Privacy Policy

Summary This policy applies to users of the KEENSPIRE application ("Application"). It provides details on the management and protection of your personal information when you download and use the Application. It has also been designed to comply with the requirements of Law 25 for Quebec residents, the HIPAA law for the protection of health information in the United States, as well as the General Data Protection Regulation (GDPR) for our users located in the European Union.

In this policy, we answer these questions:

• What personal information is collected?
• How is your personal information used?
• How do we share your personal information and with whom?
• How do we protect your personal information?
• How can you exercise your rights?

In addition, when you use the Application, information about you may be recorded in cookies installed on your mobile device. Some cookies are necessary for the operation of the Application, others allow us to optimize and personalize the content displayed. By accepting the Terms of Use and using the Application, you consent to your personal information being collected, used, and disclosed in accordance with this policy.

Definitions used in this policy We/our/us means: NeurAlly Care 

Personal information means: any information concerning a natural person and which, taken separately or combined with other data, makes it possible to identify them. 

You/your means: any person who has downloaded and is using the Application. This policy must be read in conjunction with the Terms of Use. You can read these conditions by consulting the "Settings" section of the Application.

CONSENT We need your consent for the collection, use, or disclosure of your personal information, unless the law requires or permits it. Providing us with certain personal information voluntarily is equivalent to your consent to the collection, use, and disclosure of your personal information, in accordance with this policy. Furthermore, by downloading, activating, and using the Application, as well as by accepting its specific terms of use, you consent to your information being collected, used, and disclosed in accordance with the applicable sections of this policy.

Withdrawal of your consent You may, at any time, withdraw your consent to the collection, use, and disclosure of your personal information by making a written request to this effect at protection@neurallycare.com. Note, however, that anonymized information, which does not allow you to be identified, will be retained.

What information is collected by the Application and how is it used and disclosed? Once the Application is downloaded, in order to create your account and validate your identity, we ask you to provide the personal information of the parent on the account, i.e., the parent's first and last name, and their email address. The email address is used to send you notifications about the Application as well as to validate certain elements including, notably, obtaining valid consent from a parental authority for the creation of an account for a child under 16 years of age. You can at any time refuse to have the KEENSPIRE application send you notifications by modifying your Communication Preferences in the Account Settings, under the Application Settings section. For more information about the personal information collected when you use the Application, refer to the following sections:

What personal information do we collect?

When creating your account: You can create an account by providing us with your email address as well as your first and last name and by creating a password. You have the choice of how you wish to create your account. If you wish to connect to KEENSPIRE via Google, please be aware that we will also have access to your public profile and that you are also subject to the privacy policy of that company.

Upon payment: The KEENSPIRE application is offered as a Premium subscription. This subscription can be purchased individually (including a full 7-day free trial period) or provided to you through your employer or your insurer. If you subscribe individually, since we use third-party companies ("Third Parties") for processing your payment, we do not collect any information relating to transactions you make when purchasing the application in the Apple Store or Google Play, such as your credit card number. Please note that in addition to this Policy, the processing of your payment will be subject to the Third Party's Privacy Policy.

When using the Application: When you use the Application, you are invited to create a PARENT module as well as one or more CHILD modules. KEENSPIRE being an Application designed to facilitate children's skills development, we notably collect the information you enter yourself into the Application, including:

• Your language preference
• The child's first name, age, and gender
• Activities by path and themes and associated information (active activities or tasks, completed or not, number of activities, activity title, etc.)
• Programs and associated information (active and inactive programs)

In addition to this information, we collect the following data:

• Board visited and time per board
• Duration of use
• Device type and number of devices connected to the account
• Opening of the guide, reading of the guide, reading of notifications
• Completion rate statistics
• Opening of emails / clicking on links in emails

In order to benefit from personalized advice from our virtual coach, you will be invited to provide us with additional information about your child, notably:

• Their medication
• Their medical diagnosis

Enriched medical and tracking information: In addition to medication and medical diagnosis, the application now collects the child's ongoing treatments. We also collect detailed tracking of well-being and behaviors (e.g., level of social interactions, hyperactivity, concentration, impulsivity), as well as the tracking of other general observations (e.g., sleep difficulties, mood changes, loss of appetite). We collect your responses to adapted and targeted questions concerning your child's behavior, and behavioral signals during your use of the application, such as your response time and your level of engagement (depth) when entering observations. Finally, we collect the child's activity and progression data, including speed, pace of execution, interest level, and results of each activity.

Please note that we reserve the right to request an update of the data we collect. You will, however, be informed beforehand.

How do we use your personal information? We only collect personal information that is necessary to provide you with the service you need and that we obtained following your consent. Concretely, this means notably that the information provided allows us to support you in the skill development of your child(ren) and to offer you feedback. The Application information could also be used for research and development purposes and to improve your user experience within the Application. In such a case, the information is anonymized and serves essentially statistical purposes. Moreover, since we exist to create technological solutions that will improve the daily lives of people living with disabilities, we are committed to participating in the advancement of research in the field. Thus, by using KEENSPIRE, you contribute to this mission. We want to assure you, however: no data that can identify you will be used. As mentioned previously, this involves anonymized data that will be used for statistical and research purposes.

Retention of your data Note that we will retain your personal information as long as you use our Application and for a certain period after your subscription so that you can recover your information in the event you wish to resubscribe. If you wish for your data to be destroyed upon cancellation of your subscription, we ask you to make a written request to this effect by writing to the following address: protection@neurallycare.com. We also invite you to contact us if you desire additional information regarding the retention of your data.

Use of cookies and other similar technologies When using our Application or visiting our Website, information about you may be recorded in cookies or other tools installed by us or by third parties on your computer, tablet, or mobile phone. To learn more about our practice in this regard, we invite you to consult our website: https://getkeenspire.com/fr/politique-de-confidentialite/

How do we share your personal information? We may sometimes need to share your personal information with agents or others to help us make all the features of the Application available (maintenance, analysis, legal requirement, fraud detection, marketing, and development). Note that these parties may be located in Canada or in other jurisdictions or countries. They will only have access to the personal information necessary to perform these tasks on our behalf and are required not to disclose or use it for other purposes. Be aware that we have contractual agreements with these providers to ensure the security of your data. Note that we may also share your personal information when required by law, to enforce rules, or to protect the property or security of our rights or those of others. Additionally, as mentioned in the section "How do we use your personal information?", we may share anonymized data.

If you access the Application via a program sponsored by your employer or your insurer: Rest assured that we do not share with them any protected health information (PHI) nor any personal data concerning your child's observations and behavior. Only global, aggregated, and strictly anonymized data could be transmitted to them for billing purposes or global evaluation of the program.

How do we protect your personal information? The security and confidentiality of your personal information are important to us. We strive to apply necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession. To do this, we notably follow generally accepted industry standards. The personal information we hold is therefore only accessible to persons who are authorized to know it and who consult it only when necessary in the performance of their duties.

How to access and rectify your personal information? You have access to your personal information through your user account in the Application. You can correct and update some of your personal information from this access. You may request access to your personal information or information relating to the existence of such information or how we collect, use, store, and/or disclose your personal information. You can also request that the information held by NeurAlly Care be rectified if it proves to be inaccurate, ambiguous, or incomplete. You can submit a written request to this effect by writing to the Privacy Officer at the address indicated in the "Questions, comments, complaints" section below. If you wish to obtain copies of your personal information, we may require a minimal fee, which would be disclosed to you beforehand, simply to cover transcription, reproduction, or transmission costs.

CHILDREN'S PRIVACY PROTECTION (UNITED STATES) We recognize that the personal information we collect from children in KEENSPIRE requires heightened protection. When we collect personal information from children, we take extra steps to protect their privacy, including:

• We notify parents about our practices regarding children's personal information, including the types of personal information we collect from children, the uses of this information, its disclosure, and, if applicable, the parties to whom we communicate it.
• In accordance with applicable law and our practices, we ask parents for their consent to collect personal information from their children or to send them information about our products and services directly.
• We limit the collection of children's personal information to information reasonably necessary for them to participate in KEENSPIRE.
• We allow parents to access or request access to the personal information collected from their children and give them the opportunity to request the modification or deletion of this information.

For additional information about our practices regarding children's personal information, we invite you to consult our website: https://getkeenspire.com/fr/politique-de-confidentialite/

HIPAA COMPLIANCE (UNITED STATES) Given that the Application collects protected health information (PHI), NeurAlly Care is committed to respecting the standards of the Health Insurance Portability and Accountability Act (HIPAA). We apply the following rules to ensure the security and confidentiality of your health data:

• Privacy Rule: We implement appropriate safeguards to protect the privacy of your PHI and we impose strict limits on the use and disclosure of this information without your authorization.
• Security Rule: We apply appropriate administrative, technical, and physical safeguards to ensure the confidentiality, integrity, and security of your protected health information.
• Breach Notification Rule: In the event of a breach involving unsecured PHI, we commit to notifying affected users as well as the Secretary of the US Department of Health and Human Services (HHS), in accordance with legal requirements.
• Individuals' Right to PHI Access: You have the right to inspect, obtain, or transmit a copy of all your protected health information (PHI) maintained by our organization. You can exercise this right by contacting us at protection@neurallycare.com.
• Audit Log Rule: We have put in place mechanisms that record and examine activities within our information systems containing or using PHI. These audit logs are kept for a period of six years.

QUEBEC RESIDENTS (COMPLIANCE WITH LAW 25) If you reside in Quebec, the processing of your personal information is subject to the Act respecting the protection of personal information in the private sector (Law 25). As such, you benefit from specific rights:

• Privacy Officer: NeurAlly Care has designated a Privacy Officer responsible for ensuring compliance with this policy and applicable laws. You can reach them for any question or request at: protection@neurallycare.com.
• Right to portability: You have the right to request that the computerized personal information you have provided to us be communicated to you in a structured, commonly used technological format.
• Right to de-indexation: You have the right to ask us to cease disseminating your personal information or to de-index any hyperlink attached to your name that allows access to it, if this dissemination contravenes the law or a court order.
• Confidentiality incidents: In the event of a confidentiality incident involving your personal information and presenting a risk of serious injury, NeurAlly Care is committed to notifying you as well as informing the Commission d'accès à l'information du Québec, in accordance with the law.
• Privacy Impact Assessment (PIA): We conduct rigorous assessments when transferring your personal information outside Quebec to ensure it receives adequate protection.

PERSONAL INFORMATION FROM THE EUROPEAN UNION If you are an individual located within the territory of the European Union at the time of collection, you may exercise the following rights regarding your personal information that is collected, processed, or disclosed.

• Information: Right to be informed about the processing of your personal information, i.e., what, who, and how;
• Access: Right to know what personal information we have in our possession, right to request access to it and receive a copy;
• Rectification: Right to have any incomplete or inaccurate information rectified;
• Consent: Right to withdraw consent to the processing of personal information;
• Restriction: Right to request the suspension of the processing of certain information to allow establishing the reason for its processing or its accuracy;
• Erasure: Right to request the erasure or removal of information. We may notably refuse to proceed with the erasure of personal information if it is required for compliance with applicable laws or for claims;
• Objection: Right to object to the processing of information on the basis of legitimate interest or for direct marketing purposes;
• Transfer: Right to request the transfer of personal information to another party;
• Automated decisions: Right to object to any automated decision when such a decision has a significant legal or similar impact and to request that it be reconsidered by a human.

For additional details, we invite you to consult our website: https://getkeenspire.com/fr/politique-de-confidentialite/. To exercise any of these rights, we invite you to contact us by writing to the following address: protection@neurallycare.com

Changes and updates to the policy Our Application may be modified at any time. Consequently, this Policy may be subject to change from time to time in the future. It is recommended to consult it frequently in order to stay informed about how we process personal information.

Questions, comments, complaints To contact us, ask questions related to this Policy, share your comments, submit an access or rectification request, exercise any applicable right, file a complaint or obtain information about our practices or policies, we invite you to contact our Privacy Officer at the email address: protection@neurallycare.com