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") sets out how we collect, hold, use or communicate to third parties Personal Information (as defined hereinafter) of our customers or other (hereinafter individually referred to as “you”), other than our employees or contracted staff, which is dealt with separately.
We are committed to treating any Personal Information we collect, hold, use or communicate with care, within the limits of this Policy and applicable law.
This Policy applies to Personal Information regardless of the type of medium or the form in which it is accessible: written, graphic, sound, visual, taped, filmed, computerized, or others.
We define “Personal Information” as any information about an identifiable individual, or that taken alone or combined with other data, allows an individual to be identified. By way of illustration, Personal Information could consist of, but is not limited to:
We collect Personal Information for the following purposes:
We generally collect Personal Information directly from the person concerned in the course of providing our products and services. 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.
We may disclose the Personal Information we have collected to third parties in the following circumstances:
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 the United States.
To protect your information in all such cases, we use contractual and other means to provide a comparable level of protection to that used by Semperform (as outlined in Section 8).
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 collection, use and disclosure of your Personal Information to the extent described in this Policy and as required or permitted by applicable law.
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.
You have the following rights regarding your Personal Information:
We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise his or her rights.
If the Europe or United Kingdom privacy laws apply to you, please review Section 12.2 of this Policy. If the California, Virginia, Colorado, Connecticut or Utah privacy laws apply to you, please review Section 12.3 of this Policy.
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.
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.
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.
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.
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”).
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 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.
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:
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
[email protected]
We may change this Policy from time to time to reflect changes to our privacy practices or for other operational, legal or regulatory reasons. Changes will be effective immediately upon notifying to you or posting on the Website or the HURT BLOCKER app. After these changes are notified or posted, as applicable, by submitting your Personal Information or by continuing to use the HURT BLOCKER app, our products, services or Website, you agree to any such revised policy.