I-Quantify and I-Engage Software

Intronix Technologies Corporation Software Privacy Policy

Version 2.0 September 19, 2021

We, at Intronix Technologies Corporation (“Our”, “We” or “Us”), are dedicated to maintaining both a high standard of privacy and a high standard of data protection in all of our activities.

This policy, based on the standard required by the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Health Information Protection Act, 2004 (Ontario), is Our interpretation of these responsibilities.

Additionally, we comply with the Health Insurance Portability and Accountability Act (HIPAA) which sets the standard for sensitive patient data protection. We deal with protected health information (PHI), have physical, network, and process security measures in place and follow them to ensure HIPAA Compliance.

1. What is Personal Information?

Personal information is information about an identifiable individual. This, however, does not include information, which is anonymous, i.e., where the identifying data fields are removed.

2. Accountability

You may contact our privacy officer at support@intronixtech.com.

All contractors and other third parties with whom we have a contractual arrangement and with whom we share personal data are contractually obligated to ensure that their practices meet our standards and are fully compliant with PIPEDA and other applicable privacy legislation.

3. Purpose

Our primary business is to help you keep track of your pain episodes and to enable you to share that information with your health care providers or any other third party with whom you decide to share your information through our I-Engage,I-Engage Web, I-Quantify, or I-Quantify-W software (the "Software"). All personal information that you may provide to us is voluntary and you are, at no time, required or obliged to provide any information.

However, please note that for security purposes and to improve our software as well as to determine user insight in to the use of the Software, we may collect some information from your device which includes error reporting; general usage statistics; device information; app version; and time stamps.

Further, Personal information may be gathered from you and be used in the following situations:

• If you visit our website, the web server logs IP addresses and associated information relating to the requests made;
• If you make an inquiry or complaint, apply for a job, or visit the premises;

Please note that when you sign up for an account, we will also collect information such as pain, spasticity, capability records; profile information (e.g. medications, pain conditions, name, birth date, height, weight, gender, GPS location); account information (e.g. user name, password, email address); application preferences; change-logs; cookies or other passive tracking mechanisms and tools to collect information in order to facilitate your use of the Software; and any other information that you may voluntarily supply to us.

Finally, regardless as to how and from whom we collected information, we will not sell nor share your personal information to any organization for any purpose unless you explicitly direct and authorize us to do so. All the personal information that you provide to us will, at all times, be your information and you will be, at all times, remain and be the custodian and controller of your personal information.

4. Consent

We, pursuant to the Purpose, do not require any of your personal information other than as set out above for security reasons. Therefore, any personal information you share with us is completely voluntary.

Even after you have shared personal information with us, you may withdraw consent for the further use of the personal information at any time, by contacting our Privacy Officer at support@intronixtech.com.

5. Collection and Use

Your personal information may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country, which restricts data transfers outside of that jurisdiction or region without your consent, by using our Software, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of us.

Data storage for Canadian and “other” country-based users will be located in Canada.  Data storage for American users will be located in the USA.

This section lists the data elements that are most commonly collected and used in connection with the use of our Software:

Online Account:

• Records, including pain, spasticity, and capability (e.g. location, associated symptoms, characteristics, timing, severity)
• Profile information (e.g., medications, conditions, name, birth date, height, weight, gender, place of residence)
• Account information (e.g, user name, password, email address)
• Application preferences
• Cookies or other passive tracking mechanisms and tools to collect information in order to facilitate your use of the Software
• Any other information that you may voluntarily supply to us

Visitors:

• While we do not identity individuals visiting our site, we may use session cookies to ensure a smooth and convenient site visit
• The previous page visited prior to accessing our web page is automatically logged by the servers to collect aggregate statistical data from where traffic originates

6. Disclosure of Personal Information

Our business is to help you keep track of your episodes and enable you to share that information with your health care providers, or any other third party with whom you decide to share your information. We do not use personal information for marketing purposes, and do not share or disclose personal information to other parties unless specifically stated in this policy.

We may collect and disclose aggregated non-personal information from all users of the Software relating to, for example, visual scale and questionnaire records, age, geographic location, and gender. All such information will be stripped of all personal information so that it cannot be recompiled and individual users identified. We collect and aggregate this kind of information in order to determine how the Software is being used, how it and other products and services can be improved, and to share the aggregated information to third parties so that they can use the information for improvements of their own products and services such as healthcare providers, insurance companies, pharmaceutical companies, and pain researchers.

We may share non-personally identifiable aggregate data with vendors who assist Us in providing Our Software; with third party business partners with whom We provide joint promotions; with Our affiliated companies, including any parent or subsidiaries of Us; and We may share aggregate data if We believe it is necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.), or other legal requirements of any governmental authority; if We believes it would potentially mitigate Our liability in an actual or potential lawsuit; if We believe it is permitted by law or if doing so will not violate the law; or if We believe it is otherwise necessary to protect Our rights or property; or is necessary to protect the interests of other users of the Software. In the unlikely event that all or part of Our business is sold or acquired by a third party, We will transfer such information to the new business owner.

7. Cookies, Pixels and other Usage Data

We may use “cookies” (a cookie is a small data file that is kept in your device’s memory for record-keeping purposes), and/or other storage on your device to help us collect, maintain, and use this information, for two purposes. To make the interactions easier and more personalized for you, we may utilize persistent cookies to save information relating to your Account and/or activity for future interactions with our services.  At any time, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please understand that if you do not accept cookies, you may not be able to use all portions or all functionality of Our web site. We may also use data collection tags or directives such as “pixel tags,” Javascript scripts, API calls, or similar means (individually or collectively, “Usage Tracking”) in combination with cookies and the demographic or psychographic data we have collected, and with third-party analysis partners, to analyze usage patterns of users anonymously. A pixel tag is an electronic image, often a single pixel and often transparent, that is placed on a web page and may be associated with cookies on your hard drive. Usage Tracking allows us to count users who have visited certain web sites and pages within web sites, or used applications or features, to analyze the behavior of users of our web sites and application, in order to improve the web sites and application, and to personalize and determine the effectiveness of promotional or advertising campaigns.

8. Accuracy and Retention

If you think we have information about you that is not accurate, you are encouraged to contact us at the address provided in section 11 of this policy and indicate the necessary changes. We may require that you follow certain procedures that are utilized by us for the authentication and verification of your identity.

We retain information according to retention schedules, which depend on the purpose of the information and any legal or contractual requirements with which we might need to comply.

9. Safeguards

It is important that the information maintained by us on behalf of you is accurate, protected from interference by other parties, and treated in confidence by as few personnel as necessary. We maintain technical and administrative safeguards to manage our systems and data.  While we cannot guarantee that loss, misuse or alteration of data will not occur we use commercially reasonable efforts to prevent any such occurrence. It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.  If you detect any anomalies that might lead you to believe there has been a security infraction or hacking of our system, we will be pleased to investigate.  All data is password protected on the device used. A secure socket layer tunnel is used to stream data to the cloud storage. Storage of all data in electronic format is on Microsoft Azure Cloud, protected by firewall and multiple layers of operational and physical security to ensure the integrity and safety of data including: HIPAA/HITRUST Health Data and AI to securely ingest, store, analyze, and interact with health data while being able to meet industry compliance requirements.

10. Access to Information

The intention of this policy is to answer your questions about our privacy policy and practices. Should you be interested in more detailed information about our procedures and practices, please contact us at support@intronixtech.com

Should you wish to access your own personal information, please write to our privacy office at support@intronixtech.com. At the time of your request, we may need further information from you to verify your identity, before we can provide you with the personal information we hold.

There may be instances when we will not be able to provide you with the personal information that you request. For example, if the personal information:

•  Contains references to other persons
•  Has already been destroyed due to legal requirements or because we no longer needed it for our purposes
•  Is subject to solicitor-client or litigation privilege; and/or
•  Cannot be disclosed for other legal reasons 

11. Feedback and Complaints

We take privacy seriously and consider that our treatment of personal information is part of the service that we offer. Please contact us at support@intronixtech.com  if there are any questions.

If you are interested in more information about the Personal Information Protection and Electronic Documents Act, the Office of the Privacy Commissioner of Canada has detailed information on their website at http://www.privcom.gc.ca.

We take security and privacy seriously.  We are confident in our technical and administrative safeguards to ensure your data remains protected.

While we are a Canadian based company, we do follow the guidelines put forth by the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Health Information Protection Act, 2004 (Ontario) as well as the Health Information Trust Alliance (HITRUST) that allows healthcare providers to comply with the Health Insurance Portability and Accountability Act (HIPPA) security laws.

If you have any concerns, please reach out to the privacy officer at support@intronixtech.com