Privacy policy

Last updated: 01-05-2023

This policy describes the collection, processing, use and sharing of personal information and personal data about the users of the Tadeus platform (the “Platform”) and about the persons for whose benefit the Platform is used (“Clients”).

In this policy, the term personal data means information that relates to an identifiable individual.

The use of the second person (you, your, etc.) refers to the user of the Platform.

The contact details of the person responsible for the processing of personal data under this policy are as follows:

Centre Axel

info@centreaxel.com

1.Basis for processing data

Our processing of personal data is mainly based on the following principles:

  • We process your personal data to the extent necessary to provide you with the products and services as agreed with you;
  • We may process certain personal data because you have specifically consented to the processing.
  • We process personal data about Clients on the basis of the consent of the Client (obtained by the user) or of a user authorized to consent on the Client's behalf (for example the holder of parental authority);

2.Data collected

2.1.Information provided by users

We collect the information you voluntarily give us (for example by filling in a form) through our website, a survey, by email or otherwise. Providing this information is not required to use the Platform. This information may include:

  • Your first and last name;
  • Your email address;
  • The name or a pseudonym associated with a Client;
  • Information about the Client's behaviours, the interventions with the Client and the results of those interventions;

2.2.Data collected automatically from the Platform

We collect certain information automatically while you use the Platform. This information is recorded each time you interact with the Platform. The data collected includes certain information specific to your device and data about your interaction with the Platform, including the data described below:

  • The operating system and language of the device;
  • The IP address from which a device accesses the Platform;
  • The country, state, city and postal code where the device is located;
  • Browsing data, such as the pages viewed, the number of logins to the Platform, the length of a session, the dates of logins to the Platform, the features used, and the web page from which the Platform was accessed;

2.3.Information about Clients

Users are responsible for obtaining the consent of Clients to the processing of their personal information.

The Platform may allow information to be shared about persons who are unable to consent themselves to the processing of their personal information (for example minors or persons who are incapacitated or vulnerable). Users are encouraged to use pseudonyms to avoid identifying Clients, but some personal information about persons unable to give free and informed consent could nevertheless be collected through the Platform. Any processing of such information is carried out with the consent of the holder of parental authority, the tutor or curator, or a professional in a therapeutic relationship with the person concerned, as the case may be.

3.Use of data

We use your personal data for the purposes described below. Some uses concern data that is subject to a specific consent, while other uses are necessary to provide you with services.

3.1.Operation of the Platform

We use personal data collected through the Platform to provide our services to our users.

Operating the Platform involves generating recommendations based on the information uploaded to the Platform, including personal data. Personal data is used to generate such recommendations for the benefit of the users associated with a Client.

Personal data is also used anonymously for machine learning purposes and for the development of artificial intelligence models that generate recommendations automatically.

3.2.Communicating with you

We use the personal data you have given us (for example your name and email address) to communicate with you about your data and our services, but only if you have provided us with that data and agree to receive communications from us. We comply with the regulations in force regarding unsolicited email. If you no longer wish to receive electronic communications from us, you may let us know at any time by writing to the following address: info@centreaxel.com

3.3.Research

Voluntarily submitted data (which may include personal data) could be used for fundamental and applied research purposes. Only anonymized data is shared for research purposes, so the researchers involved do not have access to your identity.

3.4.Product improvement

Certain analytics data derived from the data collected through the Platform could be used to improve the Platform's features or to develop new products. For example, we could use statistics on the actions that take the most time in the Platform to change the ergonomics of a new application.

4.Data retention and security

We keep the personal data collected about Clients while the profile associated with a Client is active. We keep the personal data relating to users while their account is active and for a maximum of 3 years afterwards.

The personal data collected is stored electronically on servers located in Canada. These servers are operated by our service provider, Amazon Web Services, which undertakes in writing to process your personal data confidentially.

Our hosting service provider undertakes to use security measures that meet industry standards to preserve the integrity and confidentiality of the data. Our employees and suppliers are informed of the confidential nature of the personal data collected, and are made aware of the appropriate security measures to prevent unauthorized access to personal data.

5.Communication and sharing of data

We only share personal data as described in this policy and when we have the explicit consent of the person concerned. Your personal data could be communicated to the categories of persons described below for the purposes mentioned.

5.1.Group members

The Platform is designed for sharing information. The personal information recorded on the Platform is shared with all the users who are part of an intervention group associated with a Client, including the professional practitioners and the Client's relatives who use the Platform.

5.2.Employees

Your personal data is only accessible to our officers and employees who need to access it to use it as provided for in this policy.

5.3.Service providers

We share certain personal data with service providers that allow us to offer our services more efficiently. These providers undertake in writing to us to preserve the confidentiality of the data and not to use it other than to provide services to us. Our service providers are listed below:

| Provider | Details | Storage location | | --- | --- | --- | | Amazon Web Services (AWS) | We use AWS services to store the data shared through the application on cloud servers. AWS undertakes to use the data only to the extent necessary to provide its services to us. | Canada (Central) |

5.4.Researchers

We could share anonymized data with researchers for research purposes. This data does not contain information that identifies individuals.

5.5.Legal obligations

We could communicate personal data if the law expressly authorizes or requires it, or if we are compelled to do so by a competent authority. We will not disclose personal data unless the law expressly requires it.

5.6.Successors

If responsibility for operating the Platform were transferred to another company or organization, we may disclose personal data as part of the transaction. In such a case, those persons or organizations undertake to us to preserve the confidentiality of the personal data and to use it exclusively to assess the feasibility or advisability of the transaction and in accordance with this policy.

6.Your rights regarding your personal data

6.1.Access to your data

To access the personal data we hold about you or to have personal data we hold about you corrected if it is wrong, you may send us a written request at the following address: info@centreaxel.com or at the address of the person responsible for processing given at the beginning of this policy.

We will respond to your request promptly (within 30 days of receiving it at most) by giving you access to the personal data about you in our records.

6.2.Withdrawal of consent

If you wish to withdraw your consent to the processing of your personal data, please let us know by writing to info@centreaxel.com. If you withdraw your consent to the processing of your personal data, we will delete your personal data from our database. Where personal data is included in analysis results or is part of an anonymized dataset, these will not be changed by the withdrawal of your consent, but no further processing of your personal data will take place.

6.3.Deletion

You may request the deletion of the personal data we hold about you. To make such a request, please write to info@centreaxel.com. We will respond to your request as soon as possible (within 30 days of receiving it at most).

6.4.Complaints

Our processing of personal data is governed by the laws and regulations applicable in Canada, and the Canadian authorities have exclusive jurisdiction to receive any complaint or claim relating to our processing of your personal data.

6.5.Verification

We could verify the identity of persons wishing to access the personal data about them. Any information collected for this verification will not be used for any other purpose.

7.Changes to the policy

We may change this policy from time to time to reflect changes in our personal data management practices. If a change is made, the new policy will be available at the following address: https://tadeus.app/en/public/licence.

If you have given us your email address, we will notify you by email of any significant change to our privacy policy within a reasonable time before the new policy comes into force. If we process your personal data on the basis of your explicit consent, we will not process your data for new purposes without your explicit consent.

8.Additional information

For any additional information about the processing of your personal data, you may contact us at the address given at the beginning of this policy.