Privacy Policy

ManagingLife Inc.'s Privacy Policy
Version 2.3, Last Updated: January 15, 2026

ManagingLife, Inc. (“ManagingLife,” “we,” or “us”) wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes how we handle information that we collect through:
- Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
- Software applications, such as the Manage My Pain app, made available by us (the “Apps”);
- Our pages on LinkedIn, Facebook, and X, (collectively, our “Social Media Pages”);
- Emails we send to you that link to this Privacy Policy or other communications with you (collectively, our “Communications”); and
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Apps (including Solace, our generative AI feature), Social Media Pages, Communications, and offline business interactions as the “Services.”
OFFLINE AND ONLINE MODE

You can use our Apps in offline and online mode. In the offline mode, which is the standard setting, your information is stored only on your device, and is not accessed by us. In the offline mode, the Apps allow you to manage your own information on your own device. Certain functionalities of the Apps require that information is shared and are therefore not available in offline mode. This is, for example, the sharing of your pain records with a health care provider of your choice, or generating pain reports. You can switch from offline mode to online mode by creating an account and logging into your Apps account, and back to offline mode by logging out of your Apps account.
PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.

The Apps collect crash reports and usage analytics, both of which can be turned off in the “Settings” menu and include the following Personal Information:
- User ID
- Device information (such as your device’s make and model)
- Usage data (such as Screens visited, features used, interaction patterns, session duration, and clicks)
- App version
When you contact us via any of our Services, we collect the following Personal Information:
- Email address
- User ID
- Device information (such as your device’s make and model)
- App version
If you choose to use the Apps in online mode, we collect Personal Information including:
- Account information (such as, your email address, IP address, and password);
- Profile information you choose to include (such as, name, medications, pain conditions, birthdate, height, weight, gender, and place of residence);
- Pain records and daily reflections you choose to create (which may include information such as, location, associated symptoms, characteristics, aggravating/alleviating factors, timing, environment, severity, meaningful activities, and notes);
- Responses you choose to submit for questionnaires assigned to you; and
- Prompts or other text you enter into Solace or other features of the Services.
Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services.
  We collect Personal Information through the Services, for example, when you register an account to access the Services, use the Apps, share information via the Apps in online mode, contact customer service.
- From Other Sources.
  If you choose to create an account on the Services and sign in by using another service provider such as Apple, Google or Facebook, you share certain Personal Information from that service provider with us, for example, your name, email address, or photo, or other information you make accessible to us when you connect your social media account to your Apps account.
  
  We need to collect Personal Information to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide all the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information

We and our service providers use Personal Information for the following purposes:
- Providing Services and fulfilling your requests.
  - To provide the Services’ functionality to you, such as adding, editing, or viewing your pain records and daily reflections, generating pain reports, processing your Prompts provided to Solace for the purpose of generating Outputs, or sharing your information with another organization such as your healthcare provider after you provide consent to do so
  - To respond to your inquiries and fulfill your requests, when you contact us via one of our online or in-app contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Services.
  - To send administrative information to you, such as changes to our terms, conditions, and policies.
    
    We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Sending you our newsletter and/or other marketing materials.
  - To email you newsletters, with information about our services, company, or partners.
    
    We will engage in this activity with your consent or where we have a legitimate interest.
- Personalizing the Services.
  - To better understand your preferences, so that we can personalize our interactions with you and provide you with information.
    
    We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
- Aggregating and/or anonymizing.
  - We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
    
    We engage in these activities based on our legitimate interest.
- Accomplishing our business purposes.
  - For data analysis, for example, to improve the Services;
  - For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  - For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  - For developing new products and services;
  - For maintaining, or modifying our current Services;
  - For safety, abuse prevention, or troubleshooting purposes;
  - For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
  - For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
    
    We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- App usage data
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:
- Your browser or device.
  - Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Your use of the App.
  - When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. You can turn off anonymous usage reporting in the “Settings” menu of the Apps.
- Cookies.
  - Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
- Pixel tags and other similar technologies.
  - Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
  - Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us by using the unsubscribe option included in each marketing email or by sending an email to privacy@managinglife.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information

If you would like to access, correct, update, or delete information you included in the Apps, you can use the self-service functionality within the Apps.

If you would like to request to access, correct, update, or delete other Personal Information, or suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes.
RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of sixteen (16).
JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including Canada, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). If we transfer Personal Information from the EEA to countries not considered adequate by the European Commission, we will put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us”.
SENSITIVE INFORMATION

The Apps enable you to record pain information, including health related information. If you enter health-related information into Solace or as part of a Prompt, we will process such information in accordance with this Privacy Notice. We ask you not to send us, and you not disclose, other sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us, unless we request you to do so.
THIRD PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
CONTACTING US

ManagingLife, Inc., located at 18 King Street East, Suite 1400, Toronto, Ontario, Canada, M5C 1C4, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at
privacy@managinglife.com, or:
18 King Street East, Suite 1400
Toronto, Ontario,
Canada, M5C 1C4

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION REGARDING THE EEA

You may also:
- Contact our EU representative:
  Rickert Rechtsanwaltsgesellschaft mbH
  - Managinglife -
  Colmantstraße 15
  53115 Bonn
  Germany
  art-27-rep-managinglife@rickert.law
- Contact our Data Protection Officer (DPO) at privacy@managinglife.com.
- Lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

Privacy Policy

OFFLINE AND ONLINE MODE

PERSONAL INFORMATION

OTHER INFORMATION

SECURITY

CHOICES AND ACCESS

RETENTION PERIOD

THIRD PARTY SERVICES

USE OF SERVICES BY MINORS

JURISDICTION AND CROSS-BORDER TRANSFER

SENSITIVE INFORMATION

THIRD PARTY PAYMENT SERVICE

UPDATES TO THIS PRIVACY POLICY

CONTACTING US

ADDITIONAL INFORMATION REGARDING THE EEA