CONFIDENTIALITY POLICY

Akinox.com (« Site »)

  1. Introduction


    Akinox has established and implemented internal policies and procedures to adequately protect the personal information in our possession and we review them on a regular basis. This policy complies with the laws set out in the Personal Information Protection and Electronic Documents Act (PIPEDA)
    (Loi sur la protection des renseignements personnels et les documents électroniques (LPRPDE)) and the Act respecting the protection of personal information in the private sector (R.R.S.Q., c. P-39.1) (La Loi sur la protection des renseignements personnels dans le secteur privé (RLRQ, c. P-39.1)) (collectively the “Acts”).

  1. Consent

    Subject to the exceptions and requirements of applicable laws, we will not share or disclose your personal information to any other third parties without your free, informed, and express consent. Users agree that by using our Site, they consent to the terms and conditions set forth in this Privacy Policy for the collection and use of the data described in this Policy. You may withdraw your consent at any time, subject to certain legal or contractual restrictions.
  1. Peronal Information We Collect

    When you visit and use our Site, we may automatically collect and store your IP address, location of the Site, hardware and software details used. If the User subscribes to the newsletter, we collect your full name and business email. This data may be collected through a form.
  1. How We Use Personal Information

    The data we automatically collect is used to provide, perform, maintain, and promote our services. We also use the data for Site usage statistics. We limit the collection, use and disclosure of your personal information to the purposes we have specified to you. Your personal information may only be accessed by certain authorized individuals and only for the purposes for which they have been designated.
  1. With Whom We Share Personal Information

    We may disclose User Data to any member of our organization as reasonably necessary to fulfill the purposes set forth in this policy. We may share User Data in order to take advantage of the Site’s usage analysis services. Third parties will not be able to access User Data beyond what is reasonably necessary to accomplish the given purpose. We will not share your data with third parties except as permitted or required by law. If you follow hyperlinks from our Site to another site, please note that we are not responsible for and have no control over their privacy policies and practices.
  1. How We Store Personal Information

    We do not retain User data beyond what is necessary to fulfill the purposes for which it is collected. We must destroy this information in accordance with the law and our record retention policy.
  1. How We Protect Your Personal Information

    We are committed to protecting your personal information. In order to prevent unauthorized access or disclosure of personal data, we have implemented technical and organizational measures to protect and secure it. To ensure the security of personal data, we have built our Site using encryption and authentication tools that meet industry standards.
  1. How to Modify, Delete or Challenge Your Collected Information

    If you wish to access, delete or modify your information, please contact our Privacy Officer here: 
    privacy-vie.privee@akinox.com
  1. Cookies

    A cookie is a small file, stored on the hard disk of a User by the Site. Its purpose is to collect data about the User’s browsing habits. We use cookies to remember any selections you make on our Site so that they are saved for future visits. This allows us to improve the design and functionality of our Site by collecting data about the content you access and click on while using our Site. You can choose to be notified each time a cookie is sent. You may also choose to disable cookies entirely in your Internet browser, but this may reduce the quality of your user experience.
  1. Modifications

    This Privacy Policy may be amended from time to time to maintain compliance with the law and to reflect any changes to our data collection process.
  1. Contact


    If you have any questions, please feel free to contact us using the following:

    Phone: (800) 996-9196

    Email : info@akinox.com

Effective Date: September 1st, 2021

PRIVACY POLICY

Akinox.com and Solutions

  1. Introduction

The purpose of this privacy policy is to inform Users of our site and of our Solutions of the personal data that we collect as well as the following information, as the case may be:

    1. The personal data that we collect;
    2. The use of the data collected;
    3. Who has access to the data collected;
    4. The rights of Users of the site; and
    5. The site’s cookie policy.

This privacy policy is supplemented with the terms and conditions of our site and Solutions.

Akinox has established and implemented internal policies and procedures designed to adequately protect the personal information in our possession and we review these policies and procedures on a regular basis. We make our employees aware of the importance of protecting personal information by requiring them to receive training on this matter and by issuing directives outlining their role and obligations in this regard from time to time.

  1. Applicable laws

This policy complies with the laws set out in the Personal Information Protection and Electronic Documents Act (PIPEDA). In addition, the collection, use, communication and storage of your personal information are, as the case may be, subject to sections 19 to 28 of the Act respecting health services and social services (CQLR, c. S-4.2.), the Act respecting access to documents held by public bodies and the protection of personal information (CQLR c A-2.1) or the Act respecting the protection of personal information in the private sector (CQLR, c. P- 39.1) (collectively, the “Laws”).

For residents of EU countries, the General Data Protection Regulation (GDPR) governs all data protection policies, regardless of where the site is located. This privacy policy aims to comply with the GDPR. If there are any inconsistencies between this policy and the GDPR, the GDPR shall prevail.

For residents of the State of California, this privacy policy is intended to comply with the California Consumer Privacy Act (CCPA). If there are any inconsistencies between this document and the CCPA, the CCPA shall prevail. If we find any inconsistencies, we will change our policy to comply with the relevant law.

  1. Consent

Subject to the exceptions and requirements of the applicable laws, we shall not communicate or disclose your personal information to any other third party without your free, informed and express consent.

    1. Users agree that by using our site, they consent to:
      1. The conditions set out in this privacy policy and;
      2. The collection, use and storage of the data listed in this policy;
    2. Users agree that by using our Solution, they consent to:
      1. The conditions set out in this privacy policy;
      2. The collection, use and storage of the data listed in this policy;
      3. Data sharing with the User’s local authority or government authorized partners for the purposes of establishing proof of vaccination;
      4. The collection of data from User’s local authority or government authorized partners for the purposes of establishing proof of vaccination.

You can withdraw your consent at any time, subject to some legal or contractual restrictions.

In special circumstances, we may collect, use or disclose personal information without your knowledge or consent. Such circumstances arise when, for legal, medical or security reasons, it is impossible or unlikely to obtain your consent or when the information is necessary for the purpose of investigating a possible breach of contract, preventing or detecting fraud or applying the law.

  1. Personal data that we collect

Any factual or subjective information about an identifiable person is considered personal information. Your personal information may include, but is not limited to, first and last name, address, phone numbers, gender, email address, information about your marital status, your lifestyle or your health. However, the name of an individual, as well as their professional contact information, that is, their professional title, address, phone number and email address, are not personal information.

Data collected automatically through our site and Solutions

When you visit and use our site or Solutions, we may automatically collect and store the following information:

    1. IP address;
    2. Location;
    3. Hardware and software details;
    4. Links a User clicks while using the Site; and
    5. Content that the User consults on your site.

Data collected non-automatically through our site

We may also collect the following data when you use specific functionalities on our site:

    1. First and last name;
    2. Email; and
    3. Telephone number.

This data may be collected through a form. Please note that we only collect data that helps us achieve the purpose set out in this privacy policy. We will not collect additional data without notifying you first.

Data collected non-automatically through our Solutions

For the purpose of providing you with a proof of vaccination, Akinox collects the following data when you use the Solution:

    1. First and last name;
    2. Email;
    3. Phone number;
    4. Health insurance number;
    5. Vaccination date;
    6. User gender;
    7. Region of residence of the User;
    8. Region of vaccination site;
    9. The type of vaccine administered;
    10. Date of birth;
    11. First vaccine date against COVID-19;
    12. First and last name of a parent.

This data may be collected through a form or may be received from User’s local authority or government authorized partners.

Please note that we only collect data that helps us achieve the purpose set out in this privacy policy depending on the Akinox product used. We will not collect additional data without notifying you first.

  1. How we use personal data

Personal data collected on our site will be used only for the purposes specified in this policy or as indicated on the relevant pages of our site. We will not use your data beyond what we disclose.

The data that we collect automatically is used for the following purposes:

    1. Provide, perform, maintain, approve and promote our services;
    2. Send transactional messages, including replies to your comments, questions and requests; provide customer and support services; send technical notices, updates, security alerts, as well as support and administrative messages;
    3. Send promotional communications by email or phone, including information on products and services, news, surveys, newsletters, offers, including specials, promotions, events and other information that may be of interest to you;
    4. Customize the site according to your interests; and
    5. Monitor and analyze trends, use and activities in connection with the site and services provided as well as for marketing or advertising purposes.

The data that we collect when the User performs certain things on the site may be used for the following purposes:

    1. To reply to your requests for information;
    2. To improve our service offering;
    3. To meet the requirements of the laws; and
    4. To control the quality of customer service and prevent errors and fraud.

The data we collect when the User performs certain things with respect to our Solution may be used for the following purposes:

    1. To meet the request for proof of vaccination;
    2. To provide downloadable proof of vaccination in PDF format;
    3. To meet the requirements of the law;
    4. To improve the Solution;
    5. To provide statistical tools to the Department of Health and Social Services; and
    6. To control the quality of customer service and prevent errors and fraud.

We limit the collection, use and disclosure of your personal information to the purposes we have indicated to you. Your personal information may only be viewed by certain authorized persons, and only in the context of the tasks assigned to them.

In general, we do not disclose your personal information without obtaining your free, informed and express consent. We may occasionally communicate your personal information to certain suppliers or agents in order to provide the Solution you have requested from us. In all cases, we comply with the restrictions and requirements prescribed by law when we disclose your personal information. We do not sell your personal information to third parties.

  1. With whom we share personal data

Employees

We may disclose User data to any member of our organization that reasonably need such data to achieve the purposes set out in this policy.

Third parties

We may share User data with the following third parties:

    1. Google;
    2. Microsoft;
    3. User’s local authority or government authorized partners

We may share User data with third parties for the following purposes:

    1. Website usage analysis services;
    2. Obtain the information necessary to provide proof of vaccination; and
    3. Provide proof of vaccination.

Third parties will not be able to access User data beyond what is reasonably necessary to achieve the expected purposes.

  1. Other disclosures

We undertake not to sell or share your data with third parties, except in the following cases:

    1. If required by law;
    2. If required for any legal proceedings; and
    3. To enforce or protect our legal rights.

If you follow hyperlinks from our site to another site, please note that we are not responsible for and have no control over their privacy policies and practices.

  1. How long we store personal data

We do not store User data beyond what is necessary to fulfill the purposes for which it is collected. We will destroy such data in accordance with the law and our record retention policy. When we destroy your personal information, we take the necessary steps to maintain its confidentiality and ensure that no unauthorized person may gain access to it during the destruction process.

  1. How we protect your personal data

We are committed to protecting your personal data. In order to prevent unauthorized access or disclosure of any personal data, we have implemented technical and organizational measures to protect and ensure its security. To ensure the security of personal data, we have built our site and Solutions using encryption and authentication tools that meet industry standards. While we take all reasonable precautions to ensure that User data is secure and Users are protected, there is always risk. The Internet as a whole may be insecure at times and therefore we are unable to guarantee the security of User data beyond what is reasonable.

  1. International data transfers

User data can be viewed, processed or collected in the following countries:

    1. United States; and
    2. Canada.
  1. Minors

For EU residents, the GDPR specifies that persons under the age of 15 are considered minors for the purposes of data collection. Minors must have the consent of a legal representative for their data to be collected, processed or used.

  1. Your rights as User

As User, you have the right to access all personal information that we have collected. In addition, you have the right to update or correct any personal data in our possession, in accordance with the applicable law.

You may choose to withdraw or change your consent to the collection and use of data at any time, provided it is legally acceptable to do so and that you provide us with reasonable notice.

You may, following the filing of a request with reasonable notice, and subject to any regulatory or contractual restrictions, consult or request the correction of personal information that we have about you.

We will provide you with such information within a reasonable time from the date of receipt of the written request. However, fees may apply to process your request.

In special circumstances, we may refuse to provide you with the information requested (e.g., if such information cannot be disclosed for legal or security reasons). These limitations are described in the Act respecting the protection of personal information in the private sector.

You can verify the accuracy and exhaustiveness of your personal information and, if necessary, request that it be amended. Any request for modification will be dealt with in accordance with the applicable laws.

  1. How to modify, delete or contest the data collected

If you would like your information to be removed or modified in any way, please contact our privacy officer at:

info@akinox.com or by phone at (800) 996-9196.

  1. Cookie policy

A cookie is a small file that is stored on a User’s hard drive by the site or Solution. Its purpose is to collect data relating to the User’s browsing habits.

We use the following types of cookies on our site:

Functional cookies

We use them to remember any selections you make on our site so that they are saved for future visits.

Analytical cookies

This allows us to improve the design and functionality of our site by collecting data on the content you access and appreciate while using our site.

You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely via your internet browser, but this may decrease the quality of your user experience.

Third-party cookies

We may use third-party cookies on our site to achieve the following purposes:

      1. To help you navigate our site, optimize your web browsing and personalize the content and advertisements offered to you;
      2. To analyze your use of our site and improve the content thereof.
  1. Accuracy

We do everything in our power to ensure that your personal information is accurate and complete for the purposes for which it was collected, used or disclosed. However, in the context of the use of the proof of vaccination Solution, Akinox does not have the mandate to verify the accuracy of User data. Akinox simply acts as a technology platform for collecting and presenting data. Akinox does not have the mandate to verify the accuracy of the data as part of the proof of vaccination Solution.

  1. Responsibility

We are responsible for the personal information in our possession, including information we entrust to third parties for the purpose of providing you the requested service. We require that these third parties store such information according to strict confidentiality and security standards.

We comply with the principles set out by law. We have policies and guidelines in place to protect your privacy. Our personal information protection and information technology security officers oversee this personal information protection policy as well as the various corporate frameworks.

Our staff are knowledgeable and adequately trained on privacy policies and practices.

  1. Modifications

This privacy policy may be amended from time to time in order to comply with the law and to reflect any changes to our data collection process. We recommend that our Users review our policy from time to time to ensure that they are informed of any updates. If necessary, we may notify Users by email of changes to this policy.

  1. Contact

If you have any questions for us, please feel free to contact us:

Phone: (800) 996-9196

Email: privacy-vie.privee@akinox.com

Effective date: May 11, 2021