1. YOUR PRIVACY
2. WHAT CONSTITUTES PERSONAL INFORMATION
Personal information is any information about an identifiable individual, but may not include certain business contact information used for employment, business or professional purposes.
3. CONSENT, AND WITHDRAWAL
Aycoutay shall seek your consent to collect, use and share your personal information, to the extent required by law. Aycoutay will assume you consent to us using and sharing your personal information, as permitted by law, if you choose to provide such personal information to Aycoutay for reasonable purposes associated with our Offerings. You can withdraw your consent at any time by using your Aycoutay account settings (if available), or the mechanisms set out at Aycoutay’s website, or you may contact our Privacy Officer as indicated below in this Policy.
4. PERSONAL INFORMATION WE COLLECT
When you use our Offerings, we may collect the following types of personal information:
Information You Provide to Us
Basic Account Information
Some personal information is required to create an account for our Offerings, such as your name, email address, password, and your telephone number. You may also choose to provide other types of information when you register with us.
To help improve your experience or enable certain features of the Offerings, you may choose to provide us with additional information, such as your health history, habits (e.g. regarding food, sleep, exercise and other activities), health conditions and limitations, medications, performance history (athletic or otherwise), symptoms, activity levels, training levels and routines, desired outcomes, and other information you may choose to provide.
Payment and Credit Card Information
Some Aycoutay Offerings require payments by credit card or other electronic means. If you process such payments with us, you will be required to provide certain information for identification and verification, such as your name, credit, debit or other card number, card expiration date, and 3 digit security code.
Information We Receive From Your Use of Our Devices and other Offerings
The Aycoutay devices collect electrical signals and other information from your body to assess your health and performance, and this information is then interpreted by the devices to generate further data and assessments about you (collectively your “Health Data”). The Health Data collected varies depending on the manner and extent to which you use the Aycoutay devices.
When you use our Offerings, we will also receive usage data. This includes information about your interaction with the Offerings, for example, when you view or search content, create or log into your account, pair a device to your account, or open or interact with an Aycoutay device.
We also collect data about the devices and computers you use to access the Offerings, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.
5. HOW WE USE INFORMATION
We use the personal information we collect for the following purposes:
Provide and Maintain the Offerings
We use the personal information we collect to deliver the Offerings to you. For example, we need to use your information to provide you with your Aycoutay results and assessments which may guide you as you consult with your own health, performance and other personal advisors, and to give you any required customer support.
Improve, Personalize, and Develop the Offerings
We may also use the information we collect to improve and personalize the Offerings and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Offerings.
We also use your information to offer you more relevant content about your assessment and the potential choices you may consider in respect of health, wellness, performance, training, habits, goals and other personal choices.
Communicate With You
We use your information when needed to send you notifications about our Offerings and respond to you when you contact us. We also use your information to promote new Offerings that we think could interest you. You can control marketing communications and most service notifications by using your notification preferences in account settings (if available), or by unsubscribe functions in communications or at our websites.
Promote Safety and Security
We use the information we collect to promote the safety and security of the Offerings, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
6. HOW INFORMATION IS SHARED
We do not share your personal information except in the limited circumstances described below.
When You Agree or Direct Us To Share
You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account, with your employer when you choose to participate in an employee wellness program, or, with your trainer or health professional who is working with you. Remember that their use of your information will be governed by their privacy policies and terms
For External Processing
We transfer information to our corporate affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payment processing, sales, marketing, data analysis, research, and surveys.
For Legal Reasons or to Prevent Harm
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Offerings or the physical safety of any person.
Our policy is to notify you of any legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiry of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.
We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about use of our Offerings, and to our business partners.
If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and will notify our affected customers upon transferring any personal information to a new entity or as otherwise required by law.
7. EDITING OR DELETING DATA
Your account settings (if available) let you change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish. You may also contact our Privacy Officer as indicated below for this purpose.
If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, such as the data recorded by your Aycoutay device and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm.
If you object to the use or sharing of your information, you may opt out and unsubscribe by adjusting your accounts settings (if available), by using the unsubscribe and opt out functions in our communications or at our websites, or you may contact our Privacy Officer as indicated below in this Policy.
If you are seeking access to certain information, please be aware that Aycoutay may not be able to provide access to information that is protected by lawyer-client privilege, constitutes confidential commercial information, was collected in respect of the investigation of a breach of an agreement or of law, or is generated in respect of dispute resolution, or that otherwise may be withheld as permitted or required by law.
8. PERSONAL INFORMATION RETENTION
We keep your account information for as long as your account is in existence as required to operate your account. In some cases, when you give us information for a feature of the Offerings, we delete the data after it is no longer needed for the feature. We keep other information, like your health and performance data, until you use your account settings or tools to delete the data or your account, so we can provide you with your personal statistics and other aspects of the Offerings. We also keep information about you and your use of the Offerings for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described above in this Policy.
9. INFORMATION SECURITY
10. INTERNATIONAL OPERATIONS AND DATA TRANSFERS
We operate internationally and transfer information to the United States and other countries for the purposes described in this policy. Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create an Aycoutay account.
11. LINKS AND OTHER ASSOCIATED SITES/PLATFORMS
12. WHERE AND HOW TO CONTACT US
If you wish to file a complaint, make an inquiry regarding or obtain access to your personal information that we may hold, or have questions about our policies and practices with respect to our service providers, including any collection, use, disclosure or storage of personal information by our service providers in certain territories, please contact us at the address below.
Aycoutay Technologies Inc.
1592 Barrington Street, 5th Floor, Halifax NS B3J 0C7
Attn: Privacy Officer