CONFIDENTIALITY POLICY

Last updated: July 27, 2020

The Neuro Solutions Group (“GNS”, “we”, “us” or “our”) places particular importance on respecting your private life and protecting your personal information.

This Confidentiality Policy (hereinafter the “Policy”) is intended to inform you of the way in which GNS collects, uses, discloses, retains and protects your personal information.

In order to provide you with quality services, we need to have access to certain personal information about you. We ensure that our employees manage this information with all the discretion and rigour necessary, in accordance with applicable legal and regulatory requirements.

PERSONAL INFORMATION

“Personal information” refers to any information about a person that is identifiable or which, separately or together with other data, can be used to identify a person. In general, personal information does not include your professional details, such as your name, title, address or work telephone number.

CONSENT

As a general rule, GNS will obtain personal information directly from you, with your consent, subject to the exceptions provided by law.

 By providing us with personal information, through our website, creating an account to use your Kairos app (the “App”), by phone, email, in person or by any other means, you agree for your personal data to be collected, used and disclosed in accordance with this Policy.

GNS will not collect, use or disclose your personal information without your consent unless it is authorized or required to do so under applicable regulations. For example, GNS may have to act without your consent, in particular when, for detecting or preventing fraud or for law enforcement, obtaining consent from the person would cause the process to fail.

Withdrawal of your consent

At any time, subject to reasonable notice and the applicable legal or contractual restrictions, you may withdraw your consent to the use of the personal data already collected by contacting our Privacy Manager. A refusal to provide information or the withdrawal of your consent could prevent us from providing or continuing to provide some of our services. However, please note that anonymized information that cannot be used to identify you will be retained.

Use for secondary purposes

GNS may also request your consent to the use of your personal information for secondary purposes, for instance, to carry out market research or build its databases. As mentioned above, we will ask for your consent to this end. Furthermore, your consent to the use of your data for secondary purposes may be withdrawn at any time, without affecting the delivery of our services to you.

What personal information do we collect?

 Information collected by GNS

As part of our interactions with you, whether during your use of the App, through a request for information or in our activities, we must collect certain personal information about you. The personal information we collect is necessary to provide you with the requested services. This includes but is not limited to:

  • Your contact details, such as your name, mailing address, email or phone number.
  • Information about marketing and communication preferences, such as comments and survey responses;
  • Information about the use of our website, including technical information about visits or any other information collected through cookies or other similar tools.
  • Recruitment information, such as CVs, information about your professional or academic background or any other information relevant to potential recruitment;
  • Historical information, such as the names of your former employers, job titles and digital content such as photos, videos or audio files.
  • Any other personal information provided.

Information collected specific to the App

When you create your account:

You can create an account via Facebook or Google by giving us only your email address, your full name and your city. You have a choice as to how you want to create an account. If you want to connect to the App through Facebook or Google, be aware that we will also have access to your public profile and that you will also be subject to these companies’ confidentiality policies.

During purchases

GNS does not collect any information about the transactions you carry out during your purchase through the Apple Store or Google Play, such as your credit or debit card number. Please note that, in addition to this Policy, the processing of your payment will be subject to the confidentiality policy of Apple or Google.

When using the App:

When you use the App, you are invited to create a PARENT module as well as one or more CHILDREN’S modules. As the App makes it easier to provide a routine for children, we collect, in particular, information you enter in it yourself, including:

  • Your preferred language
  • Your subscription type
  • The child’s name, age and gender
  • The tasks per routine and the information associated with it (active tasks, to be validated, number of tasks, task title, etc.)
  • Routines and associated information (active and inactive routine)

In addition to this information, we collect the following data:

  • Table visited and time per table
  • Duration of use
  • Device type and number of devices connected to the account
  • Opening of the guide, reading of the guide, reading of notifications
  • Completion rate statistics
  • Opening of emails/clicking on email links

Please note that we reserve the right to request an update of the data we collect. However, you will be informed in advance.

How do we collect your personal information?

GNS collects your personal information from you and using cookies. 

  1. From you

You provide certain personal information directly, in particular when you create an account through the App, when you communicate with us or when you click on an ad we place on a third-party website (e.g. Google, Facebook, etc.).

  1. From a third party

We may also collect personal information from third parties or accessible public records as permitted by law or if we have obtained the necessary consent.

2.Cookies 

Cookies are small data files that are commonly stored on your device when you use websites and online services. They are used for the efficient operation of websites and can provide information and help to customize services. GNS collects the personal data provided by cookies.

GNS uses different types of cookies:

  • Performance and functionality cookies: These cookies are not essential to providing our services. They make it easier to customize and improve the user experience. For instance, they may remember your preferences and avoid having your reenter information more than once or remember your login credentials so you do not have to enter them every time you use our services. They allow us to understand your behaviour in order to improve our services and our App. 
  • Advertising cookies: These cookies are not essential to providing our services. They use information about your visit to the site, such as the pages viewed or your response to ads, to provide the best user experience based on your situation.

If you want to disable the use of cookies, it is possible to do so from the preference menu of your browser. It is possible to disable cookies or use the private browsing mode when using our website. 

  1. Use for research and development purposes

The information in the App may also be used for research and development purposes in order to improve your experience within the App. In this case, your information will be anonymized and used mainly for statistical purposes. Furthermore, since we exist to create technological solutions to improve the everyday lives of people living with disabilities, we are committed to participating in the advancement of research in this field. Thus, by using the App, you will be contributing to this mission. However, we want to reassure you: no identifiable information will be used. As mentioned above, this information is anonymized and used for statistical and research purposes. 

Why do we collect your personal information?

GNS collects, uses and discloses personal information for purposes determined at the time of collection or as permitted or required by law. This includes, in particular, the following purposes:

  • Building and managing our relationship with you;
  • Providing services, including your use of the App;
  • Making it easier to use our website and our App and ensure their relevance and follow up on the way our website and our App are used;
  • Responding to your requests for information;
  • Engaging in business development and marketing, including to inform our current and future clients about new offers, with prior agreement from the person in question;
  • Conducting research and development in order to ensure that we maintain the highest security standards and understand the requirements of our customers to improve our offerings;
  • Recruiting staff, processing applications and evaluating the profiles of applicants against the requirements of the job;
  • As permitted or required, for any applicable legal obligation or provision;
  • Any other purpose you have consented to.

How do we share your personal information? 

Sometimes we may have to share your personal data with agents or other service providers to help us make all the features of our website and App available (maintenance, analysis, legal requirement, fraud detection, marketing and development). Please note that these may be located in Canada or in other jurisdictions or countries. They will only have access to the personal information necessary to carry out these tasks on our behalf and they are required not to disclose it or use it for other purposes. Please be aware that we have contractual agreements with these providers to guarantee the security of your data. Please note that we may also share your personal information as required by law, to comply with rules or to protect our security or our rights or those of others.

Furthermore, as mentioned in the section “How do we use your personal data?”, we may share anonymized data.

How do we share your personal information and with whom?

The security and confidentiality of your personal information are important to us. We strive to apply the necessary and appropriate security measures in order to guarantee the confidentiality of the personal information in our possession. To do so, we follow generally accepted industry standards. The personal data we hold are therefore only accessible to persons needing to know them and who use them only when necessary to carry out their duties.

Appropriate physical, technical and/or administrative protective measures have been implemented and are kept up to date in order to prevent:

  • Any accidental or unlawful destruction;
  • Any accidental loss;
  • Any unauthorized disclosure;
  • Any unauthorized changes;
  • Any unauthorized access; and
  • Any unlawful processing.

To do so, we ensure that we restrict access to our offices and computer equipment, train our staff and require our representatives and providers of goods and services with access to personal data to sign confidentiality agreements and implement security measures deemed equivalent to ours.

If you believe that your personal information has been compromised, please contact us by using the contact information listed in the “Questions, comments, complaints” section of this Policy.

How long do we retain your personal information?

Your personal information will be stored for as long as necessary to fulfill certain purposes or comply with legal requirements relating to retention periods. For instance, as it relates to our App, we will use your personal information for as long as you use it.

Users may request the deletion of their account by sending an email request to GNS.

How can you access and correct your personal information?

You have access to your personal information through your user account in the App. You can correct and update some of your personal information using this method.

You may request access to your personal information or information about the existence of such information or the way in which we collect, use, retain and/or disclose your personal data. You may also request that the information held by GNS be rectified if it is inaccurate, wrong or incomplete.

You may submit a written request to this end by writing to the Privacy Manager at the address specified in the “Questions, comments, complaints” section below.

If you would like to obtain copies of your personal information, we may have to charge you a small fee, which would be notified to you in advance, only to cover the costs of transcription, reproduction or transmission.

PERSONAL INFORMATION FROM THE EUROPEAN UNION

The following sections only apply to the personal data collected, processed or disclosed about an individual located in the territory of the European Union at the time of collection. 

Right to erasure (“Right to Be Forgotten”)

Subject to certain applicable restrictions, you have the right to obtain erasure from GNS, as quickly as possible, of the personal information about you and GNS has the obligation to erase this personal data as quickly as possible, when any of the reasons provided in the General Data Protection Regulation applies. 

Once GNS has made the personal information public and it is required to erase it, GNS, taking into account the available technologies and the implementation costs, shall take the reasonable measures, including technical measures, to inform the data processors processing such personal information that you have requested erasure, by these data processors, of any link to such personal data or any copy or reproduction thereof.

This right to erasure shall not apply to the extent that processing is necessary, including (a) to exercise the right to freedom of expression and information, (b) for scientific research purposes or statistical purposes, insofar as the right to erasure may make it impossible or seriously compromise the fulfilment of the processing objectives; or (c) to claim, exercise or defend legal rights.

Right to limit processing

You have the right to obtain, from GNS, a processing limitation when one of the following applies: (a) for a period that enables GNS to verify the accuracy of the personal data when you challenge the accuracy of the personal information, (b) processing is unlawful and you object to the erasure of personal information and demand, instead, a processing limitation to limit its use, (c) GNS no longer needs the personal information for processing purposes but it is still necessary to claim, exercise or defend legal rights, or (d) you object to processing during a verification aimed at knowing if the legitimate reasons sought by GNS prevail over yours.

When processing has been limited in accordance with the foregoing, the personal information, except for storage purposes, may only be processed with your consent or to claim, exercise or defend legal rights or to protect the rights of another individual or legal entity or for important reasons of public interest by a public authority authorized to do so by law.

Right to data portability

You have the right to receive the personal information you have provided to GNS, in a structured, commonly used and machine-readable format, and you have the right to transmit this personal information to a different data processor without GNS obstructing this, when processing is based on your consent and processing is carried out using automated processes.

Right of objection

You may object, at any time, for reasons relating to your particular situation, to the processing of the personal information about you that may be necessary for the purposes of legitimate interests sought by GNS or a third party or to perform a task carried out in the public interest or under the exercise of public authority vested in GNS, including profiling. GNS shall not process personal information further unless GNS can demonstrate that it has imperative legitimate reasons for processing that prevail over your interests, rights and liberties or to claim, exercise or defend legal rights.

Automated individual decisions, including profiling

You may request not to be subject to a decision based exclusively on automated processing, including profiling, producing legal effects to you or similarly affecting you significantly, unless the decision is not (a) necessary for the execution or performance of a contract between you and GNS (b) authorized by the law applicable to GNS also providing appropriate measures to safeguard your rights, liberties and legitimate interests, (c) based on your explicit consent.

To exercise any of these rights, you may submit a written request to this end by writing to the Privacy Manager at the address specified in the “Questions, comments, complaints” section below.

AMENDMENTS AND UPDATES TO THE POLICY

The content of our website may be changed at any time. Therefore, this Policy may be amended from time to time in the future. You are advised to read it each time you visit our website in order to stay informed of how we process personal data.

QUESTIONS, COMMENTS, COMPLAINTS

To contact us, ask questions about this Policy, provide feedback, submit an access or correction request, exercise any applicable rights, make a complaint or obtain information about our practices or policies, please contact our Privacy Manager at: contact@kairosgame.com