Your privacy is important to HealthTech Connex Inc. (a Canadian corporation with its head office in British Columbia, Canada) and its affiliates (“HealthTech Connex” or “we”) and we are committed to protecting the privacy of our customers.
HealthTech Connex Inc. will use current industry standard information security best practices to maintain the security of your sensitive information we collect from and on behalf of our customers. We will review these practices from time-to-time against new and emerging standards.
We recognize that all data is not created equal, and some types of data are more sensitive than others. With that in mind, this Policy will outline the ways in which we will protect your privacy for each type of data.
TYPES OF DATA
Depending on which HealthTech Connex Inc. Services, programs or products you choose to access or participate in, we may collect, process and/or store one or more of the following types of data about you:
Brainwave and Biometric Information
Personally Identifiable Information
Site, Service and Application Usage Information
Below we have defined each type of data and described our respective rights and obligations related to such data.
BRAINWAVE AND BIOMETRIC INFORMATION
For the purposes of this Policy, ”Brainwave and Biometric” data is defined as:
Data collected by sensors in the third-party EEG headband or other sensors. This would include the raw recordings from the sensors as well as any scores or performance data that are generated for you as part of your use of HealthTech Connex Inc. Services.
Ownership & License
Brainwave and Biometric Data is the most sensitive data contemplated by this Policy. At HealthTech Connex Inc., it is our goal to be industry leaders in the protection of users’ Brainwave and Biometric Data.
Your Brainwave and Biometric Data belongs to you, and you retain, at all times, complete ownership of all your Brainwave and Biometric Data collected during your use of HealthTech Connex Inc. Services.
For as long as your Brainwave and Biometric Data is stored as part of or as a result of your use of HealthTech Connex Inc. Services, you grant us a limited, revocable, non-exclusive license to collect, process and store that data, only so far as is required to deliver you HealthTech Connex Inc. Services.
At any time, you can choose to remove your Brainwave and Biometric Data from HealthTech Connex Inc.’s possession or control. Our contact information is set out below.
We will process these requests within a reasonable amount of time, and upon removal of the information, we will have no further license to use your Brainwave and Biometric Data.
Storage and Protection
Brainwave and Biometric Data generated by use of HealthTech Connex Inc. Services that is not anonymized will be available only to those personnel who we reasonably believe require access to such information to provide higher level technical support and troubleshooting services.
PERSONALLY IDENTIFYING INFORMATION
For the purposes of this Policy, “Personally Identifying Information” is defined as:
Information that identifies you, such as your name, address, phone number and email address.
Ownership & License
You retain complete ownership of all Personally Identifying Information collected during your use of HealthTech Connex Inc. Services.
You grant HealthTech Connex Inc. a non-exclusive, limited license to collect, process and store this data for the purpose of providing HealthTech Connex Inc. Services for as long as you continue to use them.
At any time, you may request the removal of your Personally Identifying Information from HealthTech Connex Inc.’s possession or control. These requests will be facilitated within a reasonable period of time. You can also request to see what Personally Identifying Information HealthTech Connex Inc. has stored on your behalf. Our contact information is set out below.
Storage and Protection
All Personally Identifying Information stored by us will be stored using security measures that meet or exceed industry standards for the protection of Personally Identifying Information.
Personally Identifiable information will only be accessible to people we believe have a relevant need for that information for the purposes of product/service development, billing, quality, delivery, and/or management of our business/operations. For example, customer contact and service details are available to personnel involved with service delivery and support.
If required, customer contact information may be accessible on a limited basis to 3rd party service delivery personnel from organizations with whom HealthTech Connex Inc. has engaged in a contractual relationship (which may include confidentiality agreements) where HealthTech Connex Inc. believes such access is reasonably required to deliver HealthTech Connex Inc. products/services (examples may include regional 3rd party hardware or software support personnel, or personnel providing repair, workshop or training services). Other than as set forth herein, HealthTech Connex Inc. does not share, rent, or sell Personally Identifying Information it collects about you to or with third parties.
SITE, SERVICE AND APPLICATION USAGE INFORMATION
For the purposes of this Policy, “Site, Service and Application Usage Information” is defined as:
Information that enables HealthTech Connex Inc. to track site, service and application usage such as access date and time, the specific web and application service used, frequency and duration of access, and other users contacted or collaborated with via HealthTech Connex Inc. Services.
Storage and Protection
Site, Service and Application Usage Information will only be accessible to people we believe have a relevant need for that information for the purposes of product/service development, billing, quality, delivery, and/or management of our business/operations. For example, customer contact and service details are available to personnel involved with service delivery and support.
All Site, Service and Application Usage Information will be stored using security measures that meet or exceed industry standards for the protection of such information.
DATA STORED ON LOCAL DEVICES
As part of the use of HealthTech Connex Inc. Services, some or all of your data may be stored on your local device (for example your smartphone, tablet or computer) and/or uploaded to our cloud servers. We urge you to take measures to protect the information on your local devices, for instance via application password as well as any additional protection – such as local data encryption – optionally chosen by the user (offered on both Google® Android(™) and Apple® iOS(™) devices). You also have the option of deleting locally stored data.
For more information on Apple IOS (iPhone / iPad) security, please see: https://www.apple.com/iphone/business/docs/iOS_Security_Oct12.pdf
SHARING WITH OTHER USERS OR ON SOCIAL MEDIA
When sharing your HealthTech Connex Inc. data with other users via HealthTech Connex Inc. Services, HealthTech Connex Inc. will utilize a confirmation mechanism within the application or Notice to solicit and confirm your consent. HealthTech Connex Inc. cannot, of course, control information shared by you or someone else through channels such as email, chat or other social media.
SITUATIONS REQUIRING THE DISCLOSURE OF DATA
Notwithstanding anything to the contrary, HealthTech Connex Inc. may disclose any data collected through HealthTech Connex Inc. Services if required to do so by law or in the good faith belief that such action is necessary to: (i) confirm to applicable law or comply with legal process served on HealthTech Connex Inc. or any HealthTech Connex Inc. site, (ii) protect and defend the rights or property of HealthTech Connex Inc., or (iii) in urgent circumstances to protect the personal safety of users of HealthTech Connex Inc., HealthTech Connex Inc. Services or the public.
HEALTHTECH CONNEX INC. POLICIES FOR CHILDREN
HealthTech Connex Inc. products and services are not directed at persons under the age of 13. We do not knowingly collect any Personally Identifying Information from children under 13 years old. If you are aware of a user under the age of 13 using HealthTech Connex Inc. products, please contact us using the information provided below.
Subject to compliance with applicable law, we may also send you product or service related communications, or invitations to participate in surveys, etc. We ask that you read any Notice associated with such communication before you agree to participate. Also, HealthTech Connex Inc. typically includes an unsubscribe mechanism in any HealthTech Connex Inc. marketing or commercial communication, which you may use to notify us if you do not want to receive such communications.
MERGERS AND ACQUISITIONS
HealthTech Connex Inc.
201-13737 96th Avenue
Surrey, BC, Canada
Last update: August 24, 2017