Privacy Policy

KidSONO Inc. · Pediatric Point-of-Care Ultrasound Training Portal

Privacy Policy

How KidSONO collects, uses, discloses, safeguards, retains and destroys personal information.

Effective October 5, 2026Version 2026-01www.kidsono.com

KidSONO Inc.

This Privacy Policy supplements and is to be read together with the End User Licence Agreement (the “EULA”) governing use of the Training Materials. If there is a conflict regarding the collection, use, disclosure, retention or destruction of Personal Information, this Privacy Policy governs.

1

Introduction And Scope

1.1 KidSONO Inc. (“KidSONO”) is a corporation registered under the Canada Not-for-profit Corporations Act. KidSONO operates the online training portal accessible at www.kidsono.com (the “Site”), through which it makes available pediatric point-of-care ultrasound instructional and training content (the “Training Materials”).

1.2 This Privacy Policy describes how KidSONO collects, uses, discloses, safeguards, retains and destroys Personal Information about a user (“User”) of the Site and the Training Materials.

1.3 This Privacy Policy supplements and is to be read together with the End User Licence Agreement (the “EULA”) governing the terms of use of the Training Materials. In the event of a conflict between this Privacy Policy and the EULA with respect to the collection, use, disclosure, retention or destruction of Personal Information, this Privacy Policy governs.

1.4 KidSONO conducts its activities in accordance with the Personal Information Protection Act (Alberta) (“PIPA”) and, to the extent applicable to its activities, the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”).

1.5 The Training Materials are not directed to children and the Site is not intended for use by any person under the age of eighteen (18) years. Consistent with the eligibility requirements of the EULA, individual students must be at least eighteen (18) years of age and enrolled in a Medical Institution. KidSONO does not knowingly collect Personal Information from any individual under the age of eighteen (18) years.

1.6 KidSONO does not collect, receive, host or process personal health information relating to patients and is not a custodian as contemplated under the Health Information Act (Alberta). The User must not upload, transmit, enter or otherwise submit to the Site any patient identifier, diagnostic image, clinical record, or other health information relating to an identifiable individual.

2

Interpretation

2.1 In this Privacy Policy, the following words shall have the meanings ascribed below:

(a) “Personal Information” means information about an identifiable individual and includes Data to the extent that the Data identifies an individual or can reasonably be used, alone or in combination with other available information, to identify an individual. Personal Information does not include information that has been anonymized and aggregated in accordance with Section 9, nor does it include business contact information used solely to contact an individual in that individual’s capacity as an employee or representative of an organization;

(b) “Privacy Officer” means the individual designated by KidSONO under Section 3.2 as accountable for KidSONO’s compliance with this Privacy Policy and applicable privacy legislation; and

(c) “Service Provider” means a third party engaged by or on behalf of KidSONO to provide services to KidSONO, including hosting, learning management, content delivery, electronic mail, analytics, technical support and information technology services

2.2 Terms capitalized but not otherwise defined herein shall have the meanings ascribed under the EULA.

3

Accountability

3.1 KidSONO is responsible for the Personal Information under its control, including Personal Information transferred to a Service Provider for processing.

3.2 KidSONO has designated the following individual as its Privacy Officer, who is accountable for KidSONO’s compliance with this Privacy Policy and who is able to answer questions about the collection, use, disclosure and storage of Personal Information by KidSONO and its Service Providers:

KidSONO Inc.
Alberta Children’s Hospital
2888 Shaganappi Trail N.W.
Calgary, Alberta T3B 6A8
Attention: Julia Stiz, Privacy Officer
Email: privacy@kidsono.com
Telephone: +1 825-488-8261

3.3 KidSONO requires each Service Provider to which it transfers Personal Information to provide, by written agreement, a comparable level of protection as described in this Privacy Policy, and to use the Personal Information solely for the purposes of providing services to KidSONO.

3.4 KidSONO provides its directors, officers, employees, volunteers and advisors with information regarding their obligations under this Privacy Policy and requires such individuals to maintain confidentiality of the Personal Information that they might access in providing services to KidSONO.

4

Personal Information Collected

4.1 Depending on the class of User, KidSONO collects the following information from the User: (a) first and last name; (b) login name and authentication credentials; (c) email address; (d) the name of the employer or Medical Institution; (e) in the case of Medical Professionals, the professional designation, credentials and where applicable, licence or registration number and the applicable Regulatory Body; and (f) in the case of individual students, confirmation of enrolment at a Medical Institution and confirmation that the User is at least eighteen (18) years of age.

4.2 KidSONO also collects information relating to the User’s module access and completion, progress results, quiz and assessment scores, dates and times of access and duration of access to the Site.

4.3 KidSONO and its Service Providers collect the following additional information from the User: (a) Internet Protocol (IP) address; (b) domain name; (c) approximate geographic location derived from IP address; (d) device type; (e) browser type and version; (f) operating system; and (g) referring page and pages viewed.

4.4 KidSONO collects only the Personal Information which is reasonably required for the purposes identified in Section 5. KidSONO will not collect categories of Personal Information beyond those described in this Section 4 without first notifying the User and, where required, obtaining the User’s consent.

5

Purposes For Collection, Use And Disclosure

5.1 KidSONO collects, uses and discloses the Personal Information for the following purposes:

(a) to create, administer and authenticate the User’s account and to control access to the Training Materials;

(b) to verify the User’s eligibility under the applicable User class in the EULA, including age, enrollment status and professional credentials;

(c) to deliver the Training Materials and to record and report the User’s progress, module completion and assessment results;

(d) to provide technical support to the User;

(e) to evaluate, maintain, improve and develop the Training Materials and the Site, including conducting surveys;

(f) to prepare internal reports and data analysis, and to compile, publish and disclose anonymized and aggregated compilations in accordance with Section 9;

(g) to communicate with the User regarding the User’s account, service and administrative notices, and changes to the Training Materials, the EULA or this Privacy Policy;

(h) to detect, investigate and prevent unauthorized access to or misuse of the Site and the Training Materials, and to enforce the EULA; and

(i) to comply with applicable legal and regulatory requirements

5.2 KidSONO does not sell, rent, trade or otherwise disclose Personal Information to third parties for financial gain or for any other commercial or marketing purposes.

5.3 KidSONO will not use or disclose the Personal Information for any purpose other than those identified in Section 5.1 without first obtaining the consent of the User, except where the use or disclosure is permitted or required by law.

6

Consent

6.1 KidSONO collects, uses and discloses the Personal Information with the knowledge and consent of the User, except where PIPA or PIPEDA permits or requires KidSONO to act without consent. The User provides express consent to the collection, use and disclosure of the Personal Information for the purposes set out in Section 5.1 by accepting the EULA and this Privacy Policy at the time of registration on the Site.

6.2 KidSONO will not, as a condition of providing access to the Training Materials, require a User to consent to the collection, use or disclosure of the Personal Information beyond what is necessary to provide the Training Materials.

6.3 A User may withdraw consent to the collection, use or disclosure of the Personal Information at any time on reasonable notice to the Privacy Officer, subject to legal and contractual restrictions. KidSONO will then inform the User of the likely consequences of withdrawal, which may include the suspension or termination of access to the Training Materials and the inability of KidSONO to record or verify the User’s progress in the Training Materials. Withdrawal of the User’s consent does not require KidSONO to withdraw, un-publish, retract or reverse any anonymized and aggregated compilation already prepared or disclosed in accordance with Section 9.

7

Medical Institutions Enrolment

7.1 In the case where a Medical Institution initiates training for its students, residents or staff, the Medical Institution may provide KidSONO with Personal Information about the User for the purposes of enrolment and account creation.

7.2 The Medical Institution represents and warrants to KidSONO that, before providing any Personal Information about the User to KidSONO, it has obtained all consents required under applicable privacy legislation and has notified the individual of the purposes for which the Personal Information will be collected, used and disclosed, including the reporting described in Section 7.3. The Medical Institution is independently responsible for its own compliance with applicable privacy legislation.

7.3 In the case where a User has been enrolled by a Medical Institution, KidSONO may disclose to that Medical Institution the User’s enrolment status, module access and completion records, progress results and assessment scores.

7.4 KidSONO shall not disclose the Personal Information about the User to a Regulatory Body except with the express consent of that User, or where the disclosure is required or authorized by law. Where a User requests that KidSONO provide confirmation of module completion to a Regulatory Body for continuing professional development or continuing medical education purposes, such request shall constitute consent by the User to the disclosure of the information reasonably required for such purposes.

8

Permitted Disclosure

8.1 KidSONO may disclose the Personal Information as follows:

(a) to a Service Provider, for the purpose of enabling that Service Provider to perform services for KidSONO, subject to the contractual protections described in Section 3.3;

(b) to a Medical Institution, in accordance with Section 7.3;

(c) to a Regulatory Body, in accordance with Section 7.4;

(d) in anonymized and aggregated form, in accordance with Section 9;

(e) to KidSONO’s legal, accounting, insurance and other professional advisors, where reasonably required and subject to duties of confidentiality;

(f) where required or authorized by law, including in response to a court order, subpoena, warrant, or other lawful demand of a court, regulator or government authority having jurisdiction;

(g) where reasonably necessary to investigate a suspected breach of the EULA, to protect the rights or property of KidSONO or the Protected Parties, or to prevent or investigate fraud, unauthorized access or other unlawful activity; and

(h) to a successor entity in connection with an amalgamation, continuance, transfer of all or substantially all of KidSONO’s undertaking, or the winding-up or dissolution of KidSONO, provided that the recipient agrees to be bound by protections comparable to those in this Privacy Policy and to use the Personal Information only for the purposes for which it was collected

8.2 Except as set out in Section 8.1, KidSONO shall not disclose the Personal Information to any third party without the consent of the User.

9

Anonymized And Aggregated Information

9.1 KidSONO may compile, publish and disclose anonymized and aggregated compilations derived from the Data to Medical Institutions, Regulatory Bodies, funders, research partners and other third parties for the purposes of internal reporting and analysis, seeking funding, and curriculum development assistance.

9.2 Information is anonymized and aggregated for the purposes of this Privacy Policy only where direct and indirect identifiers have been removed and the information cannot reasonably be used, alone or in combination with other information reasonably available, to identify the User. KidSONO shall not attempt to re-identify anonymized information and shall require, by written agreement, that recipients of anonymized and aggregated compilations comply with the restrictions set out in this Section 9.

9.3 For certainty, information that has been anonymized and aggregated in accordance with this Section 9 is not Personal Information and is not subject to the access, correction or withdrawal of consent provisions of this Privacy Policy.

10

Cookies

10.1 The Site uses cookies and similar technologies, which are small data files placed on a User’s device. KidSONO uses cookies in the following manner: (a) strictly necessary cookies, required to authenticate the User, maintain session security and enable core functionality of the Site; (b) preference cookies, which record a User’s settings; and (c) analytics cookies, which assist KidSONO in understanding how the Training Materials are accessed and used.

10.2 Most Web browsers permit the User to refuse or delete cookies through browser settings. Disabling strictly necessary cookies may prevent the User from logging in to the Site and accessing the Training Materials.

10.3 KidSONO does not use the Personal Information for behavioral advertising and does not permit third parties to collect the Personal Information through the Site for such advertising purposes.

11

Storage And Access Outside Alberta And Canada

11.1 KidSONO may in the future, engage Service Providers that may store the Personal Information, or have access to the Personal Information, outside the Province of Alberta and outside Canada.

11.2 In accordance with s. 13.1 of PIPA, KidSONO provides the following notice, if applicable, that KidSONO’s policies and practices with respect to the use of Service Providers outside Canada may be obtained by contacting the Privacy Officer identified in Section 3.2.

11.3 The Personal Information stored or accessed in a foreign jurisdiction, if applicable, shall be subject to the laws of that jurisdiction and may be accessible to the courts, law enforcement agencies, regulators and national security authorities of that jurisdiction in accordance with local laws.

11.4 KidSONO requires each Service Provider located outside Canada, if applicable, to protect the Personal Information by means comparable to those described in this Privacy Policy by written agreement.

12

Safeguards

12.1 KidSONO protects the Personal Information by security safeguards appropriate to the sensitivity of the information, including industry standard physical, organizational and technological measures reasonably designed to protect against loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.

12.2 As no method of transmission over the internet is completely secure, KidSONO cannot guarantee absolute security of the User’s transmission of Personal Information to the Site. Consistent with the EULA, the User is responsible for maintaining the confidentiality of the User’s login credentials and must not permit any other person to access the Training Materials using the User’s credentials.

13

Retention And Destruction

13.1 In accordance with s. 35(1) of PIPA, KidSONO retains Personal Information only for as long as is reasonably necessary to fulfil the purposes for which it was collected and to satisfy applicable legal, regulatory, accounting and reporting requirements.

13.2 Subject to applicable legal, regulatory, accounting and reporting requirements, KidSONO’s standard retention periods are as follows:

(a) account and profile information: five (5) years following closure or deactivation of the account;

(b) progress results, module completion records and assessment scores: five (5) years;

(c) server, access and security logs: five (5) years; and

(d) support and other correspondence: five (5) years

13.3 At the expiry of the applicable retention periods, KidSONO shall securely destroy, erase or anonymize the Personal Information.

14

Accuracy And Corrections

14.1 KidSONO makes reasonable efforts to ensure that the Personal Information used on an ongoing basis is accurate and complete.

14.2 The User may review and update the User’s account and profile information at any time through the account settings on the Site.

14.3 On written request to the Privacy Officer, and subject to Section 14.5, KidSONO shall provide the User with: (a) the Personal Information under KidSONO’s control; (b) information about the purposes for which that Personal Information has been and is being used; and (c) the names of organizations or categories of organizations to which the Personal Information has been disclosed, where required by applicable laws.

14.4 KidSONO will respond to an access request within forty-five (45) days of receipt, in accordance with s. 28 of PIPA, unless that period is extended in the circumstances permitted under s. 31(1) of by PIPA, in which case KidSONO shall notify the User of the extension, the reason for it, and the individual’s right to make a complaint to the Information and Privacy Commissioner of Alberta.

14.5 KidSONO may refuse or limit access to the requested Personal Information where PIPA requires or permits, including where: (a) the information is protected by solicitor-client privilege; (b) disclosure would reveal confidential commercial information; (c) disclosure would reveal Personal Information about another individual; (d) the information was collected for an investigation or legal proceeding; or (e) the request is frivolous or vexatious. Where access is refused in whole or in part, KidSONO will provide written reasons and advise the individual of the right to make a complaint to the Information and Privacy Commissioner of Alberta.

14.6 The User may request in writing that KidSONO correct an error or omission in the individual’s Personal Information. Where KidSONO does not make the requested correction, it will annotate the record with the correction that was requested but not made. Where reasonable to do so, KidSONO will send notice of the correction or annotation to any organization to which the Personal Information was disclosed during the twelve (12) months before the correction was requested.

14.7 KidSONO may charge a reasonable fee for responding to an access request as permitted by s. 32 of PIPA and will provide the User with a written estimate of the fee before proceeding. No fee is charged for a correction request or for access to the individual’s own account information available through the Site.

15

Notification Of Breach

15.1 Where there is a loss of, or unauthorized access to or disclosure of, the Personal Information under KidSONO’s control, and a reasonable person would consider that there exists a real risk of significant harm to an individual as a result, KidSONO will, without unreasonable delay, provide notice of the incident to the Information and Privacy Commissioner of Alberta in accordance with s. 34.1 of PIPA, and will notify affected individuals where directed by the Privacy Commissioner or where otherwise required or appropriate.

15.2 In the case where PIPEDA applies to an incident involving Personal Information under KidSONO’s control, KidSONO will assess whether the incident creates a real risk of significant harm to an individual. Where such a risk exists, KidSONO will report the breach to the Privacy Commissioner of Canada and notify affected individuals, as soon as feasible and in accordance with PIPEDA. KidSONO will also notify any other organization or government institution that may be able to reduce the risk of harm and maintain records of the breach as required by applicable laws.

15.3 In addition, KidSONO will also notify each affected Medical Institution of any incident involving the Personal Information of the User enrolled by that Medical Institution, without unreasonable delay.

16

Third-Party Websites

16.1 The Site may at any time in the future contain links to websites operated by third parties. KidSONO is not responsible for the privacy practices or content of those websites. This Privacy Policy applies only to the Personal Information collected by KidSONO through the Site and the Training Materials.

17

Amendments

17.1 KidSONO may amend this Privacy Policy from time to time. The amended Privacy Policy will be posted on the Site with a revised Effective Date and will apply from the date of posting.

17.2 Where an amendment materially changes the purposes for which Personal Information is collected, used or disclosed, KidSONO will provide notice to the User and, where required by applicable law, obtain updated consent before applying the amended purposes to the Personal Information already collected.

18

Questions And Complaints

18.1 Questions, requests and complaints regarding this Privacy Policy or KidSONO’s handling of the Personal Information should be directed in writing to the Privacy Officer identified in Section 3.2.

18.2 KidSONO will investigate all complaints. Where a complaint is found to be justified, KidSONO will take appropriate measures, including amending its policies and practices as necessary. KidSONO will respond to the complainant in writing.

19

Governing Law

19.1 This Privacy Policy is governed by and construed in accordance with the laws of the Province of Alberta and the federal laws of Canada applicable therein, without regard to conflict of laws principles. The sole and exclusive jurisdiction and venue for any action arising out of or relating to this Privacy Policy is the courts of Alberta, sitting in Calgary, Alberta. DATED effective this __5___ day of October, 2026. Version: 2026-01