Cerebra Privacy Notice

Last Updated on November 23, 2022. This privacy notice is effective immediately.

At Cerebra, we respect your privacy and are committed to protecting it.

Cerebra has created this Privacy Notice to describe our data practices regarding the personal information we collect about users of the Cerebra website available at cerebra.health and about users of Cerebra products. This Privacy Notice applies to all user personal information collected by Cerebra through this website and the Cerebra product but does not apply to any patient health information as this is covered under applicable health institution policies.

This Notice applies to the protection of personal data established by the Canada Personal Information Protection and Electronic Documents Act (PIPEDA) and undertakes to apply to any privacy regulation that may come into force in any territory in which Cerebra is active.

Personal data is processed by Cerebra Medical Ltd, whose head office is located at 1470 Willson Place, Unit B, Winnipeg, Manitoba, Canada, R3T 3N9.

Information We Collect

We collect personally identifiable information about you when you use our website and the Cerebra product.

NOTE: We do not knowingly collect personally identifiable information from persons under 16 years of age, and no part of the website or product is directed to persons under 16.

Information you provide to us or to a third party

We collect the personal information you voluntarily provide to us, such as your name, contact information, company, and title, when you register for a Cerebra product account (an “Account”), when you sign a contract, or when you request further information from the website.

Information collected by technologies

Cookies – Like many online services, we use cookies to collect information. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. Cookies serve a functional purpose and improve the user website experience. If you decide at any time that you no longer wish to accept cookies from our site, then you can change your browser’s settings. If you do not accept cookies, however, you may not be able to use all portions of the website.

Log files – As is true of most websites and products using browsers, we gather certain information automatically and store it in log files. These logs contain the IP address automatically assigned to your computer when you are on the internet, the browser you use, and the time and date you visited. Cerebra uses log information to help us identify popular features, to resolve user problems, and to improve the design of our product.

How we use your personal information

The personal data collected is used as part of the services provided by Cerebra through its website and the Cerebra product. Using the data minimization principle, Cerebra commits to collect only the personal data necessary and are for the following purposes:

• Processing a request for information or providing product marketing/product information that we think will be of use to you,
• To carry out our obligations and enforce our rights arising from contracts entered between you (or your health institution) and us,
• Creating and managing your user account,
• Product updates,
• Educational and product support,

In compliance with the regulation applicable to the use of your personal data, Cerebra reserves the right to use your data for information purposes on its products and services or for any other purpose evident and necessary to the information of the user.

In general, Cerebra uses your personal information to respond to your requests or to aid us in serving you better. We use personal information to perform data analysis and audits, safeguard and protect our site and the Cerebra product, improve the site and the Cerebra product, create Accounts, identify usage trends, provide improved administration of our site and related products, identify you as a user in our system, send you administrative email notifications, respond to your inquiries, and to provide you the services you request.

Cerebra also creates anonymous data records by excluding information that makes the data personally identifiable to you. We use such anonymous data records for any purpose, except where required to do otherwise under applicable law.

How we share your information

Cerebra shares or transfers your personal information as described below and as described elsewhere in this Notice:

• Cerebra may share your personal information to comply with any court order, law or legal process, including for legal, medical, or security reasons, to respond to any government or regulatory request, or in connection with a merger, financing, acquisition or dissolution transaction.
• We will share your personal information with third party service providers to: provide you with the services that we offer through our website or products; to conduct quality assurance testing; to facilitate the creation of Accounts; to provide technical support; and/or to provide other services to Cerebra. In this case, all third parties are committed to follow applicable data protection regulations. This obligation is provided in the contracts that bind these third parties to Cerebra according to data protection rules.

Personal information is processed in the country in which it was collected and in other countries where laws regarding the processing of personal information may be less stringent than the laws in your country. By providing your personal information, you consent to such transfer.

How we protect your information

Cerebra’s goal is to protect personal information submitted through its site and its products. Cerebra maintains technical, administrative and physical safeguards designed to protect against unauthorized disclosure, alteration, use or destruction of the personal information you provide. Cerebra implements all the measures at its disposal to create an environment for preserving the quality, security, and integrity of your personal data.

Cerebra also employs reasonable technologies to help keep the personal information you provide secure including: encryption, firewalls, system alerts and other information system security technologies; housing health data in secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information technology systems, facilities, and information collection, storage and processing practices.

However, we cannot ensure or warrant against all risks regarding the security of that information, so the information you choose to transmit to Cerebra and which we store is provided to us at your own risk. Cerebra does not guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our safeguards. In addition, other services or Internet sites that may be accessible through Cerebra have separate data and privacy practices independent of us, and we disclaim any responsibility or liability for their policies or actions.

Storage Period of Your Personal Data

Cerebra retains your personal data only for the duration necessary for the operations for which they were collected and in compliance with the applicable regulations in force. Your personal data used in the Account/contract creation is kept for the duration of the contract and for an additional seven (7) years for purposes of regulatory compliance and commercial, without prejudice of the obligations of conservation or the limitation periods. Prospective customer data is retained for a period of three (3) years from the date of the data collection or from the last contact with Cerebra.

Individual Rights

You may send us an e-mail via our contact link to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change would violate any legal, accounting, or health regulation requirement, cause the information to be incorrect, or if there is an unresolved issue with your account.

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via the Contact Us link.

Marketing emails

If you have signed up for our marketing list, we will periodically send you email newsletters that directly promote the use of the website and our product. When you receive promotional communications from us, you are always invited to indicate a preference to stop receiving further promotional communications from us and will have the opportunity to “opt-out” or withdraw your consent by following the unsubscribe instructions provided in the email or by directly contacting us at the address listed on the Contact Us page of our site. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to this Privacy Notice.

Changes to this Notice

We may revise this Notice from time to time as we add new features or modify the way in which we manage information, or as laws change that may affect our services. If we do, we will post the changes on the website and update the last updated date. We encourage you to periodically review this Notice, to see if there have been any changes that may affect you.

Contacting Cerebra

If you have any questions, concerns, or grievances about this Notice or our data processing practices, or if you have a request for access to your personal data that Cerebra has, please contact the Privacy Officer at Cerebra at 1470 Willson Place, Unit B, Winnipeg, Manitoba, Canada, R3T 3N9. Or by email at privacy@cerebrahealth.com. Cerebra will address any privacy issues within one month from the date of receipt.