Privacy Policy

This privacy policy (the “Policy”) is a statement of our general privacy policy and practices governing the ways in which 10032506 Canada Inc. (“Innodem”, “we” or “us”) collects, holds and uses information about individual persons. This Policy applies to data gathered by us from the mobile applications we associate with this Policy and not from any other source. BY USING INNODEM’S MOBILE APPLICATIONS, YOU CONSENT TO THE COLLECTION AND USE OF INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. YOU ALSO ACKNOWLEDGE THAT TO THE EXTENT PERMITTED BY APPLICABLE LAW, INNODEM MAY PERIODICALLY CHANGE, MODIFY, ADD OR REMOVE OR OTHERWISE UPDATE THIS PRIVACY POLICY AT ITS DISCRETION, WITHOUT PRIOR NOTIFICATION. It is our intention to post any such changes on this page so that you are fully informed concerning the types of information we are gathering, how we use it, and under what circumstances it may be disclosed.

Our Privacy Policy is easy to find as it is located on our homepage. It is also available in each of our mobile applications. At certain data collection points, further explanation may be provided, were appropriate, as to the purposes for which the data will be collected and used. This Policy, coupled with any supplementary explanation, will tell you how we will treat any data about yourself that you voluntarily submit in connection with your use of our mobile applications.

Privacy Policy Summary

What Personal Information we collect.

If you use the Pigio App, we collect information including your name, age group, gender, medical condition, if you have glasses, if you are color blind, photos of your face and ARKit data (as defined below).

If you use the ETNA App, we collect information including a unique identifier, audio and videos of your face and ARKit data (as defined below) for each video frame.

For both Pigio and ETNA, the “ARKit data” includes the App user’s face position and rotation, the iPad distance to the user’s face with the TrueDepth API, a coarse triangle mesh representing the topology of the detected face, a dictionary of named coefficients representing the detected facial expression in terms of the movement of specific facial features, identifiers for specific facial features, for use with coefficients describing the relative movements of those features, a transform matrix indicating the position and orientation of the face’s left and right eyes and a position in face coordinate space estimating the direction of the face’s gaze.

For both the Pigio App and ETNA App, we collect the performance data such as the device level identifier, the device type and model, the device operating system version, the screen resolution, the application version including the build number, the language of the application and the crash logs.

How we Use the Personal Information we collect.

The Pigio App uses information to customize what the user can see/say and to calibrate an artificial intelligence gaze-tracking model specifically tailored to you. Pigio uses the YouTube API to display the list of favourite YouTube channels in your account.

The ETNA App uses information to develop and validate an eye movement assessment tool to assist with differential diagnosis and disease progression evaluation. The gaze predictions are converted to degrees of eyeball rotation using simple trigonometry and the distance estimate provided by the TrueDepth API. The recorded videos and ARKit data are used to extract approximately 1500 features, many of which need to be expressed in degrees to accurately represent the metric of interest. Such features include the amplitude and velocity of saccades, the amplitude and velocity of square wave jerks, nystagmus amplitude, smooth pursuit gain, etc. The extracted features are used to train a machine learning algorithm for differential diagnosis and disease progression evaluation.

For both the Pigio App and ETNA App, the performance data is used to ensure server up-time, minimize app crashes, improve scalability and performance, or perform customer support.

How we share the Personal Information we collect.

For Pigio App, the personal information we collect is not shared with third parties, except as set forth in Section 4 below. It is not used for tracking purposes, not used to display targeted advertisements and not used to send advertising emails.

For ETNA App, the personal information we collect is not shared with third-parties, except as set forth in Section 4 below. It is not used for tracking purposes, not used to display targeted advertisements and not used to send advertising emails. If you participate in an ETNA research study, anonymous extracted features information (not personal information like recorded video or ARKit data) may be shared with the principal investigator, their research team, Health Canada and other regulatory authorities, for the purposes of the study, and for monitoring, control, safety, security, and regulatory approval purposes.

We may also share information if required or permitted by law.

1. Pledge on Privacy

Innodem respects and is committed to helping protect privacy and safeguarding the personal data entrusted to us by the users of our mobile applications. We pledge to make efforts to fully comply with recognized standards of privacy protection, applicable law (including the Act respecting the protection of personal information in the private sector (Québec) and PIPEDA), and internal privacy guidelines and policies.

2. Personal Data Collected

The term “personal data” as used in this Policy refers to the information that allows you to be identified and is collected from you when you use our mobile applications.

If you use the Pigio App, we collect information including your name, age group, gender, medical condition, if you have glasses, if you are color blind, photos of your face and ARKit data.

If you use the ETNA App, we collect information including a unique identifier, audio and videos of your face and ARKit data. Innodem collects personal data through ETNA only from individuals participating in a clinical research study sponsored by Innodem (a “Study”). This privacy policy does not limit any other consent you may have provided for the Study.

For both Pigio and ETNA, the “ARKit data” includes App user’s face position and rotation, the iPad distance to the user’s face with the TrueDepth API, a coarse triangle mesh representing the topology of the detected face, a dictionary of named coefficients representing the detected facial expression in terms of the movement of specific facial features, identifiers for specific facial features, for use with coefficients describing the relative movements of those features, a transform matrix indicating the position and orientation of the face’s left and right eyes and a position in face coordinate space estimating the direction of the face’s gaze.

For both Pigio and ETNA, information may cease to be personal data when it is stripped of all identifiers or aggregated with personal data collected from other individuals. Further, we reserve the right, in exceptional circumstances, to conduct additional processing to the extent permitted or required by law, including in support of any legal or criminal investigation.

For further information on how we collect and use technical “Usage Data” when you use our Apps, please see our End User Licence Agreement here https://innodemneurosciences.com/eula.

3. Intended use of Personal Data

In the case of some of our apps, you may need to complete certain fields (some are required and some are optional). If you choose to withhold any personal data that is necessary for the app to function, it may not be possible for you to gain access to the app, or certain parts of the app.

If you are a user of Pigio App, we use your personal data to customize what the user can see/say to calibrate an artificial intelligence gaze-tracking model specifically tailored to the user.

Pigio uses the YouTube API to login to the user’s account. The information shared by Google (user name, email address, language preference and profile picture) for the purpose of supporting the features of the Pigio application will be used to display the list of favourite YouTube channels. You may revoke Innodem’s access to your data via your Google permissions page.

If you are a user of ETNA App, the ETNA App uses information to develop and validate an eye movement assessment tool to assist with differential diagnosis and disease progression evaluation. The gaze predictions are converted to degrees of eyeball rotation using simple trigonometry and the distance estimate provided by the TrueDepth API. The recorded videos and ARKit data are used to extract approximately 1500 features, many of which need to be expressed in degrees to accurately represent the metric of interest. Such features include the amplitude and velocity of saccades, the amplitude and velocity of square wave jerks, nystagmus amplitude, smooth pursuit gain, etc. The extracted features are used to train a machine learning algorithm for differential diagnosis and disease progression evaluation.

For both the Pigio App and ETNA App, the performance data is used to ensure server up-time, minimize app crashes, improve scalability and performance, or perform customer support.

Innodem processes personal data for the purposes stated in this Policy and the purposes which we inform you about when we ask you for information. Generally, when you voluntarily provide us with your personal data, we will assume you consent to our collection, use and disclosure of that information for the purposes stated in this Policy and any additional purposes identified at the time of collection. If you contact us for assistance or with questions, the information you send to us in your request is used only to help address your request and is otherwise kept confidential.

Innodem may anonymize, aggregate or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purposes we deem appropriate.

4. Non-Disclosure of Information

Innodem will not sell, share, or otherwise distribute your personal data to third parties except as provided in this Privacy Policy. We may disclose your personal data to a third party if we are required or permitted to do so because of an applicable law, court order or government regulation, including if such disclosure is necessary in support of any legal or criminal investigation. We may disclose your personal data to our service providers and business associates that assist us with carrying out the purposes we describe in this Privacy Policy, and who agree to treat it in accordance with this Privacy Policy.

Personal data may occasionally be transferred to third parties who act for or on behalf of Innodem, for further processing in accordance with the purpose(s) for which the data were originally collected, such as companies that assist us with the purposes set out in this Policy, evaluation or technical support. These third parties have contracted with Innodem that they will only use personal data for the agreed upon purpose, will not sell your personal information to third parties, and will not disclose it to third parties except with your consent, or as may be required by law including in support of any legal or criminal investigation.

Where such disclosure of personal data to a third party occurs, we will endeavor to ensure that the processing is performed in accordance with the purposes and within the limits under which the data were originally collected.

Innodem may share de-identified study result information with third parties such as pharmaceutical companies.

Personal data collected through ETNA will be transferred to the principal investigator in charge of the Study and his/her research team and Health Canada and other regulatory authorities. These entities use the output of the ETNA App to clinically validate our tool against the current clinical standards of neurological health assessment in the disorder being studied, and for the purposes of monitoring, control, safety, security, and regulatory approval in respect of the tool or device. This personal data will also be used in conjunction with the other personal information that you have provided throughout your participation in the Study, for the purposes disclosed to you in the Information and Consent Form that you have completed prior to beginning your participation in the Study.

We reserve the right to transfer any personal data we have in the event that we, or any part of our business, merge with or are acquired by a third party. We may also disclose your personal data to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; or (iii) to protect our rights, safety or property. Lastly, we may disclose your personal data for any other purpose to which you consent.

5. Right of Access and Correction

You have the right to access your personal data, and ask that we correct it if you believe it is incorrect. You have the legal right to require us to correct your personal data. In addition, you can always tell us to stop contacting you. If you wish to contact us regarding our use of your personal data, please e-mail us at info@innodemneurosciences.com.

Your requests will be dealt with in a prompt and proper manner. Requests to delete personal data will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on Innodem. Please note that in some cases we may not be able to allow you to access certain personal data in certain circumstances, for example if it contains personal data of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal data, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your personal data.

6. Security and Confidentiality

To help safeguard the security and confidentiality of personal data that Innodem collects, Innodem uses physical, organizational, and technological security practices including encryption, use of secured links, password protection and other security methods. Access to personal data is restricted to those employees and representatives and other persons described in this privacy policy who have a need to use the data for the purposes described in this policy, and who have been trained to handle such data properly and observe strict standards of confidentiality. In the course of handling your personal data, we take measures reasonably designed to help protect that information from loss, misuse, unauthorized access, disclosure, alteration or destruction. While we cannot guarantee against any loss, misuse, unauthorized access, disclosure or alteration to data, we try to prevent such unfortunate occurrences.

7. Data Transfer Abroad

For Pigio App and ETNA App, the collected data is stored locally on the iPad and uploaded to the ETNA Cloud where it is encrypted and stored primarily in Canada, though we may also use databases in the European Union. We are using Cloud services to store and process the collected data. We may transfer your data to one of the Innodem databases outside of your country of residence, including to the United States and European Union. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Even if laws in the country to which the data is to be transferred do not require us to provide adequate protection for your data, we will nonetheless seek to ensure that data transfers to Innodem databases in that country are adequately protected.

8. Limitation on Retention of Personal Data

Innodem keeps your personal data only for as long as is reasonably needed for the purposes for which such information was collected, and in accordance with any applicable legal or ethical reporting or documentation retention requirements. Without limiting the foregoing, with respect to personal information collected through the ETNA App, we may retain the collected data for as long as required by the relevant regulatory authorities’ or ethics committees’ record retention rules and policies, which may be up to 25 years under Health Canada’s policies.

9. Contact us

If you have any queries or complaints about our compliance with this Privacy Policy, would like to make any recommendations or comments to improve the quality of our Privacy Policy, see exactly what personal information we have about you in our records, correct your personal information, or wish to register a complaint please email us at info@innodemneurosciences.com.

Our staff will be happy to answer any questions you may have about your personal information.

This privacy policy was last updated on January 18, 2022. We aim to constantly improve the tools available to you to manage the data that you provide to us. Please refer to this page from time to time to review these and other new features.