(old) Interaxon Privacy Policy

Introduction

Your privacy is important to InteraXon Inc. (a Canadian corporation with its head office in Ontario, Canada) and its affiliates (“InteraXon” or “we”) and we are committed to protecting the privacy of our customers.

Depending on the products, applications, services and programs you choose to access or participate in, InteraXon may collect information.  This Privacy Policy is intended to describe how such information may and may not be collected, stored, processed, transferred, disclosed and utilized. We may, from time-to-time, change our Privacy Policy by posting a new version of our Privacy Policy on our website. We will make reasonable efforts to notify our users of any such changes when they occur.

By providing information or data to InteraXon when: (i) using  online and mobile services provided by InteraXon from time-to-time, including, but not limited to certain websites, widgets, computer programs and mobile applications hosted by or on behalf of InteraXon (collectively, the "InteraXon Services"); (ii) acquiring InteraXon products or services, or (iii) agreeing to  particular terms or notices (“Notice”) associated with particular InteraXon Services, programs or products, you agree to the terms of this Privacy Policy and Notice and consent to the collection, use, processing, transfer, storage and disclosure of such information in accordance with the terms of this Privacy Policy and Notice, respectively.  The terms below apply unless you have agreed to the contrary through a Notice.

InteraXon will use current industry standard information security best practices to maintain the security of your sensitive information we collect from and on behalf of our customers. We will review these practices from time-to-time against new and emerging standards.  

We recognize that all data is not created equal, and some types of data are more sensitive than others. With that in mind, this Policy will outline the ways in which we will protect your privacy for each type of data.

 

Types of Data

Depending on which Interaxon Services, programs or products you choose to access or participate in, we may collect, process and/or store one or more of the following types of data about you:

  • Brainwave and Biometric Information
  • Personally Identifiable Information
  • Site, Service and Application Usage Information

Below we have defined each type of data and described our respective rights and obligations related to such data.

 

Brainwave and Biometric Data

Definition

For the purposes of this Policy, ”Brainwave and Biometric” data is defined as:

Data collected by sensors in the Muse headband or other sensors (e.g. 3rd party heart rate monitors, fitness trackers, etc.). This would include the raw recordings from the sensors (in the case of the Muse headband, EEG data, commonly known as brainwaves) as well as any scores or performance data that are generated for you as part of your use of Interaxon Services.

Ownership & License

Brainwave and Biometric Data is the most sensitive data contemplated by this Policy. At Interaxon, it is our goal to be industry leaders in the protection of users’ Brainwave and Biometric Data.

Your Brainwave and Biometric Data belongs to you, and you retain, at all times, complete ownership of all your Brainwave and Biometric Data collected during your use of Interaxon Services.

For as long as your Brainwave and Biometric Data is stored as part of or as a result of your use of Interaxon Services, you grant us a limited, revocable, non-exclusive license to collect, process and store that data, only so far as is required to deliver you Interaxon Services.

At any time, you can choose to remove your Brainwave and Biometric Data from Interaxon’s possession or control.  Our contact information is set out below.

We will process these requests within a reasonable amount of time, and upon removal of the information, we will have no further license to use your Brainwave and Biometric Data.

Sensitivity

Interaxon considers this data to be highly sensitive.

Storage and Protection

All Brainwave and Biometric Data will be anonymized before being stored in our cloud servers, and stored securely using security measures that meet or exceed industry standards for the protection of personally identifiable information. 

Brainwave and Biometric Data generated by use of InteraXon Services that is not anonymized will be available only to those personnel who we reasonably believe require access to such information to provide higher level technical support and troubleshooting services.

 

Personally Identifying Information

Definition

For the purposes of this Policy, “Personally Identifying Information” is defined as:

Information that identifies you, such as your name, address, phone number and email address.

Ownership & License

You retain complete ownership of all Personally Identifying Information collected during your use of Interaxon Services.

You grant Interaxon a non-exclusive, limited license to collect, process and store this data for the purpose of providing Interaxon Services for as long as you continue to use them.

At any time, you may request the removal of your Personally Identifying Information from InteraXon’s possession or control.  These requests will be facilitated within a reasonable period of time.  You can also request to see what Personally Identifying Information InteraXon has stored on your behalf.  Our contact information is set out below.

Sensitivity

Interaxon considers this data to be highly sensitive.

Storage and Protection

All Personally Identifying Information stored by us will be stored using security measures that meet or exceed industry standards for the protection of Personally Identifying Information.

Personally Identifiable information will only be accessible to people we believe have a relevant need for that information for the purposes of product/service development, billing, quality, delivery, and/or management of our business/operations.  For example, customer contact and service details are available to personnel involved with service delivery and support. 

If required, customer contact information may be accessible on a limited basis to 3rd party service delivery personnel from organizations with whom InteraXon has engaged in a contractual relationship (which may include confidentiality agreements)   where InteraXon believes such access is reasonably required to deliver InteraXon products/services   (examples may include regional 3rd party hardware or software support personnel, or personnel providing repair, workshop or training services).  Other than as set forth herein, InteraXon does not share, rent, or sell Personally Identifying Information it collects about you to or with third parties.

 

Site, Service and Application Usage Information

Definition

For the purposes of this Policy, “Site, Service and Application Usage Information” is defined as:

Information that enables InteraXon to track site, service and application usage such as access date and time, the specific web and application service used, frequency and duration of access, and other users contacted or collaborated with via InteraXon Services. 

Sensitivity

Interaxon considers this data to be moderately sensitive.

Storage and Protection

Site, Service and Application Usage Information will only be accessible to people we believe have a relevant need for that information for the purposes of product/service development, billing, quality, delivery, and/or management of our business/operations.  For example, customer contact and service details are available to personnel involved with service delivery and support.

All Site, Service and Application Usage Information will be stored using security measures that meet or exceed industry standards for the protection of such information

 

Data stored on local devices

As part of the use of Interaxon Services, some or all of your data may be stored on your local device (for example your smartphone, tablet or computer) and/or uploaded to our cloud servers. We urge you to take measures to protect the information on your local devices, for instance via application password as well as any additional protection - such as local data encryption - optionally chosen by the user (offered on both Google® Android(™) and Apple® iOS(™) devices).   You also have the option of deleting locally stored data.

For more information on Apple IOS (iPhone / iPad) security, please see: https://www.apple.com/iphone/business/docs/iOS_Security_Oct12.pdf

For more information on Google Android security, please see: http://developer.android.com/guide/faq/security.html

 

Voluntary Research Programs

Developing new algorithms for the classification of brainwave data requires intense research. The most useful tool in advancing the science of brain-sensing technology is data from users like you.

While using Interaxon Services we may, from time to time, ask you to participate in research programs aimed at improving our understanding of the brain, developing new algorithms, improving our ability to deliver products and services, and/or advancing scientific research.

Participation in such programs is entirely voluntary, and the choice to participate will always be presented clearly. We will inform you, when presenting the choice, what types of data will be collected as part of the research program.

Should you choose to participate in these programs, you grant InteraXon the right to use your de-identified data for internal research to improve our products and services and/or develop new products and services. You also grant Interaxon the right to combine your information with other information into an aggregate form, so your information no longer personally identifies you and to share such anonymized, aggregate data with specific 3rd parties of our choosing including without limitation, bona fide research organizations, scientists, investors and policy makers.

You can choose at any time to withdraw your consent to participate in any voluntary research program. Should you withdraw your consent, your non-aggregated data will not be used in any future research or reports. However, Interaxon will retain the right to any reports or aggregate data generated during your participation in the programs.

 

Sharing with Other Users or on Social Media

When sharing your InteraXon data with other users via InteraXon Services, InteraXon will utilize a confirmation mechanism within the application or Notice to solicit and confirm your consent.  InteraXon cannot, of course, control information shared by you or someone else through channels such as email, chat or other social media.

 

Situations Requiring the Disclosure of Data

Notwithstanding anything to the contrary, InteraXon may disclose any data collected through Interaxon Services if required to do so by law or in the good faith belief that such action is necessary to: (i) confirm to applicable law or comply with legal process served on InteraXon or any InteraXon site, (ii) protect and defend the rights or property of InteraXon, or (iii) in urgent circumstances to protect the personal safety of users of InteraXon, InteraXon Services or the public.

 

Product Communications

Subject to compliance with applicable law, we may also send you product or service related communications, or invitations to participate in surveys, etc.  We ask that you read any Notice associated with such communication before you agree to participate. Also, InteraXon typically includes an unsubscribe mechanism in any InteraXon marketing or commercial communication, which you may use to notify us if you do not want to receive such communications.

 

Mergers and Acquisitions

If InteraXon should merge with another company, InteraXon will require, to the best of its ability, the purchasing or merging party to comply with the confidentiality and privacy requirements set forth herein respecting sensitive information collected through Interaxon Services.  Interaxon will make reasonable efforts to notify you of any such merger or acquisition, and any resulting changes to our Privacy Policy.

 

Contact

For any questions about this Privacy Policy please contact:

Privacy Officer

privacy@interaxon.ca

InteraXon
511 King St. W. Suite 303
Toronto, ON, M5V 1K4 
+1 416-598-8989

 

Last update:  March 14 2014