Privacy Policy

Last updated: December 17th, 2020

Protecting your information is a priority for TherAppX inc. (hereinafter the "Company,” “We” or “Us”). However, due to the nature of the Internet and information technology, security and privacy risks cannot be entirely eliminated, and the Company cannot guarantee that your information will not be compromised or accessed by means not provided for in this policy.

Introduction

Welcome to our products! The purpose of this privacy policy is to make sure you understand the nature of the information collected, used and potentially disclosed by the Company and to inform you why we collect this information when you use our products. Using TherAppX's various products (hereafter the “products”), you consent to the collection, use and disclosure of your information in accordance with this policy. If you do not agree to this policy, you may not use the products and must stop using them immediately. Please make sure you read this entire Privacy Policy!

Information concerning patients

Collected information

As a user who’s a patient, you do not need to create a profile. We collect your IP address, your browser's fingerprint and user agent for analytics, support and continuous product improvement. We use Segment (read their privacy policy) and Heap Analytics (read their privacy policy) for those purposes. 

You are welcome to provide your e-mail address if you wish to benefit from follow-ups on your condition using our e-mail service. We may also use your email, if you consent explicitly, to notify you of new Digital Health Tools (hereinafter " DHT " or “DHTs”) of interest available in your area.

To be paired with a DHT, you provide the company with your location, preferred language, preferred device, operating system, current needs for DHT functionality, and other general health information. We collect and store this information for analysis and continuous improvement. This information is confidential and treated as such, just like any additional information you may communicate in the future in our products (e.g. medical history, medications, history of illness, personal identification number).

Right to be forgotten

Subject to certain exceptions provided by law, you have the right to have access to the information we collect about you, at any time, free of charge, and have the right to challenge the accuracy and completeness of the information and have them changed. To do so, please contact us at [e-mail].

Shared information

We store all information collected on secure servers in Canada.

At all times, the Company will comply with Canada’s applicable laws when using or disclosing your information. Aside from the people and organizations listed below, we won’t share your information with anyone unless the Company is legally required to pass it on to a competent authority. In all cases, these parties are subject to the same obligations as the Company as per this Policy.

We grant access to this information to:

• to company and product administrators, for example, to communicate with users or improve the service offered
• to a potential buyer and to any organization involved in a transaction involving the sale or transfer of all or part of the assets of the company, in which case the use of your information by the new entity will continue to be subject to applicable law and comply to the current policy fully;
• researchers and various levels of government to improve local services and knowledge about the health conditions affected by the pandemic
• to any organization where the Company has reasonable grounds to believe that the information may be relevant to an investigation of illegal activity or to comply with a writ of subpoena, warrant, court order or to comply with court rules regarding the production of records and information or to protect the rights and property of the company.

Aggregation of data

Concerning the aggregation of data from products and the use of this data for commercial use or process improvement, the company reserves the right to:

• disclose about the products, in communications or commercial prospecting, the nature of the functionalities sought by users, the user demographics and the corresponding DHTs to promote the products. In this case, the Company does not reveal the user’s identity. The data will always be anonymous (i.e. without personal or identifying data) and aggregated (i.e. not individual);
• provide third parties with usage data of users and its products in aggregated reports (e.g. number of matched DHTs, number of monthly active users, etc.) to indicate the products’ interest. In this case, the Company undertakes not to reveal the users’ identity. The data will always be anonymous (i.e. without personal or identifying data) and aggregated (i.e. not individual);
• send you electronic communications via the users’ e-mail address (voluntarily and in compliance with the regulations in this matter in Canada). At any time, the company you can ask us to stop sending by contacting [e-mail].

Data retention

The Company may retain and process your information for as long as necessary for the purposes for which it was collected or as permitted or required by law. After this period, the Company agrees to delete all your information stored securely.

Please note that all information collected by the Company is processed and stored in confidential and secure databases, located at Google Cloud in Canada, and commissioned by the Company. This organization has obtained ISO 27001 certification and performs annual SSAE16 / ISAE 3402 Type II audits. However, all information is the company’s exclusive property, and the use of this information by the company complies with applicable laws.

The case of the minor user

The Platform can’t be used by a child aged under 14 years old. Suppose the Company is notified or aware that the Platform has been used by a child aged under the age of 14 and that information about this child was retained without parental consent, the Company must and is authorized to delete, in its entirety, all information kept. By using the Platform to keep information about a child under 14 for whom you have parental authority, you consent to the retention of your child's information. You agree that the Company uses such information in accordance with the law and this Policy. Notwithstanding the foregoing, when the Company is notified, knows or has reason to believe that you are using the Platform with respect to a child aged under 14 years of age for whom you do not have parental authority, the Company may delete the child's information in its entirety and revoke your right to use the Platform.

Limitation

If a DHT found on in our Products contains a hyperlink that takes you to another site; this Policy does not apply to it. Therefore, the company invites you to be vigilant in this regard.

The Company may change this Policy from time to time at the sole discretion of the Company. When using the service after an update or change, you will be prompted to read and agree to the new Privacy Policy to receive the service offered by the Platform. The collection, use and disclosure of your information is governed by the most recent version of this Policy. Continuing to use the Platform as a result of any changes to this Policy will mean your consent to the collection, use and disclosure of your information in accordance with the amended Policy.

If you have any comments or questions about this policy or your information, please write to us at [e-mail].

Information for healthcare professionals and other clients of the company

Collected information

As healthcare professionals or customers of the company using the products, you are encouraged to create a profile to access the products. In addition to the information you provide when completing your profile, we collect your IP address, browser fingerprint, and user agent. We do so for analysis, support and continuous product improvement purposes. We use Segment (read their privacy policy) and Heap Analytics (read their privacy policy) for those purposes. We use Circle.so for the Community service (read their privacy policy)

When you use our products to send a DHT recommendation to a patient, you consent that your patient is bound to this privacy policy. We may use additional services that may collect data on our behalf such as Typeform (read their privacy policy). To collect payments, we use Stripe (read their privacy policy).

Right to be forgotten

Subject to certain exceptions provided for by law, you are entitled to have access to the information we collect about you, at any time, free of charge, and have the right to dispute the accuracy and completeness of the information and have it amended. To do this, please contact us at [e-mail].

Shared information

We store all information collected on secure servers in Canada.

At all times, the Company will comply with Canada’s applicable laws when using or disclosing your information. Aside from the people and organizations listed below, we won’t share your information with anyone unless the Company is legally required to pass it on to a competent authority. In all cases, these parties are subject to the same obligations as the Company as per this Policy.

We grant access to this information to:

• to company and product administrators, for example, to communicate with users or improve the service offered
• to a potential buyer and to any organization involved in a transaction involving the sale or transfer of all or part of the assets of the company, in which case the use of your information by the new entity will continue to be subject to applicable law and comply to the current policy fully;
• researchers and various levels of government to improve local services and knowledge about the health conditions affected by the pandemic
• to any organization where the Company has reasonable grounds to believe that the information may be relevant to an investigation of illegal activity or to comply with a writ of subpoena, warrant, court order or to comply with court rules regarding the production of records and information or to protect the rights and property of the company.

Agglomeration of data

Concerning the aggregation of data from products and the use of this data for commercial use or process improvement, the company reserves the right to:

• disclose about the products, in communications or commercial prospecting, the nature of the functionalities sought by users, the user demographics and the corresponding DHTs to promote the products. In this case, the Company does not reveal the user’s identity. The data will always be anonymous (i.e. without personal or identifying data) and aggregated (i.e. not individual);
• provide third parties with usage data of users and its products in aggregated reports (e.g. number of matched DHTs, number of monthly active users, etc.) to indicate the products’ interest. In this case, the Company undertakes not to reveal the users’ identity. The data will always be anonymous (i.e. without personal or identifying data) and aggregated (i.e. not individual);
• send you electronic communications via the users’ e-mail address (voluntarily and in compliance with the regulations in this matter in Canada). At any time, the company you can ask us to stop sending by contacting [e-mail].

Data retention

The Company may retain and process your information for as long as necessary for the purposes for which it was collected or as permitted or required by law. After this period, the Company agrees to delete all your information stored securely.

Please note that all information collected by the Company is processed and stored in confidential and secure databases, located at Google Cloud in Canada, and commissioned by the Company. This organization has obtained ISO 27001 certification and performs annual SSAE16 / ISAE 3402 Type II audits. However, all information is the company’s exclusive property, and the use of this information by the company complies with applicable laws.

Limitation

If a DHT found in our Products contains a hyperlink that takes you to another site; this Policy does not apply to it. Therefore, the company invites you to be vigilant in this regard.

The Company may change this Policy from time to time at the sole discretion of the Company. When using the service after an update or change, you will be prompted to read and agree to the new Privacy Policy to receive the service offered by the Platform. The collection, use and disclosure of your information is governed by the most recent version of this Policy. Continuing to use the Platform as a result of any changes to this Policy will mean your consent to the collection, use and disclosure of your information in accordance with the amended Policy.

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If you have any comments or questions about this policy or your information, please write to us at [e-mail].