Data and Privacy Policy for Innov2Learn’s SYHM and Medical Simulation Applications and Medical Simulation Devices

Last updated:2021-08-04

This policy describes how Les Solutions Innov2Learn Inc.(“Innov2Learn”, “we”, “us”) collects,
collates, processes, uses, and shares information and data about users of the SYHM and
MEDICAL SIMULATION applications (the “Applications”) and its medical simulation devices
(the ”Medical Simulation Devices”). Innov2Learn does not collect or process any personal
information or personal data through its Applications and Medical Simulation Devices.
Innov2Learn only collects information and usage data from its Applications and Medical
Simulation Devices. If personal information about you is collected by Innov2Learn, you will
be notified in advance and we will seek your consent to such collection.

The contact details of the data controller under this policy are as follows: Les Solutions
Innov2Learn Inc. 1001 Rue Lenoir, Montréal, QC H4C 2Z6, Canada, To the attention of:
Data Controller E-mail: support@i2L.ca

Data Collection

Data Collected Automatically

We collect certain information automatically when you use the Applications and Medical Simulation Devices. This information is recorded each time you interact with the Applications and Medical Simulation Devices. This usage data is anonymized and collected automatically. It includes certain information specific to your mobile device as well as data about your interaction with the Applications and Medical Simulation Devices, including:

• The operating system of your mobile device and Medical Simulation Devices, if applicable.
• The MAC (Media Access Control) address of the Medical Simulation Devices.
• The number of connections to the Medical Simulation Devices and the date, time, and count of connections to the Medical Simulation Devices.
• When the geolocation feature of your mobile device is enabled and you have authorized the Applications to access it, we collect data about your precise geographic location in order to detect available Medical Simulation Devices and determine their language and units of measurement. By allowing the Applications to access the geolocation features of your mobile device, you consent to our collection and use of your location data as set forth in this policy. You may use the Application seven if you have not authorized them to access your mobile device’s location-based features, but certain features will be disabled, including but not limited to Bluetooth if your mobile device runs on the Android platform.

Data Processing

Innov2Learn’s data processing is essentially based on the following principles:

• We do not collect or process any personal information or personal data.
• All usage data collected is anonymized.
• If we were to process personal information through the Applications and Medical Simulation Devices, it would only be because you specifically consented to its processing and based on your consent expressed in your acceptance of our Terms of Use and Privacy Policy. You may then withdraw your consent and we will cease the processing of your personal data based on your consent

Why do we collect usage data?

We use the usage data collected through the Applications for the purposes described below.

Use by Innov2Learn

Usage data is collected through the Applications and Medical Simulation Devices for the purpose of improving and enhancing our products and services, and for statistical and reporting purposes.

Maintenance of the Applications

We use data collected through the Applications and Medical Simulation Devices and data from analytics tools to monitor user usage of the Applications and Medical Simulation Devicesgenerally, to prevent misuse of the Applications and Medical Simulation Devices, to identify problems or bugs in the Applications and Medical Simulation Devices, and to determine which features to improve.

How long do we keep usage data?

We retain collected usage data until it is no longer necessary for our business to retain it. We do not, however, make a commitment to keep it for a specific period of time.
If we were to collect personal data, how would it be protected? (if applicable)
If we were to collect personal data through the Applications and Medical Simulation Devices, it would be stored on servers operated by our service providers. These servers are located in various jurisdictions in North America. These service providers have committed to us to use reasonable security measures to preserve the integrity and confidentiality of personal data.

Our employees and service providers are made aware of the appropriate security measures to prevent unauthorized access to personal data and would be informed of the confidential nature of the personal data collected if any.

To whom would your personal data be communicated? (if applicable)

We would only share your personal data in the manner described in this policy or when we would have obtained your consent. Your personal data would be communicated to the categories of persons described below for the following purposes:

Employees
The personal data that would be collected, if any, would be accessible to our officers and employees who need to access it for the purposes set out in this policy.

Service Providers
We could share certain data collected with service providers to enable us to serve our customers and users more efficiently. However, we would not sell any personal data of our users and we would not allow our service providers to use this data on an individual basis.

Legal Obligations
We could communicate personal data (if any) or usage data to third parties if expressly permitted or required to do so by law, or if we were required to do so by a competent authority. We could disclose personal data in connection with legal proceedings if necessary to protect our rights or those of our users.

Transfer of Business
In the event that the sale or restructuring of all or part of our business was contemplated, we could transfer the personal data collected (if any) and usage data to the individuals or organizations involved before and after the transaction, whether or not the transaction would go through. In such a case, such persons or organizations would undertake to us to maintain the confidentiality of the personal data collected and to use it solely for the purpose of evaluating the feasibility or advisability of the transaction and in accordance with this policy.

What rights would you have with respect to your personal data (if you had consented to the collection of such personal data)?

Access to your Data

You could be able to access certain personal data that you would have provided to us personally by accessing your account through the Applications, if any. To access the personal data we would hold about you, or to have certain inaccurate personal data amended, you would need to make a written request to us at the data controller’s address listed at the beginning of this policy. We would respond to your request promptly (within 30 days of receipt), giving you access to the personal data we would have about you in our records. Where required by law, we would provide you with your data in a machine-readable format.

Withdrawal of Consent

You could be able to withdraw your consent to the collection of certain data, including location data, by refusing the access of the Applications to the location data of your mobile device.

If you wished to withdraw your consent to the processing of your personal data beyond what
is permitted by the Applications or your mobile device, you would need to notify us in writing
at the data controller’s address listed at the beginning of this policy. However, the best way
to stop any processing of your personal data would be to stop using the Applications.

Deletion

In certain circumstances, you may be able to request the deletion of the personal data we would hold about you, if any. To make such a request, you would need to write to us at the data controller’s address listed at the beginning of this policy. We would comply with your request as soon as possible (but no later than 30 days after receipt). Identity validationWecouldverify the identity of individuals asking to exercise their rights with respect to their personal data. Any information that would be collected for this purpose would not be used for any other purpose.

Applicable Law

This policy is governed by the laws and regulations applicable in Canada. The Canadian authorities have exclusive jurisdiction to receive any complaint or claim based on this policy or in Innov2Learn’s processing of your personal data. If you reside in the European Union, you have the right to file a complaint about the processing of your personal data with a privacy enforcement authority. This authority varies depending on your country of residence.

Modifications to the Policy

We may modify this policy from time to time to reflect changes in our personal data management practices. If a modification is made, the new policy will be available at the following address: www.innov2Learn.ca If we have collected your contact information, we will notify you of any material changes to this policy by email before the new policy takes effect.

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