Privacy Policy

This version is current since March 26th, 2020

Introduction

The purpose of this Privacy Policy is to inform you of the nature of the information collected, used and potentially disclosed by the Company, and to inform you of the purpose of the collection of this information. By using Therappx’s COVID-19 platform (hereinafter the "Platform"), 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 can not use the Platform and must stop using it immediately.

Collected Informations

As a user, when using the Platform, you do not need to create a profile. We track IP addresses, browser fingerprints and user agents for analytics purposes using Heap Analytics. You can provide your email address if you want to get notified when new Digital Health Tools (hereinafter "DHT") will be made available in your region.

To be matched with a DHT, you provide the Company with your location, your preferred language, your preferred device, your operating system, your present needs in terms of DHT functionalities and other general information about your health. We collect and store this information for analytic purposes. This information, like any information that you may be required to communicate in the future on the Platform (medical history, medication, history of the disease, PHI number), are confidential and treated as such.

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 [email protected].

Shared informations

All information collected from a user is stored on secured servers in Canada.

The Company will at all times comply with applicable laws in Canada when using or disclosing your information. In addition to the persons and organizations listed below, your information will not be passed on to anyone unless the Company is legally and/or legally obliged to forward it to a competent authority. In all cases, these parties are subject to the same obligations as the Company under this Policy.

Access to this information is granted to:

  1. Platform administrators to effectively use the Platform, for example to communicate with users and/or improve the service offered;
  2. to a prospective purchaser and any organization involved in a transaction involving the sale or transfer of some or all of the assets of the corporation, in which case the use of your information by the new entity would continue to be subject to applicable law and fully comply with this Policy;
  3. to researchers and governments in order to improve local services and knowledge about pandemic-induced illnesses;
  4. to any organization when the Company has reasonable grounds to believe that the information may be relevant to an investigation of an illegal activity and/or to comply with a subpoena writ, warrant, order made by the court or to comply with the rules of the court with respect to the production of records and information and/or to protect the rights and property of the corporation;

Agglomeration of data

In regards to the agglomeration of data of the Platform and the use of this data for commercial prospecting purposes or continuous improvement purposes, the Company reserves the right to:

  1. disclose on the Platform, in communications or commercial prospecting the nature of functionalities seek by users, demographics of users and matched DHT in order to promote the Platform. In this case, the Company undertakes not to reveal the identity of the user who used the Platform;
  2. provide third parties with agglomerated user and Platform usage data (e.g. number of matched DHT, number of monthly active users, etc.) to provide an indication of the interest generated by the Platform. In this case, the Company undertakes not to reveal the identity of the users who used the data agglomeration;
  3. send you electronic communications through the email address provided by users. At any time, you can ask us to stop sending by contacting [email protected];
  4. use the analytics technology provided by Heap to measure certain aspects of our Platform (number of page views, visitor activity, user flow, etc.).

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 and/or required by law. After this period, the Company agrees to securely delete all your information stored.

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 mandated by the Company. This organization has obtained ISO 27001 certification and completes annual SSAE16 / ISAE 3402 Type II audits. However, all information is the sole property of the Company 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. In the event that 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 has been 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 and 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

In the event that a DHT found on the the Platform contains a hyperlink that takes you to another site, this Policy does not apply to it.

This Policy may be changed by the Company 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 in order 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 [email protected].