Privacy Policy

Last update: October 2^nd, 2020

This policy describes how Lanovaz Lab Inc. (“Lanovaz Lab”, “we”, “us” or “we”) collects, processes, uses and shares personal information and/or personal data about users of the iOS PA-DTI application (the “Application“).

In this policy, the term personal data refers to information about an identifiable individual.

The contact details of the data controller under this policy are as follows:

Lanovaz Lab Inc.
privacy@lanovazlab.com

1.   Basis of data processing

Our processing of personal data is mainly based on the following principles:

• We process your personal data to the extent necessary to provide you with our products and services as requested by you;
• We may process certain personal data because you have specifically given consent to the processing.

2.   The data we collect

2.1.  Information collected from you

We collect information that you voluntarily provide to us (e.g., by filling out a form) through our website, a survey, e-mail or otherwise. The disclosure of this information is not required to use the Application. This information may include :

• Your full name;
• Your email address;
• Your age;
• The age of your children;
• Your place of residence;

2.2.  Data collected from the Application

We do not collect data automatically from the Application.

When you choose to provide data through the Application, the following data will not be provided to us :

• Your username (can be a pseudonym);
• The identification number of your iPad;
• Completed programs and answers entered by users into the Application;

2.3.  Information about children

Although the Application is intended for children, we do not voluntarily collect any personal information about children. You are never required to disclose your identity or that of your children in order to use the Application.

2.4.  Collected by Youtube

The Youtube service (operated by Google) collects data when you interact with the Youtube interface from the Application, for example when you link content available on Youtube to the Application.

The Application does not allow you to log in to a Youtube or Google account, so the Youtube service (Google) only collects data related to your iPad (operating system, language, IP address, identification number, etc.). See the Google Privacy Policy at the following address: https://policies.google.com/privacy?hl=en-US for more information on Google’s practices regarding the collection of personal data.

3.   How is your data used?

We use your personal data for the purposes described below. Some uses involve data that is subject to your specific consent, while other uses are necessary to provide you with services.

3.1.  Communication with you

We use the personal data you have provided us with (e.g. your name and e-mail address) to communicate with you about your data and our services, but only if you have provided us with this data and if you agree to receive communications from us. We comply with applicable laws and regulations regarding unsolicited emails. If you no longer wish to receive electronic communications from us, you may notify us at any time by writing to us at privacy@lanovazlab.com.

3.2.  Search

Voluntarily submitted data (which may include personal data) may be used for fundamental and applied research purposes. Only anonymized data is shared for research purposes and consequently the researchers involved do not have access to your identity.

3.3.  Product Development

Voluntarily submitted data (which may include personal data) may be used on an anonymous basis to improve our products and to assist in the development of new products. For example, we may use data voluntarily submitted by our users to compile statistics on time-consuming actions in the Application in order to improve the usability of a new application.

4.   How is your data stored?

We retain the personal data collected until you request that we destroy it or until our activities no longer require us to retain it. We do not, however, make a commitment to retain the personal data collected for a specific period of time.

The personal data collected is stored electronically on servers located in Canada. These servers are operated by our service provider, Microsoft, who has made a written commitment to us to treat your personal information as confidential.

Personal data collected about individuals outside of Canada is transferred to Canada. Canada is recognized as an appropriate jurisdiction for the transfer of personal data from the European Economic Area.

5.   How your personal data is protected

Your personal data is hosted by our service provider, Microsoft, which is committed to using industry-standard security measures to maintain data integrity and confidentiality.

Our employees and suppliers are informed of the confidential nature of personal data and are made aware of the appropriate security measures to prevent unauthorized access to personal data.

6.   Disclosure of personal data

We only share your personal data in the manner described in this policy and when we have your explicit consent. Your personal data may be disclosed to the categories of persons described below for the purposes mentioned.

6.1.  Employees

Your personal information is only accessible to our officers and employees who need to access it for the purposes of this policy.

6.2.  Service Providers

We share certain personal information with service providers that allow us to provide our services more efficiently. These service providers agree in writing to maintain the confidentiality of the data and not to use it for any purpose other than to provide services to us. Our service providers are listed below:

Supplier	Details	Useful links
Microsoft	We use the Office 365 service to store data gathered from the Application on cloud servers. Microsoft agrees to use our data only to the extent necessary to provide services to us.	Microsoft Privacy information : https://www.microsoft.com/en-ca/trust-center/privacy
Sidekick Interactive Inc.	We use the services of Sidekick Interactive to carry out the development and maintenance of the Application. Sidekick Interactive may have access to personal data during development work. Sidekick Interactive agrees to use our data only to the extent necessary to provide us with its services.	Website: https://www.sidekickinterac­tive.com/

6.3.  Youtube (Google)

Google collects data about your iPad directly when you use the Youtube service through the Application. We do not have an agreement with Google regarding such collection of data and users should review Google’s privacy policy before using the Application (https://policies.google.com/privacy?hl=en-US).

6.4.  Researchers

We share anonymized data with researchers for research purposes. This data does not contain information that identifies individuals.

6.5.  Legal obligations

We may disclose personal data if expressly permitted or required to do so by law, or if we are compelled to do so by a competent authority. We will not disclose personal data unless expressly required by law.

6.6.  Transfer of business

In the event that the sale or restructuring of all or part of our company is contemplated, we may disclose personal data to the persons or organizations involved before and after the transaction, whether or not the transaction takes place. In such a case, these persons or organizations undertake to us to maintain the confidentiality of the personal data and to use it exclusively for the purpose of evaluating the feasibility or advisability of the transaction and in accordance with this policy.

7.   What are your rights regarding your personal data?

7.1.  Access your data?

To access the personal data that we hold about you or to have certain personal data that we hold about you that is inaccurate modified, you may make a request in writing at privacy@lanovazlab.com.

We will respond to your request promptly (within 30 days of receipt), allowing you access to your personal data in our files. Where required by law, we will provide your data in a machine-readable format.

7.2.  Withdrawal of Consent

If you wish to withdraw your consent to the processing of your personal data, please notify us at privacy@lanovazlab.com. If you withdraw your consent to the processing of your personal data, we will delete your personal data from our database. Insofar as personal data that you have voluntarily submitted to us is included in analysis results or is part of an anonymized data set, these data will not be affected by the withdrawal of your consent, but no further processing of your personal data will be carried out.

7.3.  Opposition

In certain circumstances, you have the right to object to the processing of your personal data by us in order to fulfill legitimate interests. Your rights in this respect depend, among other things, on your place of residence. If you wish to object to the processing of your personal data, notify us at privacy@lanovazlab.com.

7.4.  Deletion

You may request the deletion of personal data that we hold about you. To make such a request, please write to us at privacy@lanovazlab.com. We will respond to your request as soon as possible (no later than 30 days after receipt).

7.5.  Complaint

If you reside within the European Union, you have the right to file a complaint regarding the processing of your personal data with a supervisory authority. This authority varies depending on your country of residence.

If you reside outside the European Union, our processing of personal data is governed by the laws and regulations applicable in Canada and the Canadian authorities are exclusively competent to receive any complaint or claim relating to our processing of your personal data.

7.6.  Audits

We may verify the identity of persons wishing to access their personal data. Any information collected to perform this verification will not be used for any other purpose.

8.   Policy Change

We may amend this Policy from time to time to reflect changes in our personal data management practices. In the event that a change is made, the new policy will be available at the following address: https://www.lanovazlab.com/privacy/

If you have provided us with your email address, we will notify you of any material changes to our privacy policy by email within a reasonable delay before the new policy takes effect. If we process your personal data on the basis of your explicit consent, we will not process your data for new purposes without your explicit consent.

9.   Additional Information

For any additional information concerning the processing of your personal data, you may contact us at the address indicated at the beginning of this policy.