personal information as described in this policy.

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You may withdraw consent, subject to legal, contractual, insurer, administrator, and regulatory limitations. Please note that withdrawing consent may affect our ability to provide quotes, maintain coverage, administer benefits, process service requests, or support claims.

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Use of Artificial Intelligence

Ecotone uses artificial intelligence tools responsibly to support business productivity, drafting, research, workflow design, marketing, education, and general administrative efficiency.

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Ecotone does not intentionally enter client personal information, private health information, claims information, banking information, application details, policy records, certificate numbers, or other sensitive client data into public or general-purpose AI tools.

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When AI tools are used, Ecotone takes reasonable steps to ensure that:

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• client personal information is not used in prompts or uploaded files;

• information is anonymized, generalized, or de-identified where possible;

• AI is used to support human work, not replace professional judgment;

• AI-generated content is reviewed by a person before being used for client-facing, compliance, insurance, or advisory purposes;

• AI is not used as the sole basis for eligibility, underwriting, claim, cancellation, or coverage decisions;

• sensitive client records remain within approved business systems, insurers, administrators, or secure service providers.

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Ecotone may use AI to help create educational content, website copy, workflows, marketing concepts, internal process documents, summaries, and non-client-specific business materials.

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Ecotone does not sell client information, train AI systems using client files, or permit client information to be used for unauthorized AI model training.

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Automated Decision-Making

Ecotone may use digital forms, CRM systems, automation tools, and workflow rules to help organize leads, applications, reminders, onboarding, renewal notices, and service communications.

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These tools may help route information, trigger follow-ups, or identify next steps. However, Ecotone does not rely on fully automated decision-making to make final decisions about insurance eligibility, underwriting, claim payment, cancellation, or coverage entitlement.

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Final coverage, eligibility, underwriting, and claim decisions are subject to the applicable insurer, policy documents, plan rules, third-party administrator requirements, and licensed representative review where applicable.

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Storage, Data Residency, and Service Providers

Ecotone uses secure business systems and third-party service providers to operate its websites, CRM, email, enrollment, administration, payment, claims, document, and communication processes.

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Where practical, Ecotone prioritizes Canadian-based systems, Canadian data storage, and service providers with strong privacy and security safeguards.

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Some approved service providers may process or store information outside Canada or may be subject to the laws of another jurisdiction. Where this occurs, Ecotone takes reasonable steps to ensure that personal information is protected through contractual, administrative, technical, and organizational safeguards.

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Ecotone remains responsible for personal information transferred to service providers for processing.

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Payment and Banking Information

Ecotone does not collect or store client banking information directly on its own websites.

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Payment information, banking information, credit card information, withdrawals, and premium collection are handled securely by authorized third-party administrators, payment processors, insurers, or approved service providers acting on behalf of Ecotone or the applicable plan.

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Disclosure of Personal Information

Ecotone may share personal information only when reasonably necessary and permitted or required by law.

This may include sharing information with:

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• insurers and insurance carriers;

• third-party administrators and claims administrators;

• licensed advisors or representatives involved in servicing your coverage;

• service providers that support Ecotone’s business systems, communications, websites, forms, CRM, document storage, or administration;

• healthcare professionals, pharmacies, dental offices, or providers where needed to verify coverage or support claims;

• authorized representatives, including legal representatives, guardians, executors, or individuals with Power of Attorney;

• employers, associations, or group sponsors where required for eligibility, billing, or plan administration;

• government, tax, legal, law enforcement, or regulatory authorities when required or permitted by law.

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Ecotone does not sell, rent, or trade personal information.

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Safeguarding Personal Information

Ecotone maintains administrative, physical, and electronic safeguards designed to protect personal information from unauthorized access, loss, theft, misuse, disclosure, copying, modification, or disposal.

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These safeguards may include:

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• password-protected systems;

• access controls and role-based permissions;

• secure cloud-based business systems;

• confidentiality obligations for personnel and representatives;

• secure document storage and transmission practices;

• limited access to information based on business need;

• reasonable review of vendors and service providers;

• internal privacy and confidentiality practices;

• secure disposal or deletion of information when no longer required.

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While no system can guarantee absolute security, Ecotone takes privacy and confidentiality seriously and uses reasonable safeguards appropriate to the sensitivity of the information.

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Privacy Breaches

If Ecotone becomes aware of a privacy breach involving personal information under its control, we will take reasonable steps to contain, investigate, assess, and respond to the breach.

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Where required by law, Ecotone will notify affected individuals, regulators, insurers, administrators, or other appropriate parties.

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Ecotone maintains records of privacy incidents and breach assessments as required by applicable privacy laws.

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Retention of Personal Information

Ecotone keeps personal information only as long as reasonably necessary for the purposes for which it was collected, or as required for legal, regulatory, tax, insurance, claims, audit, contractual, or business recordkeeping purposes.

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When personal information is no longer required, Ecotone will securely delete, anonymize, or dispose of it using reasonable methods.

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Accuracy of Information

Ecotone makes reasonable efforts to keep personal information accurate, complete, and up to date for the purposes for which it is used.

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You are responsible for advising Ecotone of changes to your contact information, eligibility status, dependents, address, payment details, or other information that may affect your coverage or communications.

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Access and Correction

You may request access to your personal information or ask us to correct inaccurate or incomplete information.

Requests must be made in writing to Ecotone’s Privacy Compliance Officer. We may require proof of identity before releasing or correcting information.

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Ecotone will respond to access and correction requests within 30 days, unless an extension is permitted by law.

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In some cases, access may be limited or denied where permitted or required by law, including where the information contains references to another individual, is subject to legal privilege, relates to an investigation, or cannot be disclosed for legal, security, or commercial reasons.

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Marketing Communications

Ecotone may send newsletters, plan education, renewal reminders, service updates, and marketing communications to individuals who have requested information, applied for coverage, become clients, joined a plan, or otherwise provided consent where required.

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You may unsubscribe from marketing emails at any time using the unsubscribe link or by contacting us directly.

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Please note that even if you unsubscribe from marketing communications, Ecotone may still send necessary service, renewal, billing, claims, administrative, or legal communications related to your coverage or account.

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Website Data, Analytics, and Cookies

Ecotone websites may use cookies, analytics tools, pixels, tags, and similar technologies to improve navigation, measure engagement, understand website traffic, assess marketing performance, and improve user experience.

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This information may include browser type, device type, pages visited, time spent on pages, referral source, approximate location, and interactions with website content.

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You may manage or disable cookies through your browser settings. Some website features may not function properly if cookies are disabled.

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Continued use of Ecotone websites indicates consent to these practices, where permitted by law.