Privacy Policy

Comfort Keeper’s Canadian Privacy Policy

Last Updated: June 29, 2026

PURPOSE OF THIS POLICY

KanKare Home Services Inc., d.b.a ‘Comfort Keepers Canada’, takes the protection of your personal information very seriously. We will only collect, use or disclose your personal information in accordance with this policy unless otherwise required or permitted by applicable law.

We, our franchisees and the healthcare providers who provide services to you understand the responsibility that comes with collecting, using, retaining and sharing your personal information, including personal health information, and are committed to protecting your privacy.

This policy describes:

• How personal information, including personal health information, is collected, used, stored, and disclosed by Comfort Keepers and our franchisees.
• The types of information we collect from you or that you may provide when you interact with us and our franchisees, including when you interact with in person, on the phone, in writing or via social media
• The information we share with our franchisees and vice versa.
• Our overall privacy practices relating to personal information that is under our or our franchisees’ control.

This policy applies to individuals that:

• access or use our Website; and
• otherwise interact with us or our franchisees (e.g., in-person, on social media, through email or via the phone).

This notice should be read in conjunction with any other privacy statements and forms when you sign up for our services. For example, when you sign any consent forms for specialized services.

DEFINITIONS

“personal information” means any information about an identifiable individual.

“personal health information” or “PHI” means any “identifying information” regarding an individual’s health status or health care history.

“us” or “our” Comfort Keepers Canada and its affiliates and subsidiaries (hereinafter designated collectively as “Comfort Keepers”) for all dimensions and activities.

“you” any website or application user/visitor.

“Website” means either (1) the website where this privacy policy appears at the footer or (2) the application where this policy is linked.

COLLECTION AND SOURCE OF PERSONAL INFORMATION

Generally, we or our franchisees collect personal information directly from you. For example, we collect your personal information when you complete and submit a form to us, attend a consultation or an appointment, request services from us, or otherwise communicate with us.

In other circumstances where personal information that we collect about you is held by a third party such as someone in your circle of care or a third party service provider, e.g., we will obtain your permission before we collect this information from the third party (such permission may be given directly by you or implied by your actions). For example, if you undergo a laboratory test (e.g., blood test) at our request, you consent to our collection and use of the test results to assist us with providing you with treatment and other services that you request from us.

In addition to as outlined in this policy, you will in any event be informed of the purposes for which your data are collected via the various online data collection or consent forms and via the Cookie Policy.

TECH SOLUTIONS

We use various technology-enabled camera, audio, and biometric monitoring solutions operated by third-party service providers to support the health and safety of patients (“Tech Solutions”). These Tech Solutions may be available under our Comfort Keepers brand but are owned and operated by independent third-party vendors.

The Tech Solutions may include devices and sensors that are installed in patients’ residences that capture and analyze environmental, audio, visual, and other biometric data. Using artificial intelligence and other technology, the Tech Solutions evaluate this information to detect certain events, patterns, or potential risks and to generate alerts, summaries, or insights that support patient health monitoring, clinical assessment, care planning, and treatment.

Data collected via the Tech Solutions is transmitted directly to and processed by the applicable third-party service provider. We do not independently store or maintain the underlying monitoring data (such as continuous audio, video, or sensor data) on our own systems. The collection of data by these third-party providers is governed by their own privacy policies.

SOCIAL NETWORKS

You have the option to click on the dedicated icons of social networks such as Twitter, Facebook, Linkedin, etc. that appear on our Website. Clicking on those links or enabling those connections may allow the social network to collect or share data about you. We do not control these third-party websites and we encourage you to read the privacy notice of every website you visit.

Social networks create a friendlier atmosphere on the Website and assist in promoting the Website via sharing. Video sharing services enrich the video content of the Website and increase its visibility.

When you click on these buttons, we may have access to the personal information that you have made public and accessible via your profiles on the social networks in question. We neither create nor use any separate databases from these social networks based on the personal information that you have published there, and we do not process any data relating to your private life through these means.

If you do not want us to have access to your personal information published in the public spaces of your profile or your social accounts, then you should use the procedures provided by the social networks in question to limit access to this information.

TYPES OF PERSONAL INFORMATION COLLECTED AND USED BY US

We or our franchisees may specifically collect and process the following types of personal information:

• Registration and contact information you provide when you create an account (such as your name, phone number, home address, email address, date of birth)
• Information that you provide for authentication purposes (such as government issues photo-ID);
• Emergency contact information;
• Information that you provide when filling in the forms on the Website (for example, for subscription purposes, to participate in surveys, for marketing purposes, etc.);
• Transaction information you provide when you request information or purchase a product or service from us, such as your postal address, telephone number, and payment information (such as payment card information and banking account information);
• Usage, viewing, technical, and device data when you visit our Website, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, search queries, and IP address;
• Information that you provide for order fulfillment or to provide a service;
• Records and copies of your correspondence (including email addresses), if you contact us; and
• Information from “posts”, comments or other content that you post on the Website.

In addition, depending on the services you ask us to provide you with, either via the Website or in-person, may collect the following types of personal health information:

• Health and medical information (including diagnoses, treatment history, prescriptions, allergies);
• Biographical and family health history related information; and
• Records of visits by Comfort Keepers and the care you received through them or other healthcare providers. For instance, geolocation data is collected from the caregiver each time they clock in and out of a shift. This means, in some cases, your geolocation data may be inferred through this data.

Personal information identified by an asterisk in data collection forms are compulsory as these are necessary to fulfill any orders placed. In the absence of this compulsory information, these transactions cannot be processed.

PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

We or our franchisees use your personal information for the following purposes:

• To operate, administer and improve the Website;
• To deliver the services or carry out the transactions you have requested or purchased;
• To improve our services. For instance we use your personal information to develop a personalized Plan of Care for each of our clients;
• To provide you with more effective customer service,
• To perform research and analysis aimed at improving our products, services and technologies. However, we only use aggregate data to inform our research and analysis for these purposes;
• To satisfy our legitimate business interests and operate our business (including performing trend analysis and market studies, set prices, accomplish the billing function),
• To display content and advertising that are customized to your interests and preferences,
• To comply with government regulations. We use your personal information specifically for the following purposes:
• To present our Website and its contents to you;
• To provide you with appointments reminders;
• To respond to your requests such as requests for information, searches, the newsletter or other content;
• To provide the services and offers ordered on our Website and/or in one of our establishments;
• To conduct surveys and gather statistics;
• To personalize and enhance your experience on our Website;
• To notify you when Website updates are available, and of changes to any products or services we offer or provide though it.
• To offer you our products and services and/or our partners’ products and services; and
• For investigations and disciplinary proceedings;
• To protect us against error, fraud, theft, and damage to our services, business, and property;
• To meet legal and regulatory requirements; and
• Any other reasonable purpose to which we may notify you of, or to which you consent.

Additionally, we and our franchisees shall use your PHI to provide and coordinate healthcare services, communicate with you about your care, and manage administrative and operational functions. This includes scheduling appointments, maintaining medical records, processing billing and insurance claims, and ensuring quality and safety in service delivery.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information and other information in the manner and for the purposes that are described in the sections below.

• We may share your personal information with entities and affiliates within the Comfort Keepers group.
• Franchisees collect, use and retain your personal information but may share this information with us for business and legal purposes in keeping with our contractual arrangements.
• As part of our regular reporting, compliance, and corporate governance functions.
• In accordance with applicable law, to 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 Comfort Keepers’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Comfort Keepers about our customers and users is among the assets transferred.
• We share personal information with authorized service providers (for example: technical service providers hosting, maintenance, consultants, etc.) whom we may call upon for the purpose of providing our services. We do not authorize our service providers to use or disclose your data, except to the extent necessary to deliver the services on our behalf or to comply with legal obligations.
• We may disclose your PHI for treatment purposes, including for the activities of a physician or other healthcare provider providing treatment to you. For example, your PHI may be provided to a physician who is treating you to assist with referral or diagnosis.
• We may use and disclose your PHI in connection with operating our business. These operating activities may include quality assessment and improvement activities, reviewing the competence or qualifications of healthcare professionals, evaluating provider performance, conducting training programs, accreditation, certification or licensing activities. For example, Comfort Keepers may contact you to remind you of your scheduled visit by our Comfort Keepers office. Your PHI will be used and disclosed.
• We may use or disclose PHI, including identifying or locating, to notify, or assist in the notification of a family member, your personal representative or another person responsible for your care, of your location, your general condition, or death. If you are present, then prior to use or disclosure of your PHI, we will provide you with an opportunity to object to such use or disclosures. In the event of your incapacity or emergency circumstances we will disclose PHI based on a determination using our professional and reasonable judgment and only disclosing PHI that is directly relevant to the person’s involvement in your healthcare. We will also use our professional judgment and our experience with common practice to make reasonable inferences of your best interest in allowing a person to pick up filled prescriptions, medical supplies and other similar forms of PHI.
• We may disclose your PHI to a family member, friend or other person that is involved in your care, who assists in taking care of you assists with payment for your healthcare, but only if you agree that we may do so.
• We may disclose your PHI to appropriate authorities if we reasonably believe that you are a possible victim of abuse, neglect, or domestic violence or the possible victim of other crimes. This information may be disclosed to the extent necessary to avert a serious threat to the health or safety of you or others.
• We may use or disclose your PHI to a coroner or medical examiner to identify a deceased person and determine the cause of death, as well as, to funeral directors, as authorized by law, so that they may carry out their jobs.
• We may disclose PHI to organizations involved in organ and tissue donation and transplant.
• We may disclose your PHI to researchers when an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your PHI has approved their research.
• To fulfill the purpose for which you provide it or authorize us to use it.

Furthermore, we may share personal information concerning you (i) if the law or a legal procedure requires us to do so, (ii) in response to a request by public authorities or other officials  (iii) if we are of the opinion that transferring these data is necessary or appropriate to prevent any physical harm or financial loss or in respect of an investigation concerning a suspected or proven unlawful activity; or (iv) to enforce or apply our agreements with you.

DE-IDENTIFIED, AGGREGATE OR ANONYMIZED INFORMATION

We may also de-identify, aggregate or anonymize information to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Such information may also be shared with: (a) our affiliates and business partners to understand and improve Comfort Keeper’s and the Website’s performance and to develop better websites or applications in the future; (b) for legitimate business purposes; and (c) third parties for other analytical purposes. At no time will such information personally identify, or be used to identify, any individual.

POSTING ON OUR WEBSITE

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

CONSENT

Comfort Keepers only collects, uses or discloses personal information by lawful means, including with your consent for the purposes identified (in this policy or at the time of collection) or otherwise as permitted or required by applicable law.

Where applicable, Comfort Keepers may obtain your permission based on implied/deemed consent (including through this policy) or through other means (such as express consent), depending on the circumstances and the type of information collected. However, in some situations, the law allows us to collect, use or disclose personal information without your consent.

You can withdraw your consent to the collection, use or disclosure of your information that is under our control at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.

You may withdraw your consent to the collection, use or disclosure of your or your child’s personal information at any time by contacting the Privacy Officer (see ‘Contact Information’ below) and, subject to any legal constraints, we will comply with your request. Note, where another party, such as your Health Information Custodian, is the controller of such information, we may direct you to them in those circumstances.

RETENTION

We will store your data only for as long as necessary to fulfill the purposes for which it was collected and processed. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

CHILDREN

The Website is for use by adult persons who have the capacity to conclude a contract under the legislation of the country in which they are located.

This Website is not directed towards children under 16 years of age. No one under age 16 may provide any information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features/register on the Website, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@corp.comfortkeepers.com.

TRANSFER OF PERSONAL INFORMATION

As Comfort Keepers is an international group, your personal information may be transmitted to internal or external recipients that are authorized to perform services on our behalf and that are located in countries outside the country where data was collected (such as in the United States or Canada). While your personal information is outside of Canada, it is subject to the laws of the country in which it is located.  In the event that personal information is transferred internationally, the government, courts, law enforcement or regulatory agencies of the transferred to jurisdiction may be able to obtain disclosure of the data through the laws of that jurisdiction. If you would like to learn more about how your personal information is transferred or about the service providers we use and how they process your personal information, including PHI, please contact us at privacy@corp.comfortkeepers.com.

OPTING OUT OF COMMUNICATIONS

If you no longer want to receive marketing-related emails or SMS messages from us, you may opt-out of receiving emails by clicking the “unsubscribe” link at the bottom of any email you receive from us or replying STOP to any SMS message you may receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.

Please note that if you opt-out from receiving marketing-related emails and messages, we may still need to send you communications about your use of our products or services, or other matters.

YOUR DATA SUBJECT RIGHTS

You can ask to access or correct the personal information that we have about you. If you want to review, verify, delete or correct your personal information, please contact our Privacy Officer (see ‘Contact Information’ below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by emailing it to you).

If you believe that personal information, we hold about you is incorrect, incomplete, or inaccurate, then you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it, together with your requested amendment. If we correct your personal information, we will, so far as is reasonably practicable, inform every other person to whom we have disclosed that information of the correction.

We may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by emailing it to you). If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are situations where applicable law allows or requires us to refuse to provide some or all of the personal information that we hold about you. For example, in some cases the information you request access to may contain details about other individuals, or there may be legal, security, or commercial proprietary reasons why information is withheld. In addition, your personal information may have been destroyed, erased, or made anonymous in accordance with our record retention practices. In the event that we cannot grant your data subject request, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

SECURITY

The security and confidentiality of your personal information are of great importance to us. We implement reasonable technical and organizational security measures to ensure security and confidentiality in processing your personal information.

To this end, we take all necessary precautions given the nature of the personal information and the risks related to its processing, in order to maintain data security and in particular to prevent distortion, damage or unauthorized third-party access (physical protection of the premises, authentication procedures with personal, secured access via identifiers and confidential passwords, a connection log, encryption of certain data, etc.). we restrict access to your personal information only to members of our staff who need to have this information in order to process your orders or to provide the requested service. We also request that our third-party service providers use commercially reasonable security measures to protect your information from unauthorized access or use.

However, no method of electronically transmitting or storing data is ever completely secure, and therefore, we cannot guarantee that your information will never be accessed, used, or disclosed in a manner that is inconsistent with this privacy policy.

PERSONAL INFORMATION THAT WE AUTOMATICALLY COLLECT

We collect some information automatically when you visit the Website to personalize and enhance your experience. To learn more or to opt-out of tailored advertising, please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

We collect this information using various methods such as:

Cookies

A “cookie” is a small information file sent to your browser when you visit our Website and stored on your computer. This file contains information such as the domain name, the internet access provider and the operating system as well as the date and time of access by the user. Cookies cannot damage your computer in any way.

Cookies are not used to determine the identity of an individual who visits our Website. Cookies allow us to identify, in particular, your geographic location and the display language in order to improve your online browsing experience. They also enable us to process information about your visit to our website, such as the pages viewed and the searches made, in order to improve our Website content, to follow your areas of interest and offer you more suitable content.

If you do not want to receive cookies from our Website, you can adjust your browser settings accordingly. To manage your choices, each browser has a different configuration. These configurations are described in your browser’s help menu, which will explain how to change the settings to your desired cookies configuration.

We recommend, however, that you do not deactivate our cookies. Keep in mind that if you block, turn off or reject our cookies, some of our webpages will not display correctly or you will no longer be able to use some of the services we offer. In this case, we cannot be held liable for any consequences related to the reduced functionality of our services arising from our inability to store or consult the cookies required for its functioning and which you have declined or deactivated.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Lastly, by clicking on the dedicated icons of social networks such as Twitter, Facebook, Linkedin, etc., if these are displayed on our Website, and if you have agreed that cookies may be downloaded while you are browsing our Website, the social networks in question may also download cookies to your devices (computer, tablet or mobile phone). These types of cookies are downloaded to your device only on condition that you have given your consent by continuing to browse our Website. You can, however, at any time revoke your consent to these social networks downloading these types of cookies.

For more information, please consult our Cookie Policy.

IP addresses

An IP address is a unique identifier used by some electronic devices to identify and communicate with each other on the internet. When you consult our Website, we can use the IP address of the device used by you to connect you to the Website. We use this information to determine the general physical location of the device and to know in which geographical areas visitors are located.

Statistics

Our Website uses Google Analytics, a web analytics service of Google, Inc. (“Google”), or comparable technology. Google Analytics uses “cookies”, which are text files stored on users’ computer, to analyze how they use the website. The information generated by the cookie about use of the websites (including IP address) is sent to a Google server in the U.S. and stored there.   This information is aggregated and logged and used to measure statistical information about usage of the site, including but not limited to the total number of visits, average time spent on the site, and pages viewed, both in real-time, and within a certain historical time frame. We use this aggregated information to measure the use of our site and to improve the content and usage of our site.

Additionally, Google may transfer this information to a third party when required by law or in the case of a third-party processing information on Google’s behalf. In no case will Google use users’ IP address in connection with any other information held by Google. Users can set their internet browser to prohibit the installation of cookies, although some features and functions of the website will then be unusable.

By using the Website, users consent to the processing of user data collected by Google in the manner described and for the above-mentioned purpose. The consent for collection and storage of data can be withdrawn at any time in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

UNSUBSCRIBING

If you have subscribed to certain services via our Website and you no longer want to receive emails, please consult the “unsubscribe” page corresponding to the service you are subscribed to.

LINKS TO OTHER SITES 

Occasionally, we provide links to other websites for practical and informative purposes. These websites are mostly Comfort Keepers websites, however some of them operate independently from our websites and are not under our control. These websites are run by third parties with their own confidentiality recommendations or terms of use which we strongly advise you to read. We do not accept any liability with regard to the content on these sites, for the products and services that may be offered there or for any other use thereof.

CHANGES TO THIS PRIVACY POLICY

We may make changes to this policy from time to time, including amending, updating or supplementing this policy. We will post an updated version of our policy on our Website when we make changes and may also notify you of the changes we have made if we are required to do so by applicable law. Any updated versions of the policy will be effective from the date of posting. You are responsible for checking if any amendments have been made to this privacy policy. Your continued use of our website or our services will constitute your consent to the collection, use, retention and disclosure of your personal information as described in the updated version of the policy.

CONTACT INFORMATION

If you have any questions or comments with regard to this policy, please do not hesitate to contact our Privacy Officer (Comfort Keepers Canada) at:

• Emai: privacyofficer@comfortkeepers.ca.
• Mailing Address: 245 Fairview Mall Drive, Suite 401, Toronto ON.