Last revised: April 6 2026
SWORD HEALTH PRIVACY NOTICE
Canada
Sword Health Technologies, Inc. and its affiliates, including Sword Health, Inc. and Sword Health Canada, Ltd. (collectively, “Sword”, “we”, “our” or “us”) recognize the importance of privacy. The purpose of this Privacy Notice is to inform you about our Canadian privacy practices, including how we collect, use, and disclose personal information of users in Canada.
US Users - If you are accessing the Services from the United States, tap or click here.
UK and EU Users - If you are accessing the Services from the United Kingdom or European Union, tap or click here.
Sword offers a variety of health and wellness services through a combination of technology, accessory devices, and specialist support, which are supported by websites, including www.swordhealth.com, and related sites, and the Sword and Mind mobile applications, (collectively, the “Sites”), as well as certain accessory devices and other technology and electronic means, such as video conferencing, chat, phone, and online events (the foregoing, collectively the “Services”).
Through the Services, registered users can access a variety of health and wellness programs for musculoskeletal support, pelvic health support, mental wellbeing, and other health purposes (“Health Services”). Sword does not directly provide Health Services. Health Services are provided by regulated health professionals, including physiotherapists and clinical psychologists, who are licensed to practice in a province or territory in Canada (“Professionals”).
This Privacy Notice applies in respect of personal information that is collected, used or disclosed by Sword in connection with Services, including any records of personal health information that are collected by or on behalf of a Professional in connection with the Health Services (“Health Records”).
What This Privacy Notice Covers
This Privacy Notice covers the following topics:
Personal Information We Collect
“Personal information” means any information that can be used to identify an individual directly (on its own) or indirectly (in combination with other information). Personal information does not generally include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.
We may collect different types of personal information, depending on our relationship with you. Generally, we collect the following types of personal information in the following ways (not all of which may apply to you):
Information You Provide to Us
Sword collects personal information that you provide to us, including when you register for the Services, use the Services, respond to a survey, or contact us. This information may include:
Contact or other identifying information, such as your name, address, email address, telephone number, username, and password;
Professional or employment-related information, such as the name of your employer, company, and other professional or employment information you provide to us;
Mental and physical condition and characteristic information, such as age, height, weight, general health, exercise patterns, personal motivations, information about pregnancies and childbirth, and feelings of anxiety, pain, fatigue or depression;
Medical information, such as current or former injuries, medical diagnoses and whether you are cleared by a physician to exercise; and
Payment information, such as bank account number, credit card number, or debit card number, if applicable.
Information Collected While Using Our Services
Sword may also collect personal information when you access, browse, and use our Services. This information is generated by the computer, tablet, mobile app, devices, or other accessories used in the Services. This information may include:
Internet and other electronic activity data, such as the name of the domain, host and device from which you access the internet; the browser software you use, and your operating system; the date and time you access the service; how often you access the Services, and the internet address of the website from which you directly linked to Sword;
Log and troubleshooting information, such as information about how our Services are performing when you use them, like service-related diagnostic and performance information, including log files, timestamps, diagnostic or crash data, website/app performance logs, and error messages or reports;
Identifiers or geolocation data, such as Internet Protocol (IP) address, device identifier, or geolocation (if enabled);
Sensor data, such as the type and order of exercises, number of repetitions, duration, manner, and individual performance during the assigned exercise;
Wearable sensor data, if you elect to wear our device or use your personal device, which could include sleep and recovery, cardiovascular and respiratory, fitness capacity, body measurement, glucose and metabolic data and the type and duration of movement or exercises;
Data from tracking technologies, such as information from cookies, web beacons, tags, or other tracking technologies, as further described below; and
Video and audio recordings, such as recordings of your sessions with a Professional. Sword will not record video or audio of your sessions with a Professional without obtaining your consent prior to each recording.
Information Collected from Other Sources
In connection with your use of the Services, we may collect personal information from third parties or combine or compare information we have collected from you with information collected from a third party, which may include:
Eligibility Information: If you are participating in a program sponsored by your employer, insurance provider, or healthcare provider, information contained in an eligibility file, such as whether you are enrolled in the plan, your name, email, and some related health information;
Information from Your Health Care Providers: In connection with your treatment, we may collect medical records from your past, current, and future health care providers, including past or present diagnoses, previous treatments, general health, test results and reports, any family history of illness, and records of communications related to your health; and
How We Use Your Personal Information
We generally use your personal information for the following purposes:
To provide you with the Services, including Health Services that are provided by Professionals;
To personalize, improve, update, and expand our Services, including:
For product testing and development, data analysis, and survey purposes;
For training our staff and for quality assessment and improvement; and
For scientific, statistical, and historical research;
To communicate with you about the Services, including:
To respond to your inquiries and concerns or inquire about safety or other concerns;
Provide you with information or request action in response to technical, security, and other operational issues; and
To follow-up with you regarding your enrollment process;
To create de-identified or anonymized information (for example, aggregated statistics related to the use of the Services) in accordance with applicable law;
To comply with laws and regulations, including to respond to law enforcement or government requests as required by applicable law, court order, or governmental regulations and to monitor our compliance with those obligations;
To protect the integrity and maintain the security of our Services;
To enforce our Terms and Conditions; and
For any other purpose for which you may provide consent or as disclosed to you when you provide information to us.
When we use the term “de-identified,” we mean information that is neither used, nor intended to be used, to identify an individual. To the extent permitted by law, we may use de-identified information without restriction and may share it with unaffiliated third parties.
How We Share Your Personal Information
We generally identify to whom, and for what purposes, we will disclose your personal information (and we obtain your consent to such disclosure) at the time we collect your personal information.
Sword may share personal information with the following categories of third parties for the following purposes:
Health Care Providers: If you receive Health Services, we may disclose your personal information to other health care providers to facilitate the provision of your healthcare. This helps to coordinate care and ensure that everyone involved in your healthcare has the right information to meet your healthcare needs.
Employer, Health Plans and Insurers: If you are participating in a program sponsored by your employer, insurance provider, or healthcare provider, we may share limited personal information with them for the purpose of confirming your eligibility for the program or facilitating payment.
Corporate Affiliates: We may share your personal information with our subsidiaries, affiliates, and associated organizations who assist us in providing the Services;
Research Partners: We may share your personal information with research partners with your consent or if otherwise permitted by law. Research partners include commercial or non-profit organizations that conduct or support scientific research, the development of therapeutics, medical devices or related material to treat, diagnose, or predict health conditions. In some circumstances, we or a research partner may have a financial interest in the research arrangement;
Law Enforcement, Government Agencies, Professional Colleges, or Other Third Parties: From time to time, we may be required to provide personal information to a third party in order to comply with a subpoena, court order, government or professional college investigation, or other similar legal process. If we disclose your personal information in this way, we will reasonably attempt to provide you with advance notice, unless we are prohibited from doing so. We may share your personal information if we believe it is reasonably necessary to:
Comply with valid legal process (e.g., subpoenas, warrants, order, lawful requests, etc.);
Respond to a government request;
Enforce or apply our Terms and Conditions;
Investigate fraud;
Protect the security or integrity of the Services;
Protect the rights, property, or safety of Sword, our employees/contractors, members or users; or
Corporate Transaction: If we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of all or a portion of our assets, we may share or transfer your personal information as part of such corporate transaction; and
For such other purposes as you may consent to from time to time, or as otherwise required or permitted by law.
We may rely on service providers to perform a variety of services on our behalf, such as cloud services infrastructure providers; vendors that assist us in marketing and consumer research analytics, fraud prevention, and security; communications infrastructure providers; vendors that help us provide some support functions, like phone support or survey tools; and our business and legal advisors. These third parties are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.
Your Consent
Where required or permitted by law, we may collect, use, and disclose your personal information with your consent. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question. Generally, we will seek your consent at the time we collect your personal information, either orally, electronically, or in writing.
If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their information as described in this Privacy Notice.
If you wish to withdraw your consent to our collection, use or disclosure of your personal information, please contact us using the contact information in the “How to Contact Us” section below. We will accommodate your request to withdraw consent, subject to legal or contractual restrictions. Withdrawal of your consent may mean that we will no longer be able to provide you with certain Services.
Our Use of Tracking Technologies
We may use technologies such as cookies, web beacons or pixels, tags, scripts, and other storage technologies (collectively “Tracking Technologies”) to collect or receive information on the Sites. These Tracking Technologies may help us save your preferences, understand how you navigate through the Sites, and improve your experience.
Cookies and Other Tracking Technologies
Cookies are small data files that we transfer to your device to collect information about your use of the Sites. Cookies can be recognized by the website that downloaded them or other websites that use the same cookies. This helps websites know if your browsing device has visited them before. We may use both first party and third party cookies on our Sites for the following purposes: to make the Sites function properly; to improve the Sites; to track your interaction with the Sites; to enhance your experience with the Sites; to remember information you have already provided; to collect information about your activities over time and across third party websites or other online services in order to deliver content tailored to your interests; and to provide a secure browsing experience during your use of the Sites.
The length of time a cookie will stay on your browsing device depends on whether the cookie is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted. The following types of cookies may be used on the Sites:
Strictly Necessary Cookies. These cookies are essential because they enable you to use the Sites. For example, strictly necessary cookies allow you to access secure areas of the Sites and for us to provide the Sites. These cookies do not gather information about you for marketing purposes. This category of cookies would be essential for the Sites to work and they cannot be disabled.
Functional or Preference Cookies. We may use functional cookies to remember your choices so we can tailor the Sites to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on the Sites. We do not use functional cookies to target you with online marketing. While you may disable these cookies, this may result in less functionality during your use of the Sites.
Performance or Analytic Cookies. These cookies collect passive information about how you use the Sites, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize the Sites. We do not use these cookies to target you with online marketing. You may disable these cookies.
Targeting or Advertising Cookies. These cookies are used to drive online advertising that is relevant to you by building up a picture of what you are interested in from your use of the internet. The cookies can limit the number of times you see an advert and help to measure the effectiveness of any advertising. They remember that you have visited a website and this information may be shared with other organizations or advertisers. We may use these cookies in limited circumstances associated with our public-facing sites, and only with your consent where required by applicable law.
We may also use Tracking Technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on the Sites, web pages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Sites for the same purposes. Our Sites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Managing Your Tracking Technology Preferences
When viewing the Sites, you can accept or reject the use of cookies. In addition, many browsers allow you to manage your cookie preferences at the individual browser level. You can set your browser to reject and/or delete some or all cookies. If you reject or delete cookies, please be aware that you may not be able to use some or all portions or functionalities of the Sites.
Do Not Track. Some Internet browsers (e.g. Internet Explorer, Mozilla Firefox, and Safari) include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, the Sites currently do not process or respond to “DNT” signals.
Location Information
You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by: (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your Wi-Fi, Bluetooth, and other device settings. Please see your device settings for more information.
Analytics Tools
We may use tools such as Google Analytics, Facebook, and LinkedIn to help analyze how individuals use the Sites. Such third parties may use cookies, APIs, and SDKs on our Sites to enable them to collect and analyze user and device-related data and information on our behalf. These tools use cookies to collect information such as how often users visit the Sites, what pages they visit, and what other websites they used prior to coming to the Sites. We use the information we get to improve our Sites and to tailor the Sites to you.
We may use Google Analytics to obtain information about your visits to the Sites. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by Google Analytics Terms of Service and the Google Privacy Policy. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on.
Our Sites may utilize the Conversion Tracking Pixel service of Meta Platforms. This tool allows us to follow the actions of users after they click on a Facebook advertisement and allows us to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remains deidentified which means we cannot see the personal data of any individual user. However, the collected data is saved and processed by Meta and Meta may be able to connect the data with your Meta accounts and use the data for their own advertising purposes in accordance with Meta’s Data Use Policy. Meta Conversion Tracking also allows Meta, and its partners, to show you advertisements on and outside Meta. You can manage your preferences regarding how Meta uses your data through your Meta account settings.
Regarding Targeted Advertising. For more information about the collection and use of your information for online behavioral advertising generally, and how you can opt-out of having your data used for certain online behavioral advertising, please visit the Digital Advertising Alliance’s opt-out tool available at https://youradchoices.com/ and the Network Advertising Initiative’s Opt-Out Tool available at: https://networkadvertising.org/choices/.
Opting Out of Marketing Communications
If you no longer want to receive marketing-related e-mails from us, you may opt out by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information in the “How to Contact Us” section below.
If you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.
Retention of Personal Information
We generally will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and for a longer period when permitted or required by law.
For example, Sword will retain the personal information you provide while creating your account and your profile until such time as you delete your account or you request deletion provided you are entitled to request deletion under applicable law, whichever comes first. Any Health Records will be maintained by Sword for a period that is no less than the minimum number of years such records are required to be maintained under applicable law and health regulatory guidelines. Sword may also retain certain personal information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, securities, and regulatory compliance requirements.
International Transfer of Personal Information
We may transfer your personal information outside of Canada to fulfill the purpose for which we collected it, including for processing and storage by our service providers. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your personal information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information in the “How to Contact Us” section below.
Information Security
We have implemented physical, organizational, contractual, and technological security measures in an effort to protect your personal information from loss or theft, unauthorized access, use, or disclosure.
Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in risks such as phishing and identity theft. We will address such breaches as required by law.
We may also require that you assist us in safeguarding your personal information. For example, if you create an account through our Sites or applications, you should use a unique and strong password and not share your password with others.
If you have reason to believe that your personal information is no longer secure, please contact us immediately using the contact information in the “How to Contact Us” section below.
Your Privacy Rights
We expect you to supply us with updates to your personal information, when required. We will not routinely update your personal information unless such a process is necessary.
You may make a request to review any personal information about you that we have collected, used, or disclosed, and information about those uses and disclosures, and we will provide you with any such personal information to the extent required by applicable laws.
You may also challenge the accuracy or completeness of your personal information in our records. If you demonstrate that your personal information in our records is inaccurate, incomplete or equivocal, we will amend or delete your personal information as required. We may transmit the amended information to third parties to whom we have disclosed your personal information.
You may also withdraw your consent to our continued collection, use or disclosure of your personal information, and you may place conditions on your consent. We will accommodate your request to withdraw or place conditions on consent, subject to legal or contractual restrictions. Withdrawal of your consent may mean that we will no longer be able to provide the Services to you.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.
Third-Party Websites and Services
We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products or services from third parties with different privacy practices. Those other websites, products, or services are governed by the privacy Notices and policies of the respective third party. This Privacy Notice does not extend to any websites, products, or services provided by third parties. We do not assume responsibility for the privacy practices of third parties not acting on our behalf and we encourage you to review all third-party privacy Notices prior to using third-party websites, products, or services.
Children’s Personal Information
Our Services are not intended for children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. Children under the age of 13 should not use our Services and should not provide us with their personal information.
We may provide Service to children over the age of 13. In cases where a child is capable of consenting to the collection, use, or disclosure of their personal information, we may obtain consent from the child or through their parent or legal guardian. In cases where a child is not capable of consenting, we obtain consent from their parent or legal guardian.
Changes to this Privacy Notice
The Privacy Notice was last revised as of the date that appears at the top of this page. To review a summary of recent changes, click here.
From time to time, we may make changes to this Privacy Notice. When changes are made, they will become immediately effective when published in a revised Privacy Notice posted on our Sites, unless otherwise noted. We may also communicate the changes to this Privacy Notice by other means.
How to Contact Us
All comments, questions, concerns, or requests regarding your personal information or our privacy practices should be forwarded to our Privacy Officer at help@swordhealth.com.
If you have concerns about our privacy practices, you may also contact the applicable privacy commissioner or regulator in your jurisdiction of residence.