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Effective Date: October 15, 2024

Introduction

Welcome to Promed, an application provided by PROMED AI INC. We provide evidence-based education and recommendations of preventative health to help you improve awareness and health. We value your privacy and are committed to protecting your personal information. This summary provides a brief overview of how we collect and process your data. For detailed information, please read the full Privacy Policy below.

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Your rights as a user of our services

You have the right to access, correct, or delete your personal data at any time. You can withdraw any consent you've given us and object to certain types of data processing. For any personal data-related inquiries, please contact us at contact@promedai.ca.

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Data we collect about you

We collect personal information to provide you with the best possible experience when using our application and to deliver our core services. The types of data we collect include:

• Registration Information: When you sign up for Promed, we collect the information you provide during registration, such as your email, password, and other authentication-related information to create your account. You may have the opportunity to provide additional information voluntarily such as your name, telephone number, and billing address.

• Health Information: You may choose to voluntarily share certain health-related information with us under your consent. This may include data related to your health and wellness goals, lifestyle information such as exercise and diet, height and weight, and other metrics that help us provide personalized, preventative health recommendations and education. Where feasible, we de-identify or aggregate health data so that it cannot reasonably be used to identify you personally. Please note that you can still use our application and most of its services without providing this information.

• Profile and Demographic Information: Through your account in Promed, you may voluntarily provide additional information about yourself under your consent, such as your age, sex at birth, and details about your health history and perceived health risks. To protect your privacy, we use de-identified or aggregated forms of this information for analyses and insights that help improve the app’s recommendations. Note that you can still use our application and most of its services without providing this information.

• Payment Information: If you make a purchase, you may be required to provide your payment card information. Please note that we do not directly process payment card information, and instead rely upon third-party payment processors such as Stripe to do so on our behalf. Personal information collected for these purposes includes card number, type, expiration date, and billing address, and certain anonymized, limited, and/or truncated versions of this information may be provided to us. You can still use our application and most of its services for free.

• Communication Information: When you send or respond to emails, or other communications from us, we may collect your email address, name, and any other personal information you choose to include in the body content of your communications. In addition, when you interact with certain features of our application, we may collect the content of those communications.

• Cookies and Cookie Policy: To provide a better user experience, we use cookies for data collection and storage. Cookies are small data packets stored on your device that do not cause any harm. We collect cookies in the following categories: (1) Necessary technical or functional cookies: These cookies make the services usable by enabling basic functions ensuring the services function as intended. (2) Preference cookies: These cookies remember your preferences to personalize your experience. (3) We do not collect cookies for analytics nor third-party marketing.

• Personal Data of Children: We do not knowingly collect personal information from children under 167 years of age. If we learn that a child under 17 has provided us with personal data, we will delete that information as quickly as possible. If you believe that a child under 17 may have provided us with personal data, please contact us at contact@promedai.ca.

 

How we collect your data

We collect your data in three different ways:

• Automated Collection: Certain information is collected automatically when you use our application, such as the date you access certain feature.

• Through Cookies: Cookies help us gather data that enhances your experience with our application.

• Voluntary Input: You provide data directly to us when you register or enter information within the application, such as sharing details and answering surveys.

Please note that we do not collect information related to your IP address, device details, or any wearable data. Our focus is on maintaining the privacy and security of the information you voluntarily share with us.

 

What we use your data for

We use your personal data to provide, improve, and personalize the services offered by Promed, including:

• Nutraceutical Recommendations: To offer personalized nutraceutical recommendations based on the health information you provide voluntarily and evidence from literature.

• Preventative Suggestions: To provide you with suggestions for checkups, vaccinations, and other preventative measures based on official guidelines and health information you provide voluntarily.

• Health Education and Information: To deliver preventative health education and information tailored to health information you provide voluntarily. For example, suggest preventative measures according to health guidelines.

• Health Analysis and Explanations: To analyze health information you provide voluntarily and provide evidence-based explanations and education.

• User Support: To provide support and assistance, address any questions or issues, and communicate with you.

• Payments and Orders: To process payment, manage your orders, deliver your purchased products, and account for applicable sales taxes.

• Use of your data for other purposes: In addition to the purposes already mentioned, we are also subject to legal requirements, such as: (1) Any request for information (and the related disclosure) to governmental authorities. (2) Any request for information (and the related disclosure) to copyright holders. (3) For the misuse recognition of our provided services. (4) Troubleshooting or avoidance.

We are committed to using your data only for the purposes stated above and ensuring that your privacy is respected at all times.

 

Sharing of personal information

We collaborate with trusted third-party providers whom we may disclose your personal information to. This is exclusively regulated by data processing agreements and the processing is instruction-bound, so that we always keep the responsibility for the processing:

• Our Service Providers: In some circumstances, we may need to disclose your personal information to a third party so they can provide a service on our behalf, such as to help deliver Products or Services that you have purchased. These service providers may include services such as analytics, payment processing, product delivery, advertising and marketing, and other services. Our service providers have access to your personal information only to perform these tasks on our behalf, based on our instructions, and are contractually obligated to maintain the confidentiality and security of your personal information.

• Compliance and Harm Prevention: If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceeding, similar legal process, or to enforce our agreements with you, or to protect the rights, property, our customers, or others.

 

Data security and retention

The security of your personal information is important to us. We follow generally accepted standards, practices, and procedures to protect the personal information submitted to us, both during transmission and once it is received. We maintain appropriate technical, administrative, and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure, or misuse.No security can be fully guaranteed, though. If you have an account with us and you suspect unauthorized use of your account or its credentials, you should contact us immediately at contact@promedai.ca.We will keep your personal information for as long as needed to perform our obligations to you, or for as long as legally permitted. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you.

• Whether there is a legal obligation to which we are subject.

• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). For example, we keep your account information, like your name, email address, and password, for as long as your account exists so that you may access it.

 

Your privacy rights

We believe that you should have control of your personal information. To that end, we provide the following rights to make requests regarding your personal information. You may make these requests by contacting contact@promedai.ca.

• Access: You have the right to know what personal information we collect about you and how we use it. This Privacy Policy serves to inform you about that collection and use. If we have personal information about you, you may also request a copy of that information.

• Correction: You have the right to request the correction of your inaccurate personal information.

• Portability: You may request an export of your personal information in a structured and machine-readable format such as a .csv or .pdf. Where feasible, we can send that export to a third party you identify.

• Deletion: You have the right to request, under certain circumstances, the deletion of your personal information that we collect.

• Restriction: You have the right to request that we restrict the use of your personal information in certain circumstances. Please note that in some cases we may not be able to place a restriction due to the use being necessary for Product functionality or delivery of the Services.

• No Retaliation or Discrimination: You have the right not to receive discriminatory or retaliatory treatment for making a request.

 

Additional Information

 

General and Responsible Entity

PromedAI Inc. ("we," "us," or "our"), based at 151 CHARLES ST W UNIT 199 KITCHENER, ON N2G 1H6 CAN, is responsible for collecting and processing your personal data when you use the Promed application ("the App" or "Services"). This detailed privacy policy explains how we collect, use, and protect your information while using our services.

 

Revocation of Consent

Many of the data processing operations that we perform are based on your consent. You have the right to revoke this consent at any time, without affecting the legality of the processing that occurred based on your consent before revocation. If you wish to revoke your consent, please send us an email at contact@promedai.ca. Upon receiving your revocation, we will stop processing your data for the purposes for which consent was originally given. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

 

Right to Complain to the Competent Supervisory Authority

If you believe that your data has been processed unlawfully or that your rights under applicable data protection laws have been violated, you have the right to lodge a complaint with the competent supervisory authority. You may contact your local data protection authority or the Office of the Privacy Commissioner of Canada (OPC) if you are in Canada. We encourage you to first contact us so we can address your concerns and attempt to resolve the issue in a satisfactory manner.

 

SSL or TLS Encryption

We take the security of your data very seriously. To protect the transmission of sensitive information, we use SSL (Secure Socket Layer) or TLS (Transport Layer Security) encryption. If SSL or TLS encryption is enabled, the data that you transmit to us is protected against unauthorized access by third parties.

 

No Data Selling Policy

We are committed to protecting your privacy. PROMED AI INC. does not, and will never, sell your personal data to third parties. Our priority is to provide you with a personalized, secure, and trustworthy experience without monetizing your personal information.

• No Selling of Personal Data: We do not sell, rent, or trade any personal information you provide to us, including but not limited to your health information, contact details, and usage data, to any third parties for commercial purposes.

• Purpose of Data Collection: The personal information we collect is solely for providing, improving, and personalizing our services, and for essential operations like customer support and security enhancements.

• Data Sharing with Trusted Partners: In cases where we work with trusted service providers to deliver specific services (such as payment processing or product delivery), these providers are bound by strict data protection agreements that prohibit them from using your data for any purpose outside of what we’ve requested.

• Commitment to Privacy: Our No Data Selling Policy is part of our broader commitment to respecting your privacy and protecting your personal information. We uphold this policy in compliance with all applicable privacy laws and regulations, and relevant international standards.

 

De-identification of health data

We take measures to protect your privacy by de-identifying health data where appropriate. De-identification involves removing or altering personal identifiers so that the information cannot reasonably be used to identify you.

• We take measures to protect your privacy by de-identifying health data where appropriate. De-identification involves removing your personal identifiers so that the information cannot reasonably be used to identify you.

• De-identified data may be used for health analysis and education. For example, we might analyze your health data to provide better recommendations.

• We use industry-standard techniques for de-identification, including removing direct identifiers (such as your name, email address, or account information) and generalizing specific data points to ensure that the data cannot be linked back to you.

• We do not attempt to re-identify de-identified data, nor do we share it in a way that would allow third parties to re-identify it.

 

Information, Correction, Deletion, Blocking, Data Transferability

You have the right to request information about the personal data we hold about you at any time. You can also request the correction of inaccurate information, deletion of your personal data (unless it is required for legal reasons), blocking of data processing in certain circumstances, and data transferability, meaning the right to receive your data in a structured, commonly used, and machine-readable format. To exercise these rights, please contact us at contact@promedai.ca.

 

Right to Object

If your personal data is processed based on legitimate interests, you have the right to object to this processing at any time for reasons arising from your particular situation. You can also object to the processing of your personal data for direct marketing purposes. If you wish to exercise your right to object, please contact us at contact@promedai.ca.

 

Right to Opt-Out

You have the right to opt-out of certain data processing activities by contacting us at contact@promedai.ca

• Marketing Communications: We do not send any marketing communications to our users.

• Analytics Tracking: If you do not want us to use your data for analytics purposes, you can contact us for further instructions.

• Cookies and Tracking Technologies: You can manage your cookie preferences by adjusting the settings on your device. If you disable cookies, some features of the app may not function properly.

• Health Data Processing: If you choose not to share health-related information, you can still use most features of our app. You may also request deletion of specific health data by contacting us.

 

Address Do Not Track

• Handling of Do Not Track Signals: We do not track your online activities across different websites or apps.

 

Server Log Files

Our servers automatically collect and store information in log files when you use the App. This may include anonymous data such as app usage statistics, timestamps, and general error reports to help us maintain the functionality of our services. This information is not linked to individual users and is used solely for technical troubleshooting and service improvement.

 

Registration on this App

To use the full range of services provided by Prome, you must register within the App. During registration, we collect personal information such as your name and email address. This information is necessary for us to create your account and provide our services to you. We will use your registration information only for the purpose of offering and improving our services and communicating with you.

 

Payment Information

When you choose to make in-app purchases of physical goods, payments are processed through Stripe:Stripe Inc., 185 Berry Street, Suite 550, San Francisco, CA 94107 (USA)We do not collect or store your credit card information. Stripe is a PCI-compliant payment provider that securely handles payment data, ensuring that your financial information is protected. If you have any questions regarding payment security, please refer to Stripe's privacy policy for more information. We have entered into "Data Processing Agreements" with Stripe, in which we commit Stripe to protect the data of our customers, to not disclose them to third parties and to comply with the provisions of the standard contractual clauses according to Art. 46 GDPR in the case of a transfer of personal data to the USA.

 

Hosting & Analysis

To provide our services and ensure optimal performance, we use trusted third-party services for hosting and analytics. Our hosting and analysis partners help us understand user behavior, troubleshoot issues, and enhance our services. These partners are required to protect your data and comply with applicable data protection regulations.Google Cloud Platform: We use cloud services operated by Google Cloud Platform (a developer platform operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) and its parent company Google LLC (1600 Amphitheatre Parkway, Mountain View, California 94043 USA), for hosting and analytics purposes. We use services such as hosting, cloud storage, access control, and real-time analytics to improve services, monitor app usage, and enhance the user experience. Data processing is carried out based on our legitimate interest in providing a technically error-free and optimized user experience. Data collected is encrypted using TLS/SSL and stored securely to ensure protection from unauthorized access. We have entered into a "Data Processing Agreement" with Google, which obligates Google to protect your data and comply with applicable data protection regulations.

 

California Privacy Rights

We take the data protection regulations of the California Consumer Privacy Act ("CCPA") and the California Civil Code seriously and respect the resulting rights for California residents as stated in the following paragraphs. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

 

Shine the Light / Opt-out

California residents have the right to request information about their personal data that we have shared with third parties once per calendar year and to request that this data be deleted by us. Additionally, California residents have the right to opt out of the disclosure of their personal data to third parties ("opt-out"). To exercise the right to information, deletion, or opt-out, please send an email to contact@promedai.ca along with proof of identity and place of residence. We will respond to verified requests within 30 days. California residents also have the right to opt-out of the sale of their personal data. We do not sell personal data.

 

Purposes of data processing of California residents

We collect and process personal data of California residents only for the purposes stated in this privacy policy, particularly to provide our services in a technically flawless manner, analyze user behavior to optimize our offerings, and enhance our marketing. We do not sell personal data of California residents. We only share data for business purposes as stated in this privacy policy.

 

Categories of personal data of California residents

We collect and process personal data from California residents that is provided to us directly or through interactions with our services. This includes the following categories: (i) personal data (e.g., name), (ii) identifiers (e.g., name, email address), and (iii) information about activities on the App. The categories of third parties with whom we may share California residents' personal data include: (i) analytics and hosting providers, (ii) payment service providers. We do not knowingly disclose personal data of minors under 16 years of age to third parties.