RELIEF CARE INC.

Privacy Policy

Effective Date: June 23, 2026  ·  Last Updated: June 23, 2026

Introduction

Relief Care Inc. (“Relief Care,” “we,” “us,” or “our”) operates an online marketplace and payment infrastructure that connects Care Seekers with Care Givers in Ontario, Canada. This Privacy Policy explains the personal information we collect, how we use and disclose it, and the choices and rights you have. Capitalized terms have the meanings given in our Terms of Use, which is incorporated into this Privacy Policy by reference.

Table of Contents

1. Our Practices and Your Agreement
2. Definitions
3. Compliance with Canadian Privacy Laws
4. Personal Health Information (PHIPA Posture)
5. Information We Collect
6. How We Use Information
7. Use of Information by Other Users
8. Disclosure of Personal Information
9. Cross-Border Data Transfers
10. Data Retention
11. Communication Choices and CASL Consent
12. Cookies, Analytics and Tracking Technologies
13. Automated Decision-Making
14. Access, Correction, Removal, Portability
15. Privacy Rights of Individuals Outside Ontario
16. Children’s Privacy
17. How We Protect Information
18. Privacy Breach Notification
19. Accessibility Statement (AODA)
20. Links to Other Sites
21. Changes to This Policy
22. Contact

1. Our Practices and Your Agreement

By browsing the Site or using the Services, you consent to this Policy. We collect information from you when you use the Services, when you communicate with us, and when others communicate with us about you. We use Personal Information to deliver and improve the Services, enable trust and safety, and comply with our legal obligations.

If you use the Services, you consent to our performing limited verification checks (see Section 5.3). If you do not consent to verification checks, do not use the Services.

2. Definitions

“Care Giver,” “Care Seeker,” “Services,” “Site,” “Registered User” have the meanings given in the Terms of Use.

“Personal Information” means information about an identifiable individual that can be used to contact or identify the individual.

“Personal Health Information” or “PHI” has the meaning given in the Personal Health Information Protection Act, 2004 (Ontario), S.O. 2004, c. 3, Sch. A (“PHIPA”).

“PIPEDA” means the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5.

“CASL” means An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, S.C. 2010, c. 23.

3. Compliance with Canadian Privacy Laws

3.1 PIPEDA

Relief Care complies with the 10 Fair Information Principles in Schedule 1 to PIPEDA: Accountability, Identifying Purposes, Consent, Limiting Collection, Limiting Use, Disclosure and Retention, Accuracy, Safeguards, Openness, Individual Access, and Challenging Compliance.

3.2 Right to Complain to the Office of the Privacy Commissioner of Canada

If you are not satisfied with our response to a privacy concern, you may file a complaint with the Office of the Privacy Commissioner of Canada (“OPC”):

Office of the Privacy Commissioner of Canada

30 Victoria Street, Gatineau, Quebec K1A 1H3

Toll-free: 1-800-282-1376

Website: www.priv.gc.ca

4. Personal Health Information (PHIPA Posture)

4.1 Relief Care’s Position Under PHIPA

Relief Care is NOT a Health Information Custodian. Relief Care does NOT act as an Electronic Service Provider, Health Information Network Provider, or agent for any Health Information Custodian. Personal Health Information is NOT required to use the Services and should NOT be transmitted through the platform.

Relief Care’s PHIPA posture rests on three positions:

(a) No-purpose collection. The platform is designed and operated for marketplace and payment functions. PHI is not necessary for any of those functions, is not collected by design, and is not requested.

(b) Incidental processing only. Despite our prohibitions, users may from time to time include PHI in messages, profile fields, or other content. To the extent any PHI is incidentally transmitted through the Services in violation of the Terms of Use, Relief Care processes such information only as necessary while providing the Services — including identification, removal, platform integrity, and legal compliance. Relief Care does not, by reason of such incidental processing, undertake the role of an Electronic Service Provider or Health Information Network Provider within the meaning of O. Reg. 329/04 s. 6, or of an agent of any Health Information Custodian. Relief Care does not retain PHI after identification beyond what is necessary for investigation or removal, does not use PHI for any secondary purpose, and does not use PHI to train any model.

(c) Non-agent positioning. Where a Care Seeker is a Health Information Custodian (such as a long-term care home, hospital, or clinic), the Care Seeker remains responsible for its own PHIPA obligations and the obligations of its agents. Relief Care does not undertake the role of agent, Electronic Service Provider, or Health Information Network Provider for any such Care Seeker. The Facility Customer Addendum (incorporated into the Terms of Use for institutional Care Seekers) confirms this allocation.

4.2 Prohibition on Transmitting PHI

Care Givers and Care Seekers are strictly prohibited from transmitting PHI through the platform. This includes patient names and identifiers, medical conditions or diagnoses, treatment plans or care notes, medication information, health card numbers, and any other information relating to the physical or mental health of an identifiable individual other than the user themselves (and even then, with caution).

Any PHI that needs to be exchanged in connection with care services must be handled directly between the Care Giver and the patient or client (and any Health Information Custodian involved) outside the platform, in compliance with PHIPA.

4.3 Care Givers Who Are Health Information Custodians

Care Givers who are themselves Health Information Custodians (such as regulated health professionals operating their own practice) remain solely responsible for their own PHIPA compliance obligations, including obtaining patient consents and maintaining records outside the platform.

5. Information We Collect

5.1 Information You Provide

We collect Personal Information you provide when you register, post a job, post a profile, use mobile applications, or communicate with us — including name, email, postal code, town, gender, date of birth, phone number, and (where applicable) payment information and billing address.

5.2 Information Provided by Others

We collect information that you, other users, and third parties provide about each other — for example, when Care Givers are rated or reviewed, when references are provided, and when we receive correspondence about Registered Users.

5.3 Verification Checks

Relief Care may perform limited verification checks. These checks may include identity verification, email and phone verification, professional credential and license validation, regulatory body register lookups (such as the College of Nurses of Ontario public register), Vulnerable Sector Check status confirmation, and reference checks.

Verification checks are LIMITED and NON-EXHAUSTIVE. Relief Care does not guarantee the accuracy, completeness, or currency of any verification result. Verification checks must not be relied on as a substitute for independent verification by the Care Seeker.

5.4 Technical and Usage Information

We receive IP address, device information, operating system, browser type, mobile carrier information, and the URLs you came from and go to.

5.5 Location Information

Our mobile application may, with your consent, collect location information for matching, shift verification, and safety features. You can disable location sharing in your device settings; doing so may limit certain Services.

5.6 Tax Information (Care Givers)

Where required by applicable law — including the reporting rules for digital platform operators in Part XX of the Income Tax Act (Canada) — we collect from Care Givers the information required for tax reporting. This may include legal name, primary address, date of birth, and tax identification information such as a Social Insurance Number or business number, and a GST/HST registration number where applicable. We report required information, including amounts paid to Care Givers through the Services, to the Canada Revenue Agency annually, and we provide each affected Care Giver with a copy of the information reported about them. Tax identification information, where collected, is gathered only through a dedicated secure flow (which may be operated by our payment processor) — never through chat, job postings, profiles, or support messages — is encrypted at rest where technically feasible, is access-restricted to authorized personnel, is never displayed to other users or in general support views, and is used and disclosed only for tax compliance purposes. Identity verification for payout accounts is performed by our payment processor under its own terms and privacy policy; information you provide directly to the payment processor for that purpose is not collected by Relief Care.

6. How We Use Information

We use Personal Information to:

• register and service your account;
• include relevant information in Care Seeker job postings and Care Giver profiles;
• respond to inquiries and solicit feedback;
• enable Care Seekers and Care Givers to search and find matches;
• verify information you provide and your suitability to participate;
• send service-related communications;
• process payments through our limited payment collection agency function (see Terms of Use Section 10.1);
• detect, prevent, and respond to fraud, abuse, or misuse;
• operate support, moderation, and safety tooling, which may include artificial intelligence systems provided by third-party service providers under contract; we do not permit these providers to use your Personal Information to train their general-purpose models;
• comply with legal and regulatory obligations (including Income Tax Act Part XX digital platform reporting); and
• conduct research and analytics, in aggregated and de-identified form where practical.

7. Use of Information by Other Users

If you are a Care Seeker or a Care Giver, we share with Site visitors and Registered Users the information you include in a job posting or profile (other than contact information), as well as registration information such as first name, first initial of last name, city, province, and profile picture. Where Care Giver profiles display demographic information (such as gender), any Care Seeker preference based on that information remains subject to Section 4.4 of the Terms of Use.

Reviews of Care Givers are made available to Registered Users. Care Giver phone numbers are visible to certain Registered Users only if the Care Giver elects to share them.

If we terminate your registration, we reserve the right to send notice of termination to other Registered Users with whom we believe you have corresponded.

8. Disclosure of Personal Information

By using the Services, you agree we may disclose your Personal Information:

• to affiliates and service providers acting on our behalf, who are bound to use it only for the purposes for which we engaged them;
• in connection with verification checks (see Section 5.3);
• as required or permitted by PIPEDA or substantially similar provincial legislation, including without consent in emergencies, to comply with subpoenas, warrants, or court orders, in legal proceedings to protect rights, or to law enforcement concerning offences;
• in connection with a merger or sale of all or part of Relief Care or its affiliates; and
• as otherwise described in this Policy.

9. Cross-Border Data Transfers

Your Personal Information may be stored and processed in the United States and other jurisdictions where our service providers operate.

By using the Services, you consent to:

(a) the transfer of your Personal Information to the United States and other jurisdictions;

(b) the storage and processing of your Personal Information in those jurisdictions, subject to the laws of those jurisdictions, which may provide different protections than Canadian law and which may include lawful access by foreign government or law enforcement authorities; and

(c) the use of contractual safeguards rather than additional consent for each onward transfer.

Safeguards we implement include:

• contractual data protection agreements with service providers requiring comparable protection;
• encryption of data in transit and (where technically feasible) at rest;
• access controls limiting who can access Personal Information; and
• regular security assessments of providers.

You may withdraw consent to cross-border transfers by closing your account; doing so will end your access to the Services.

10. Data Retention

We retain Personal Information only as long as reasonably necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to protect platform integrity. Specific retention principles:

Active account information — Retained for the duration of the user relationship.

Account information after closure — Retained for up to 24 months for fraud prevention, dispute resolution, and audit, then deleted or anonymized, except as below.

Booking, transaction and payment records — Retained for a minimum of six (6) years from the end of the last taxation year to which they relate, in compliance with Income Tax Act s. 230(4)(b) and Excise Tax Act s. 286(3). Period extends if there is an outstanding objection or appeal.

Digital platform reporting records (ITA Part XX) — Retained for the period required under Income Tax Act s. 293.

Verification check results — Retained for up to 24 months following the check or account termination, whichever is later.

Communications with support — Retained for up to 24 months.

Marketing consent and unsubscribe records — Retained for the period required by CASL and applicable laws (typically a minimum of three (3) years).

Privacy breach records — Retained for a minimum of 24 months as required by PIPEDA s. 10.3.

Backup copies and security logs — Retained for a reasonable period for security, disaster recovery, and legal compliance.

11. Communication Choices and CASL Consent

11.1 Service-Related Communications (Implied Consent)

By becoming a Registered User, you consent to receive electronic communications necessary to operate the Services — booking confirmations, shift reminders, payment receipts, account security notifications, policy and legal notices, and other transactional messages. You may not opt out of these messages while you remain a Registered User.

11.2 Promotional Communications (Express Consent)

We send commercial electronic messages (newsletters, promotions, marketing) only where you have given express consent in compliance with CASL. You may withdraw consent at any time:

• by clicking the unsubscribe link in any promotional email;
• by adjusting your communication preferences in account settings; or
• by contacting privacy@reliefcare.com.

We will give effect to your withdrawal within 10 business days as required by CASL.

12. Cookies, Analytics and Tracking Technologies

We use cookies, pixels, SDKs and similar tracking technologies in these categories:

Strictly necessary — Required for the Services to function (authentication, security).

Functional — Remember preferences and settings.

Analytics and performance — Help us understand how users interact with the Site, including via Google Analytics. You can opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

Advertising and targeting — If used, deliver advertising. Where required by law, we request consent before placing these cookies.

Where required by law, we present a cookie consent notice. You may also adjust browser settings to refuse cookies. For Google’s privacy practices, see https://policies.google.com/privacy.

13. Automated Decision-Making

We use automated systems to support certain functions of the Services: matching job postings to Care Givers using objective criteria (profession, specialty, service area, and availability); processing payments; detecting fraud, abuse, and misuse; and flagging potential safety risks.

The matching function operates by notification, not ranking. When a Care Seeker posts a job, Care Givers whose profession, specialty, and service area match the posting are notified and may choose whether to apply; the Care Seeker selects from the Care Givers who applied. Relief Care does not use automated systems to rank Care Givers, to score reliability, or to adjust the visibility or matching priority of any Care Giver based on ratings, cancellations, or past performance.

Significant account-level decisions — deactivation, suspension, termination, removal of content, the recording of reliability concerns, and the review of Care Seeker preferences under Section 4.4 of the Terms of Use — are made by humans. You may contact our Privacy Officer to request additional information about how these systems work or to express a concern about an outcome.

14. Access, Correction, Removal, Portability

You may access, change, or remove Personal Information you provided through your account settings. For information not accessible through settings, contact privacy@reliefcare.com. We will respond within 30 days or sooner where required by law.

If you close your account, we will remove your name and other Personal Information from publicly viewable areas, subject to Section 10.

14.1 Limitations on Deletion

• Messages you have sent to other users may remain visible to those users.
• Reviews and ratings (yours or about you) may remain visible.
• Information copied or captured by other users cannot be removed by us.
• Backups and logs may be retained for a reasonable period.
• Third-party search engines and caches are outside our control.

14.2 Data Portability

Where required by applicable law, you may request a copy of the Personal Information you have provided to us in a structured, commonly used and machine-readable format.

15. Privacy Rights of Individuals Outside Ontario

Our Services are offered exclusively in Ontario. Residents of other jurisdictions may have additional privacy rights (Quebec Law 25, GDPR, certain U.S. state laws). Contact our Privacy Officer to discuss rights that may apply to you.

16. Children’s Privacy

Our Services are intended for individuals 18 or older. We do not knowingly collect Personal Information from individuals under 18. If we become aware we have done so, we will take appropriate steps to delete the information.

17. How We Protect Information

We implement administrative, technical, and physical safeguards including:

• TLS/SSL encryption in transit during registration, login, account management, and payment processing;
• Encryption of sensitive information at rest where technically feasible;
• Role-based access controls and the principle of least privilege;
• Logging and monitoring of access to systems containing Personal Information; and
• Periodic security assessments and security awareness training.

18. Privacy Breach Notification

In the event of a breach of security safeguards involving Personal Information:

(a) we investigate the breach and assess the risk of significant harm under PIPEDA s. 10.1;

(b) where there is a real risk of significant harm, we notify the Privacy Commissioner of Canada as soon as feasible;

(c) we notify affected individuals at the first reasonable opportunity, describing the nature of the breach, the types of information involved, the steps we are taking, and steps individuals can take to protect themselves;

(d) we notify any other organizations or government institutions that may be able to reduce the risk of harm; and

(e) we maintain a breach register documenting all privacy breaches for a minimum of 24 months as required by PIPEDA s. 10.3.

19. Accessibility Statement (AODA)

Relief Care strives to provide accessible Services consistent with the Accessibility for Ontarians with Disabilities Act, 2005 and the Integrated Accessibility Standards Regulation (O. Reg. 191/11). We strive to meet WCAG 2.0 Level AA, the standard currently incorporated into the IASR for private sector organizations.

If you require this Policy or other content in an accessible format, or if you have feedback about our accessibility, contact support@reliefcare.com. Our accessibility policy and multi-year plan are available on request.

20. Links to Other Sites

Links to external sites are not endorsements. This Policy applies only to information collected through the Services.

21. Changes to This Policy

We may change this Policy from time to time. We will notify you of significant changes by email or by prominent notice on the Site, with significant changes taking effect 30 days after notice. Non-material changes take effect on posting.

22. Contact

Privacy Officer: Privacy Officer, Relief Care Inc. (designated role, accountable to the founder)Email: privacy@reliefcare.com

Support: support@reliefcare.com

Relief Care Inc.

5171 Yonge Street, 2nd Floor

North York, ON M2N 5P5, Canada