Privacy Policy

1. Introduction and Definitions

This Privacy Policy (the "Privacy Policy") constitutes an agreement between you — or, if you are under the age of majority in your local jurisdiction, your parent or legal guardian ("you" or "your") — as a person making use of our platform, software, and services under the "Blair AI" name, operated by Inference Research Inc. and its sub-contractors and subsidiaries (collectively, "Blair AI," "Inference Research Inc.," "us," "our," or "we").

Blair AI is dedicated to protecting your privacy rights. This Privacy Policy describes how Blair AI collects, protects, uses, and discloses Personal Information and data created in the course of your access to and use of the Site, Content, and/or Services (each as defined below).

Please note that this Privacy Policy distinguishes between information collected through the Site, Content and/or Services from you as a Customer of Blair AI and information collected in the course of your organization's use of our scheduling and staffing services. When interacting directly with Blair AI through our Site and related functions and services, you are considered a direct Customer of Blair AI, and we are accountable to applicable provincial and federal commercial privacy laws for protecting any Personal Information you may provide as a Customer.

If you have any questions or concerns after reading this, please email us at: care@helloblair.com

Definitions

For the purposes of this Privacy Policy:

(a) "Content"

means any expression fixed in a tangible medium and includes, without limitation, ideas, text, comments, voice communications, scheduling data, caregiver information, shift details, images, graphics, designs, logos, trademarks, copyrights, information, data, software, scripts, and any intellectual property therein, any of which may be created, submitted, or otherwise made accessible on or through the Site and/or Services.

(b) "Minor"

means a person under the age of majority in the jurisdiction where the home care agency is located.

(c) "Services"

means all services made available by or through Blair AI, including but not limited to scheduling, automated caregiver communications, shift management, and related administrative services accessed through the Content or the Site.

(d) "Site"

means helloblair.com, its related webpages and sites (including, without limitation, any mobile optimization website and white-labelled/DNS-forwarded sites), and Blair AI's mobile applications.

(e) "User Generated Content" or "UGC"

means any Content whatsoever that you submit, create, upload, transfer, or otherwise make available by access to the Site or through the Services, including but not limited to scheduling preferences, caregiver availability, shift requirements, messages, information, data, or other Content posted in any area through our Site or Services.

2. Acceptance of Terms and Revisions

By accessing the Site, submitting information to us (regardless of whether you register an account with us) or downloading, installing or using any of the Content or Services, you consent to become a Customer of Blair AI and consent to the collection and use of your Personal Information by Blair AI in accordance with this Privacy Policy. If you do not accept this Privacy Policy, you must not submit information to or register an account with us, access the Site or download, install or use any of the Content or Services.

We reserve the right to revise this Privacy Policy at any time. We will give you notice of such revisions by posting the revised Privacy Policy at helloblair.com/privacy. It is your responsibility to ensure that you are aware of the current Privacy Policy when you access or use the Site and/or Services. If you continue to access or use any of the Site and/or Services after any revisions to this Privacy Policy are posted, you will be deemed to have accepted those revisions.

3. Types of Information We Collect

There are two types of information we may collect from you as our Customer through your access to and use of the Site, Content and/or Services:

(a) Personal Information

"Personal Information" means information about an identifiable individual, including any "Personal Information" as such term is defined in the Personal Information Protection and Electronic Documents Act (Canada), where Personal Information crosses provincial or international boundaries, or as may be defined in any applicable provincial privacy laws, such as the Personal Information Protection Act (British Columbia and Alberta) and the Act Respecting the Protection of Personal Information in the Private Sector (Quebec). In the context of Blair AI's services, Personal Information may include, but is not limited to, a caregiver's name, email address, phone number, availability schedule, certifications, work preferences, and employment status. For agency administrators, it may include name, email address, phone number, and role within the organization. Please note that this list is provided as an example only and is not an exhaustive list of all information collected or held by Blair AI.

(b) Non-Personal Information

"Non-Personal Information" means information that does not identify you. One common source of Non-Personal Information is business activity or transaction data and statistics resulting from the accumulation of that data, such as shift fill rates, response times, and aggregate scheduling patterns. Another source can be Personal Information that has been de-identified to yield more generalized Non-Personal Information such as availability patterns, certification types, and geographic service areas, which can be aggregated and used for statistical and related purposes such as usage pattern recognition, system optimization, and troubleshooting. Identifying information of any type about Customers must be de-identified by Blair AI before it falls under this definition.

The choice to provide us with Personal Information and Non-Personal Information is yours as our Customer. If you do not wish to have Blair AI collect your Personal Information through the use of our Site, Content and/or Services, you can choose not to provide it. However, your decision to withhold particular details may limit the Services we are able to provide. At all times, it remains your decision whether to provide or withhold your information.

4. Application of This Privacy Policy

This Privacy Policy only applies to the information that Blair AI collects and uses or that is supplied by Customers through the access to and use of the Site, Content, and/or Services. Blair AI is not responsible for the actions of any third parties, the content of their websites, the use of information you provide to them or any products or services they may offer. Any information you disclose to a third party is dealt with in accordance with the privacy policies adopted by each of those third parties.

The Site, Content and/or Services may contain links to third-party websites (the "Linked Sites") that are not controlled or operated by Blair AI. Linked Sites are offered solely for your convenience and do not constitute our sponsorship or endorsement of, or affiliation with those third parties. Blair AI is not responsible for any information disclosed to or collected by those Linked Sites or for the privacy practices of any operators or sponsors of the Linked Sites.

5. Consent — Personal Information

By submitting Personal Information to Blair AI as a Customer, you agree that we may collect your Personal Information, and you consent to the use, disclosure, and transfer of your Personal Information in accordance with this Privacy Policy and as permitted or required by law.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to the collection, use, disclosure, and transfer of your Personal Information for certain of the purposes identified herein at any time by contacting Blair AI through the contact details provided below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain Services.

6. Collection of Information

We may collect information as follows:

(a) Information You Provide to Us.

When you engage in receiving a Service of any type from us as our Customer that requires the submission of information, we may collect the minimum information necessary in compliance with this Privacy Policy to deliver the requested Service. This information is necessary for actions such as verifying your identity, fulfilling your requests, contacting you concerning the Service you requested, and protecting the privacy and security of your information as our Customer.

(b) In-Media Communications.

If you choose to send a message to us through our message, chat, post or other function, we may collect any information you may disclose through such means in order to facilitate the communication.

(c) Your Location.

As our Customer, we may collect precise or approximate geolocation information as part of providing requested Services to you that may require that location information for Service delivery. This information is not stored or used for any other purpose and is collected only when you specifically enable this feature. Users can disable the collection of precise geolocation information at any time. Any geolocation information collected in the course of delivering a Service is securely deleted immediately after being used for this purpose.

(d) Information You Submit to Us.

If you choose to submit Personal Information to us for any other reason or in any other form, we will collect such information and use it for the purposes for which you submitted it.

(e) Visiting our Site.

We will not collect any Personal Information from you simply by virtue of your visiting our Site; we only collect Personal Information if you choose to submit it to us. We do, however, collect Non-Personal Information, such as Usage Data, for purposes of connection management and platform improvement whenever you use our Site and/or Services.

(f) Where Permitted by Law.

We may also collect information, including Personal Information, as otherwise permitted by law.

(g) Do Not Track (DNT).

Do Not Track (DNT) is a privacy preference that you can set in your web browser allowing you to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals, and, therefore, Blair AI does not currently recognize DNT.

(i) Third Party Advertising Partners.

Blair AI is not engaged with any third-party advertising partners at this time and does not in any way collect Customer Personal Information for such activities.

7. Use of Your Information

As a Customer of Blair AI, we may use your Personal Information to deliver, support, and secure the Services, specifically for the following purposes:

• (a) To operate, provide, and deliver the Services you have requested, including managing your account and fulfilling requests you make through the platform.
• (b) To improve our Site and/or Services and to inform the creation of future Services.
• (c) To send you information related to our Site and/or Services, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
• (d) To process transactions for the Services.
• (e) To manage your account with Blair AI.
• (f) To track your access to and use of our Site and/or Services to help us learn more about your preferences so that we can personalize your experience and otherwise enhance your experience when using our Site and/or Services.
• (g) To match caregivers with appropriate shifts based on qualifications, availability, and preferences.
• (h) To respond to customer service inquiries and provide support.
• (i) To troubleshoot problems with the Site and/or Services.
• (j) To enforce our Terms of Use.
• (k) To protect against unlawful activities or other misuse of the Site, Content and/or Services or for other security reasons.
• (l) To compile statistics.
• (m) To send you push notifications (if you choose to allow that function).
• (n) For any other purpose to which you consent or that is otherwise permitted or required by law.

8. Automated Processing of Your Information

In providing our Services, our platform makes use of automated systems to analyze information and generate outputs in support of scheduling, communications, and related functions. This section describes how that processing works and the rights you have in relation to it.

(a) How Automated Processing Works.

Our platform processes information you and your organization provide — including caregiver availability, certifications, preferences, and shift requirements — to generate scheduling recommendations and facilitate communications in connection with your use of the Services. This processing occurs in real time and is designed to optimize outcomes for your organization.

(b) Use of De-Identified Information for Service Improvement.

We may use de-identified or aggregated data derived from platform activity to improve the accuracy and effectiveness of our Services, including the optimization of scheduling recommendations and communications. This de-identified data cannot be used to identify you individually. You may opt out of having your de-identified data used for this purpose at any time by contacting us at care@helloblair.com.

(c) Your Rights Regarding Automated Processing.

Where our platform generates a recommendation or output that significantly affects you or your caregivers, you have the right to: (i) request information about the factors considered in generating that output; (ii) request that a qualified member of our team review the output; and (iii) withdraw your consent to the use of your information for service improvement purposes at any time, without affecting your continued access to the Services. To exercise any of the rights set out in this section, please contact us at care@helloblair.com.

9. Notifications

If you have provided your email address or cell phone number and provided consent to receive notifications under Canadian Anti-Spam Law (CASL), we may occasionally send you as a Customer important information regarding your Service. If you no longer wish to receive notifications, you may unsubscribe at any time by following the instructions in any notification we send, or by contacting us at care@helloblair.com.

10. Disclosure of Information

For Customers of Blair AI, we will not transfer your Personal Information to third parties, except for our subsidiaries, sub-contractors and business partners that we engage to provide services on our behalf, such as (but not limited to) cloud hosting and data storage providers, communication service providers for voice and text messaging, analytics and monitoring services, and payment processing services. Information will only be shared provided that such third parties have agreed to comply with legally required privacy standards, and they agree to use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose. We will only provide those third parties with the minimum Personal Information that they need to deliver the Services you requested.

Notwithstanding the foregoing, we reserve the right to disclose information, including Personal Information of our Customers, if we reasonably believe that we are required to do so by law or legal process or if we are otherwise requested by any law enforcement officer or agency acting under colour of law. In addition, we reserve the right to disclose Personal Information and Non-Personal Information of our Customers in order to: (a) enforce the Terms of Use; (b) investigate and/or take action against unlawful activity, suspected abuse or unauthorized use of the Site and Services; (c) protect and defend the rights or property of Blair AI; or (d) act in urgent circumstances to protect your safety or the safety of the public.

Subject to applicable privacy laws, we may also disclose information (including Personal Information of our Customers) in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets as allowed by Canadian federal and provincial commercial privacy legislation. If we do carry out such a disclosure, as required by applicable legislation we will notify you that such a transaction has taken place and that your Personal Information has been disclosed.

We may also share aggregate or anonymized information, including de-identified Personal Information, about our Customers with service providers, business partners, and other third parties to the extent permitted by applicable law.

SMS Communications: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information will not be shared except as required by law or for message delivery.

11. Protection of Your Information

As required by applicable privacy laws, Blair AI has implemented reasonable administrative, physical, and technical measures including encryption, access controls, and system audit logs to protect the information we collect or are provided with from unauthorized access and from loss, misuse or alteration by third parties. We use industry-standard security practices to protect scheduling data and caregiver information. While we attempt to ensure the integrity and security of our network and systems, no method of transmission over the Internet or electronic storage is 100% secure. As such, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining access to this information.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE EXPRESSLY DISCLAIM ANY GUARANTEE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION.

For further information on how we safeguard information we collect, contact us via email at care@helloblair.com.

12. Data Breach Notification

In the event of a privacy breach involving Personal Information, Blair AI will take the following steps:

• (a) We will notify affected individuals without unreasonable delay where the breach creates a real risk of significant harm to those individuals, as required under applicable privacy legislation including the Breach of Security Safeguards Regulations under the Personal Information Protection and Electronic Documents Act (Canada).
• (b) We will report breaches to the Office of the Privacy Commissioner of Canada and relevant provincial privacy commissioners as required by applicable law.
• (c) We will notify affected home care agencies and organizations using our Services as soon as practicable following discovery of any breach that involves their data.
• (d) We will maintain records of all privacy breaches and the remedial actions taken in response.
• (e) We will provide clear guidance to affected individuals on steps they can take to protect themselves.

Any notification we issue in connection with a breach will include: the nature of the breach, the type of Personal Information involved, the steps we have taken to address the breach, and contact information for further inquiries. To report a suspected breach or for inquiries regarding a breach notification you have received, please contact us at care@helloblair.com.

13. Retention of Your Information

Blair AI retains Personal Information for as long as necessary to: provide our scheduling and staffing services; comply with legal and regulatory requirements; resolve disputes and enforce agreements; and maintain business records for analysis and audit purposes. Scheduling data and caregiver information is typically retained for the duration of the service agreement plus a reasonable period thereafter. We will securely delete or anonymize Personal Information when it is no longer needed for these purposes.

Blair AI or our third-party service providers retain and store information in the cloud and on secure servers primarily located in Canada. Some of our third-party service providers may retain and store limited contact information outside of Canada for services such as communications that you have requested or accessed. Under the laws of those other jurisdictions, in certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities may be entitled to access this information. You will be made aware of when and what information may be shared outside of Canada and will have the option to not engage in services that require such sharing.

14. Account Security

If you as our Customer access our Site and/or use any of our Services, you are responsible for protecting the confidentiality of your account password and account information, and for restricting access to your computer, device or media system platform, and you agree to accept responsibility for all activities that occur under your account. Please notify us immediately at care@helloblair.com if you detect a suspected breach or misuse of your account.

15. Your Privacy Rights

As a Customer of Blair AI, you have the following rights in relation to your Personal Information, subject to applicable law and any legal or contractual obligations that may apply:

• (a) Access. You have the right to request access to the Personal Information we hold about you and to receive information about how that information is being used.
• (b) Correction. You have the right to request correction of any Personal Information we hold about you that is inaccurate or incomplete.
• (c) Withdrawal of Consent. You have the right to withdraw your consent to the collection, use, or disclosure of your Personal Information for certain purposes at any time, subject to legal and contractual obligations. Withdrawal of consent may affect our ability to provide certain Services to you.
• (d) Deletion. Where permitted by applicable law, you have the right to request deletion of your Personal Information. We will honor such requests to the extent we are not required to retain the information by law or for legitimate business purposes.
• (e) Complaint. You have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner if you believe we have failed to handle your Personal Information in accordance with applicable privacy law.
• (f) International Transfers. You have the right to receive information about any transfer of your Personal Information outside of Canada and the safeguards in place in connection with such transfers.
• (g) Automated Processing. You have the right to request information about how our platform's automated systems processed your information in connection with any output that significantly affected you, and to request that a qualified member of our team review any such output.

Response Timelines

We will respond to privacy requests within thirty (30) days of receipt. Where a request is complex or where we have received a high volume of requests, we may extend this period by an additional thirty (30) days. We will notify you in writing if an extension is required.

Exercising Your Rights

To exercise any of the rights described in this section, please contact us at care@helloblair.com with sufficient information to verify your identity and a description of your specific request.

16. Our Policy Regarding Children

Blair AI recognizes the privacy interest of children, and our Site, Content and/or Services are not intended for children under the age of majority in your jurisdiction, and we do not target our Site, Content and/or Services to children under the age of majority. Blair AI does not knowingly collect or use any Personal Information from children under the age of majority. If a parent or guardian becomes aware that their child has provided us with information without their consent, please contact us at care@helloblair.com. We will delete such information from our files within a reasonable time.

17. International Data Transfers

Blair AI primarily operates in Canada and stores data in Canadian data centers. If we need to transfer Personal Information outside of Canada, we will ensure appropriate safeguards are in place to protect your information in accordance with Canadian privacy laws, including contractual protections consistent with applicable legislation and, where required, obtaining your consent. You have the right to request information about any such transfer and the protections in place, by contacting us at care@helloblair.com.

18. Governing Law

Those who choose to use or access the Site and/or Services from outside Canada do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. This Privacy Policy is governed and interpreted pursuant to the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to principles of conflicts of law that would impose the law of another jurisdiction, and you accept and submit to the exclusive jurisdiction of the courts located within the Province of Ontario.

19. Questions or Comments

We welcome questions or comments about this Privacy Policy. Please direct any questions or comments to the individual below who oversees Blair AI's compliance with privacy requirements: