HealthQB Technologies Inc.
LAST UPDATE: April 14, 2020
1. WHY DOES THIS MATTER?
At HealthQB Technologies Inc. (“HQB”), we take data protection seriously. Our goal is to generate insights
into your autonomic nervous system and broader biopsychosocial state to enable you and your
healthcare providers to better treat and manage your health challenges and concerns. We appreciate and
respect your privacy, your right to control your personal information, and how your personal information is
treated. Safety of your information is of paramount importance to us. We therefore hope that you take a
moment to review this policy.
Please note that certain measurement data collected via the apps and device may be regarded as health
related data under data protection laws in certain jurisdictions.
2. ABOUT THIS POLICY
aims to answer the following questions:
• What personal data we collect when you use HQB products and services
• How we store and process your data
• Your legal rights and how to exercise them
a data controller. Additional terms and conditions imposed by the third-party device manufacturer
(Biostrap USA, LLC) and the third-party software provider (LifeData, LLC) may apply.
date at the top of this page.
3. OUR CONTACT INFORMATION
HealthQB Technologies Inc.
Address: Suite 1, 2230 Cornwall Ave, Vancouver, BC V6K 1B5
Data Protection Officer: Privacy Officer,
4. HOW DO THE DEVICE AND APPS WORK?
When worn, the device automatically collects data of your body responses during your sleep. That data is
uploaded wirelessly to your mobile phone via the mobile app. The subjective capture app also prompts
you to provide information regarding your subjective state. The device and the apps are connected to
your computer/phone and a cloud service and your data can be made available to you and/or your
5. WHAT PERSONAL DATA DO WE PROCESS?
When registering for an account or during your use of it, we may process the following general account
data as inserted by you:
• E-mail address
• Birth date and year
• Height and weight
• Notes and tags
• Billing information
The device automatically tracks and collects biometric data, including the following:
• Heart rate
• Heart rate variability
• Movement data
• Duration of sleep
• Sleep phases (deep, light, REM, awake)
• Activity levels throughout the day
The subjective capture app will collect the following information from you:
• emotional state
• health routines
• lifestyle factors
• mental state
• social state
• pain level
We also may track and generate certain usage related and technical data:
• IP address and high-level location
• User ID (anonymized and randomly generated eg, Amazing Human #39)
• Log and Device Information
• Cookies and Tracking Information
• Metadata regarding app use
Based on your submitted data and measurement data, the device and apps may calculate a variety of
parameters, such as:
• Duration of sleep
• Sleep phases (deep, light, REM, awake)
• Activity levels throughout the day
• Average subjective state
The foregoing information is used to produce evaluation data regarding the health of your autonomic
nervous system, your psychophysiological states, social state, quality of your sleep, level of your
nocturnal recovery, and daily strain on your nervous system.
6. DATA SOURCES
Some of the information are received directly from you in connection with your registration, which is
anticipated just to be basic contact information. Measurement data is collected automatically by the
tracking functions of the device and survey information you submit which is collected via the subjective
capture app. Data is also produced by combining the data listed above.
7. PURPOSES AND LEGITIMATE GROUNDS FOR COLLECTION, USE AND DISCLOSURE OF
Purposes of collection, use and processing
To provide you the service
We collect, use and process personal data in the first place to be able to offer the apps and service to our
Users in accordance with their user agreement.
We may process personal data for the purpose of communicating with Users. If you contact our support
with questions regarding your app data, we will use the provided information to answer your questions
and for solving any issues you may have.
For analytics and service improvements
We may process aggregated information regarding the use of our Service to improve our app quality.
When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
We process personal data on the basis of a user agreement, which is formed in connection with the
creation of an account and acceptance of our terms and conditions. We may also process certain
information to comply with legal obligations, such as consumer protection legislation.
Furthermore, we process the personal data to pursue our legitimate for aggregated analytics and trend
detection. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our
own interests against your right to privacy.
Measurement data or any data derived from measurement data is used for advertising only subject to
your explicit consent.
8. SHARING YOUR PERSONAL DATA
and group subsidiaries. Otherwise we do not share personal data with third parties outside of our
organization unless one of the following circumstances applies:
To the extent that third parties need access to personal data to enable the offering of the service, HQB
has taken appropriate contractual and organizational measures to ensure that personal data is processed
For legal reasons
We may share personal data with third parties outside HQB’s organization if we have a good-faith belief
that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law,
regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues;
and/or (iii) protect the interests or safety of HQB or our Users in accordance with the law. Where possible,
we will inform Users about such transfer and processing.
To our authorized service providers
We may share personal data to authorized service providers who perform services for us (including data
storage, sales, marketing and other support function services). Our agreements with our service providers
include commitments that the service providers agree to limit their use of personal data and to comply
mind that if you provide personal data directly to a third party, such as through signing up with our device
provider or subjective capture software provider, or through a link on our website, the processing will be
based on their policies and standards.
For other legitimate reasons
If HQB is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party
involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to
all Users concerned when the personal data are transferred or become subject to a different privacy
policy as soon as reasonably possible.
With your explicit consent
We may share personal data with third parties outside HQB’s organization for other reasons than the
ones mentioned before, when we have the User’s explicit consent to do so. The User has the right to
withdraw this consent at all times.
9. ANONYMIZED DATA
We may aggregate and anonymize data collected via the application. Once anonymized such data will not
be able to be connected to an individual User, and therefore no longer be considered personal
information. We may use this type of anonymized data for analytics, statistics, research, communications
and PR purposes as well as for trend detection and for benchmark data. The aggregated and anonymized
data may be used to write a scientific report. Your privacy will be protected in any scientific publication or
presentation of it.
10. HOW LONG DO WE KEEP YOUR DATA?
HQB does not store personal data longer than is legally permitted and necessary for the purposes
specified above. The storage period generally depends on the duration an account lifecycle, unless data
has been deleted upon request. Backups are deleted as soon as reasonably possible, we expect this will
typically be within 12 months.
11. YOUR RIGHTS
Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform
you what personal data we have collected and processed regarding you.
Right to withdraw consent
In case the processing is based on your consent, you may withdraw the consent at any time. Withdrawing
a consent may lead to fewer possibilities to use our products or services. The withdrawal of consent does
not affect the lawfulness of processing based on consent before its withdrawal.
Right to correct
Users have the right to have incorrect or incomplete personal data we have stored about the User
corrected or completed. You can correct or update some of your personal data through your user account
Right to erasure
Users may also ask us to erase the User’s personal data from our systems. We will comply with such
request unless we have a legitimate ground to not delete the data or unless data has been aggregated
Right to object
Users may object to the processing of personal data if such data are processed for other purposes than
purposes necessary for the performance of our products or services to the User or for compliance with a
legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we
shall no longer process the personal data after your objection.
Right to restriction of processing
Users may request us to restrict processing of personal data for example when your data erasure,
rectification or objection requests are pending and/or when we do not have legitimate grounds to process
your data. This may however lead to fewer possibilities to use our products or services.
Right to data portability
Users have the right to receive their personal data from us in a structured and commonly used format and
to independently transmit those data to a third party.
How to use the rights
The above-mentioned rights may be used by sending a letter or a secured e-mail to us on the addresses
set out above, including the following information: the full name, name, address, e-mail address and a
phone number. We may request the provision of additional information necessary to confirm the identity of
12. DIRECT MARKETING AND PUSH NOTIFICATIONS
Notwithstanding any consent granted beforehand for the purposes of direct marketing you may have
given, you have the right to prohibit us from using your personal data for direct marketing purposes by
contacting us or by using the unsubscribe possibility offered in connection with our newsletter.
We will ask your explicit consent if we wish to send you push notifications or to use any health-related
data for marketing purposes.
13. DATA OF CHILDREN
We do not knowingly process data of children under the age of 18 without parental consent.
Please note that according to our terms and conditions we reserve the right to delete accounts of children,
in particular if no proof of parental consent is provided.
14. SAFEGUARDING YOUR DATA
We do our best to keep your data safe and secure.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we
collect and process. Measures may include, for example, where appropriate, encryption,
pseudonymization and access right systems. Our security controls are designed to maintain an
appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We
regularly test our products and services, systems, and other assets for security vulnerabilities.
We will take all reasonable precautions to ensure that our staff and employees who have been specifically
granted access to information about you have received adequate training to ensure that they process that
information only in accordance with this policy and with our obligations under applicable legislations.
Should despite of the security measures, a security breach occur that is likely to have negative effects to
your privacy, we will inform you and relevant authorities as required by applicable data protection laws.
15. SOCIAL MEDIA AND PUBLIC FORUMS
The application may enable you to publish certain information from your application related to your HQB
experience or biometric or subjective state data on social media sites such as Facebook, Instagram and
Twitter, online blogs and forums.
If that feature is available to you, please think carefully before deciding what information you share, in
connection with your User Content. Please note that we do not control who will have access to the
information that you choose to make public in such forums, and cannot ensure that parties who have
access to such information will respect your privacy or keep it secure.
We are not responsible for the
privacy or security of any information that you make publicly available on social media, online blogs or
public forums – or what others do with information you share.
16. LODGING A COMPLAINT
In case you consider our processing of personal data to be inconsistent with the applicable data
protection laws, a complaint may be lodged with the applicable data protection supervisory authority,
which in British Columbia, Canada is the Office of the Information and Privacy Commissioner.