Privacy Policy - BioTwin | BioTwin

Privacy Policy

Last Update: May 20th, 2022   Hello there! We are BioTwin (“BioTwin”, “we”, “us” or “our”). It’s important for us that you trust how we handle your personal information. This is why this Privacy Policy (“Policy”) provides you with the information you need to understand how we collect, use and disclose your personal information and how this personal information can be consulted and corrected when necessary. Our mission is to improve health and wellness services, but your privacy is as important to us!   Please review carefully this Policy. By using our Services (as defined hereinafter), you consent to the collection, use and disclosure of your personal information, as precisely set out in this Policy, and as revised from time to time. We used a question and answer format so that you can navigate this Policy easily.   If you have any questions or comment about this Policy, your personal information, to make an access or correction request, to make a complaint or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer can be reached by email at :   The person responsible for the protection of personal information at BioTwin is identified below and can be reached by mail at the following address:   BioTwin – Attention : Marc-Antoine Denis 200-1405 boul. du Parc Technologique Québec (Québec) G1P 4P5 Canada  
  1. When does this Policy apply and what does it cover?
  This Policy contains information about how we collect, use and disclose your personal information when:
  1. we receive your personal information, including biological samples, from you or from your third party service providers or third party applications, for the purposes of using our health and wellness analytical services (the “Analytics Services”);
  2. you navigate our public website  (the “Website”); and
  3. you download the TwinMe App (the “App”)
  4. you exchange with us by e-mails, social media or otherwise
  In this Policy, we use the term “Services” to refer to all of the above, and where there is no distinction to make between the different aspects of the Services.   This Policy also covers our use of tracking technologies such as cookies (as defined hereinafter). For more information about what we mean by “cookies” and what we do with it, please read the section 5 of this document.   This Policy does not apply to third-party content accessible through the Services, or to the use of third-party apps, platforms or services for the purpose of connecting to our Services, as applicable. You must have your own subscription with them, and they are not our service providers. These third parties collect, use and disclose personal information in accordance with their respective privacy policies. We invite you to consult these policies carefully.  
  1. What types of personal information do you collect, and why?
  We collect personal information to provide you with our Services, to help us develop new products and features, to improve our services and product through pilot and research projects among others, for internal purposes such as data analysis, research, development and auditing,  for the purpose of obtaining analytics on your use of our Services, in connection with our marketing activities, . This section does not cover the cookies that we use, which is covered in the next section of this Policy.   If you provide BioTwin personal information concerning another person, you must first obtain that person’s consent.  
Electronic Data
IP address, mobile identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and language.
This information is collected automatically by our Services to function effectively, to fix bugs, or to improve the security of our Services. We also use this information for analytics purposes to help know more about your use of our Services. These may be collected as part of cookies.
Usage Data
Time spent on the Services, pages visited, links clicked, language preferences, pages that led or referred you to the Website.
We collect this information for analytics purposes.
Communication Data
Email addresses, identification data, publicly available information, emails content
If you communicate with us by email, on social media, by subscribing to our services-related news communications on our Websites, or by any other means, we collect the personal information that you share with us, such as your email address and the content of your communication. If you communicate with us using social media, we will have access to your publicly available information.
Analytics Services
Profile Data
Name, age, email address, sex, ethnicity.
We collect this information through our questionnaires and forms, using collection devices, as well as from your third-party service providers and applications, such as Strava, Facebook, LinkedIn, Garmin, and Fat Secret.
We use this information to provide you, directly or indirectly, with requested health information as part of the Analytics Services, including assessments based on artificial intelligence to generate health profiles, provide assessments between biometric and biological information, and provide health information concerning your levels of stress, risk of injury, heart health, risk of diabetes, intolerance management, bone health, as well as phenotype profiling, in order to improve wellness and support healthcare decisions
Health and Wellness Data
Medical history, nutrition information, physical activity Information, social information, hobbies information, professional information.
Biometric and Biological Information
Biological samples (such as blood, urine, saliva and sweat samples).
Usage Data
Connected devices information, related software information.
We collect this information for support and security purposes.
Recruiting & Marketing
Social Media
Publicly available information
If you follow us or interact with us on social media, we may process your personal information for recruiting, marketing or advertising purposes, subject to applicable laws, including those on consent.
  1. To whom do you disclose my personal information?
  Let’s be clear, we do not sell your personal information to data brokers. However, we do share your personal information with certain types of third parties to provide you with the Services, conduct marketing and as required by the law. In these situations, your personal information will only be shared and/or disclosed to provide or improve our services and/or our product in the context of research and development or to fulfill our contractual obligations.   We can also share your personal information in the context of a merger or acquisition, as part of bankruptcy procedures or for other corporate requirements. When we disclose your personal information, we take reasonable measures to ensure that the rules set forth in this Policy are complied with.   Within our organization, we take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. When we disclose your personal information to service providers, we take reasonable measures to ensure that the rules set forth in this Policy are complied with.   We encourage you to review the privacy statements and policies of those third parties so that you can understand those they collect, use and disclose your personal information.  
Service Providers
Service providers are used to providing you with some functionalities that are outsourced to third parties. For instance, to provide support or to contact you.
IT Service Providers
We use IT Service Providers to offer you the Services, such as Microsoft Azure which host the Services and your personal information (click here to jump to their privacy statement).
Marketing Partners
We use marketing partners to manage our leads and provide you with marketing content. All of these activities require the processing of your personal information, including through cookies.
If you decide to integrate our Analytics Services with third-party service providers and/or applications, this may require the sharing of personal information with these third parties.
Integration partners are not our suppliers. You are required to enter into distinct agreements with them and review their privacy policy.
Law enforcement and other authorities
We may receive requests by authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required.
  We may share your personal information with our financial and legal advisors or auditors if reasonably required, or in the event we would be required to do so to defend our rights and interests.   In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures or similar circumstances, your personal information would be considered our assets and property. In these circumstances, ownership of the personal information we collected may be transferred or we may have to share some of your personal information to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.   Where do you store my personal information, how long do you retain it and how do you keep it secure?   Your personal information is stored on Microsoft’s Cloud Azure servers, which are located in Canada and in USA. By using our Services, you consent to the transfer of personal information to countries outside your country of residence which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.   BioTwin will retain your personal information for as long as necessary to provide its Services, or as required by applicable laws, regulations, or government orders.   BioTwin has implemented various physical, administrative, organizational, technical and technological safeguards designed to protect the confidentiality and security of personal information under our control, taking into account the sensitivity, amount, distribution and format of such information. As mentioned above, Microsoft hosts our Services and your personal information on our behalf. Click here to jump to their Trust Center, which provides more information on security safeguards related to Microsoft Azure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  
  1. Do I have any rights over my personal information?
  Yes you do! However, these rights vary depending on where you are located.   You generally have the right to access your personal information and to correct it if inaccurate, in certain circumstances. On written request and subject to proof of identity, you may access the personal information that we hold, and ask that any necessary corrections be made, where applicable, as authorized or required by law.   At every moment, upon written request and subject to proof of identity, you may withdraw your consent to the use and disclosure of your personal information.   However, to make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information.   If you want to exercise your rights, you can contact us using the contact information provided at the beginning of this Policy.   We will respond to your request within 30 days. If we can’t comply with your request, we will tell you why.   If you are located in Canada, note that the Office of the Privacy Commissioner of Canada drafted a FAQ to help you access your personal information when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:   Telephone 9:00 am to 4:00 pm EST Toll-free: 1-800-282-1376   Mailing address Office of the Privacy Commissioner 30 Victoria Street Gatineau, Québec K1A 1H3  
  1. How can I manage my cookie preferences?
  You can always manage your Cookie preferences. However, some functionalities may require Cookies in order to perform as expected, or for security purposes. You can control your Cookie preferences through your browser. Depending on the browser that you are using, different instructions are applicable. Click on your browser for more information:  
  • Google Chrome
    • You can also browse on Incognito Mode while using Chrome.
  • Firefox
  • Safari
  • Internet Explorer
  • Opera
  1. Surveys, Forms, and Questionnaires
  From time to time, we may invite you to participate in surveys, fill out forms or to respond to questionnaires that we, our clients or a third party may administer. These surveys are optional and may include personal information. They may also include questions about your personal health, biometric information, or any other personal information. It may as well include questions about your experience with our services and their specific features. Such surveys are meant to help us provide the services and features of our Website and App and to better understand the needs and requirement of our customer so that we can continue to improve our products and services.         7. Can you change this Policy?   We will update this Policy from time to time to reflect changes to our practices, technology, legal requirements, and other factors. Please check the “Last Updated” legend at the top of this page to see when this Policy was last updated. When changes are made to this Policy, they will become immediately effective when published in an updated Policy posted on this page unless otherwise noted. Your use of our Services following these changes indicates your consent to the practices described in the updated Policy. We recommend that you visit and review this Policy regularly to stay informed on our most current practices and to stay up to date on the use of your personal information. For more info 
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