Privacy Policy

Last Updated: March 8, 2026

1. Introduction

Semperform Innovation Inc. (hereinafter "Semperform", "us", "we", "our") is a software development company and, inter alia, the owner of HURT BLOCKERTM, an ACL tear prediction app (hereinafter the “HURT BLOCKER app”). This privacy policy (hereinafter the "Policy") explains how we collect, use, store, disclose and otherwise process Personal Information (as defined hereinafter) relating to individuals who use our products, services, website and applications, (hereinafter individually referred to as “you”), other than our employees or contracted staff, whose information is governed by a separate internal policy.

We are committed to preotecting Personal Information with care and in compliance with this Policy and applicable privacy laws.

2. Types of Personal Information

This Policy applies to Personal Information in any form or medium, including written, digital, audio, video, recorded or otherwise.

We define “Personal Information” as any information about an identifiable individual or information that, alone or combined with other data, can identify an individual. Depending on your interactions with us, Personal Information may include, without limitation:

  • first and last name;
  • date of birth;
  • home address, phone number and email address;
  • preferred language and time zone;
  • financial, credit, billing, and account information;
  • usage details obtained from our Website or App through cookies or similar technologies;
  • Internet protocol (IP) address, browser type, locale preferences, mobile carrier; and
  • any other Personal Information provided

3. The Purposes for Collecting Personal Information

We collect Personal Information for the following purposes:

  • to provide, operate and maintain our products, services and the HURT BLOCKER App;
  • to develop, enhance, and manage our business, operations, and user experience;
  • for marketing, advertising, and communications with you (subject to applicable consent requirements);
  • for analytics and statistical purposes relating to the use of our Services;
  • to improve, troubleshoot, personalize, and optimize our Services;
  • to respond to inquiries or manage interactions with you;
  • to evaluate employment applications;
  • to comply with legal, regulatory, and risk‑management requirements;
  • for any purpose permitted or required by law; and
  • for any other purpose for which you have provided your consent.

4. Means by which we Collect Personal Information

We generally collect Personal Information when you interact with us, sign up for an account, use our services, communicate with our support team or submit information voluntarily. We also collect Personal Information from a number of independent sources, such as social networks, our service providers or other business partners.

We additionally collect, passively using cookies, a limited amount of Personal Information when you use the HURT BLOCKER or our Website. Cookies are small text files or strings that a website can send to your device to identify your web browser and the activities of your computer. This mainly consists of IP address, type of operating system, pages visited, requests made, dates and times of connections. Cookies help us improve our products, services and Website.

The use of cookies does not allow us or our analysis service providers to identify you specifically. Furthermore, it does not give us access to your device or any other information about you, other than the data you choose to share with us. The use of cookies can be accepted through the cookie banner displayed when entering our Website or using the HURT BLOCKER app for the first time. Please note that if you choose not to accept cookies, you may not be able to access or fully experience the interactive features of our Website or the HURT BLOCKER app, as applicable.

5. Outsourcing, Storage and Transfers of Personal Information

We may disclose the Personal Information we have collected to third parties in the following circumstances:

  • to service providers assisting us in delivering our Services;
  • to comply with applicable laws, regulations, court orders, law enforcement requests, or national‑security requirements;
  • to protect our rights, enforce contracts, or mitigate damages;
  • to protect the safety or security of our Services or the public;
  • in connection with a business transaction such as a sale, merger, transfer, or financing involving SSP or its assets; and
  • for any other purpose to which you have consented.

If you are a Quebec resident, note that your Personal Information may be transferred to places outside Quebec. Indeed, we call upon service providers located outside of Quebec to carry out specific mandates in the normal course of business. Furthermore, your Personal Information may be stored in data centers located in Canada or elsewhere.

When Personal Information is transferred outside Québec or outside your jurisdiction, we use contractual and other safeguards to ensure a level of protection comparable to that required under applicable privacy laws.

6. Your Consent under this Policy

We will not collect, hold, use or disclose your Personal Information without your consent unless it is authorized or required to do so by applicable law.

By submitting your Personal Information, using our Website, the HURT BLOCKER app or our products and services, you consent to the practices described in this Policy.

If you provide Personal Information concerning another individual to us, you represent that, prior to submitting such information, you have obtained the necessary consent or authority to permit us to collect, use and disclose such Personal Information for the purposes set out in this Policy, or the collection, use and disclosure is permitted by applicable law.

You may vary or withdraw your consent to the use and disclosure of your Personal Information, or opt-out of certain uses and disclosures, subject to legal and contractual restrictions as well as applicable law. Please note that the withdrawal of your consent may prevent us from providing or continuing to provide our products and services or access to our Website.

If you require any assistance in understanding the scope of the consent being sought or to vary or withdraw your consent, please contact our Privacy Officer using the contact information in Section 13.

7. Your Rights

You have the following rights regarding your Personal Information:

  • Access: request an electronic or physical copy of your Personal Information.
  • Correction: request correction of inaccurate, incomplete, or outdated Personal Information.
  • Deletion: request deletion of Personal Information where appropriate (e.g., no longer necessary, unlawfully collected).
  • Change or Withdrawal of Consent: withdraw or modify your consent for future processing.

We may request additional information to verify your identity before processing your request.

If the Europe or United Kingdom privacy laws apply to you, please review Section 12.2 of this Policy. If California, Virginia, Colorado, Connecticut or Utah privacy laws apply to you, please review Section 12.3 of this Policy.

8. How we Safeguard Personal Information

In order to protect the Personal Information that is in our possession, we employ administrative, physical, and technological safeguards which are appropriate to the sensitivity of the Personal Information provided. These safeguards also prevent the accidental or unlawful destruction, loss, unauthorized alteration or disclosure, access, or misuse of the Personal Information in our possession. We follow generally accepted industry standards to protect the information that is provided during its submission and once it has been received. These include measures to deal with any suspected data breach.

Once communicated, the Personal Information is kept in an electronic file within our document management system or third-party technologies used by us, or both. Only those personnel who reasonably require the Personal Information to perform their duties are granted access to the information and they are bound by a duty of confidentiality.

It is important to note that, despite our best efforts to protect your Personal Information, there is a risk associated with the communication, exchange and storage of information, as no form of electronic transmission or storage is perfectly secure. SEMPERFORM ASSUMES NO RESPONSIBILITY FOR THE DESTRUCTION, LOSS, UNAUTHORIZED ACCESS OR DISCLOSURE, OR ALTERATION OF PERSONAL INFORMATION, NOR FOR ANY DAMAGES SUFFERES AS A RESULT.

9. Links to Third-party Websites and Services

Our services, products and Website may contain links to third-party websites or services that are not owned or controlled by Semperform. This Policy only applies to information collected by us for the purposes mentioned in Section 3 above. We have no control over these third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Website.

10. Personal Information of Children under 14

Our products and services are not directed at or intended for use by children, nor do we knowingly collect Personal Information from children under the age of 14. If you are a parent or guardian and become aware that your child has provided us with Personal Information without your consent, please contact our Privacy Officer using the contact information in Section 13.

11. Retention and Destruction of Personal Information

The Personal Information we collect is retained for varying periods of time depending on the type of information in question and the purposes for which it is collected and used. Subject to a retention period provided for by applicable law, the Personal Information we hold is destroyed or anonymized to use for serious and legitimate purposes once the purpose(s) for which it was collected or used (or any subsequent and compatible purpose(s)) has been fulfilled.

12. Notice to Certain Residents

12.1 Quebec Residents

This Policy is compliant with an Act respecting the protection of Personal Information in the private sector, as recently amended by an Act to modernize legislative provisions as regards the protection of Personal Information (commonly referred to as “Law 25”).

12.2 EU and United Kingdom Residents

If the processing of your Personal Information is subject to the General Data Protection Regulation 2016/679 ("EU GDPR") or the United Kingdom General Data Protection Regulation ("UK GDPR"), this supplemental Section of our Policy apply to you.

Our lawful basis for processing Personal Information may include when:

  • you have given consent;
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary to protect our legitimate interests or that of a third party, except where such interests are overridden by your interests or fundamental rights;
  • processing is necessary for compliance with a legal obligation to which we are subject; and
  • processing is necessary to protect the vital interests of the data subject or of another natural person.

You have many rights with respect to our processing of your Personal Information. Depending upon the lawful basis of processing, you may have the right to withdraw consent or object to our processing of your Personal Information.

You have the right to be informed about your Personal Information and how it is being processed, to access, correct and erase Personal Information, to restrict further processing, to obtain and reuse your data for your own purposes across different services and to object to processing. You also have the right to lodge a complaint with the relevant EU or United Kingdom supervisory authority.

We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise his or her rights.

12.3 California, Virginia, Colorado, Connecticut and Utah Residents

To the extent any California, Virginia, Colorado, Connecticut or Utah privacy law applies to you, this supplemental Section of our Privacy Policy outlines the rights that residents of such jurisdictions may have, and how they can exercise those rights. We provide this supplemental Section to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively as “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) and the Utah Consumer Privacy (“UCPA”).

We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise his or her rights below.

Subject to certain exceptions under applicable law, you may be entitled to the following rights:

  • to access and request an exported or physical copy of the documents containing your Personal Information;
  • to have the Personal Information we hold about you corrected or updated;
  • to request deletion, in certain circumstances, of the Personal Information that we hold about you;
  • to opt out of the sharing of your personal information for cross-context behavioral advertising or targeted advertising purposes;
  • to opt out of the “sale” of your Personal Information (as the term is defined under applicable law);
  • if you are a California resident, you have a right to know the categories and names/addresses of third parties that have received your Personal Information for their direct marketing purposes;
  • if you are a Virginia, Colorado and Connecticut resident, you have the right to appeal our denial of any request you made under this Section, and if we deny your appeal, to lodge a complaint to the relevant Office of the Attorney General; and
  • to not be discriminated for exercising any of your rights under this Section.

13. How to Contact Us

In order to obtain more information on the Policy or the use of your Personal Information, to exercise your rights or to file a complaint, please contact our Privacy Officer at the following coordinates:

Semperform Innovation Inc.
ATTN: Privacy Officer
privacy@semperform.ca

14. Changes to this Policy

We may update this Policy periodically to reflect changes in our practices or for legal, regulatory, or operational reasons. Changes take effect upon posting on our Website or the HURT BLOCKER app or upon direct notification to you. By continuing to use our Services after such changes take effect, you agree to the updated Policy.

15. Automated Decision-Making

Some features of the HURT BLOCKER App may rely on automated processing or profiling techniques to analyze movement patterns or injury risk indicators. This may include:

  • automated extraction of movement or sensor data;
  • software based calculations or risk assessment metrics;
  • generation of a predicted score or probability related to ACL tear risk.

What this means for you: These outputs are generated automatically based on movement‑related inputs. They are not medical opinions, and human review is not automatically applied. Should you not agree, please cease use of the application.

As a reminder, the results generated by automated processing are informational only and should not be relied upon for medical or clinical decisions.

16. De Identification and Anonymization Practices

Where possible and appropriate, Semperform may de identify or fully anonymize Personal Information so that it can no longer be associated with an identifiable individual. We may use such de identified or anonymized data for:

  • analytics and statistical modeling;
  • improving our algorithms and training data;
  • enhancing functionality, safety, or accuracy of the HURT BLOCKER App;
  • research and development;
  • internal reporting and business intelligence.

De identified or anonymized information is handled in accordance with applicable law and is not considered Personal Information.

17. Third Party Service Providers and Categories of Recipients

We may share Personal Information with third parties strictly for purposes consistent with this Policy, including:

  • cloud storage and hosting providers;
  • analytics and performance monitoring tools;
  • software development and maintenance vendors;
  • identity verification providers;
  • professional advisors and auditors;
  • payment processors (if applicable).

These third parties receive only the information necessary to perform the services on Semperform’s behalf and are contractually obligated to protect Personal Information in accordance with applicable privacy laws and Semperform’s requirements.

18. Accuracy of Your Personal Information

We rely on you to provide accurate, complete, and up to date Personal Information. If you believe any Personal Information we hold is inaccurate or incomplete, you may request correction using the process described in Section 7.

19. Security Expectations for Users

While Semperform takes appropriate steps to protect Personal Information, you are responsible for:

  • protecting the confidentiality of your login credentials;
  • securing your device and network connections;
  • installing updates and security patches; and
  • preventing unauthorized access by third parties.

Semperform is not responsible for breaches arising from your failure to adequately secure your device or access credentials.

20. Governing Law (Privacy)

Except where prohibited by law, this Policy is governed by the federal and provincial laws applicable in the Province of Québec.

If you are resident outside Québec, additional local laws may also apply to our handling of your Personal Information.