NEURAPULSE PRIVACY POLICY

Introduction

Impirica Inc. ("we," "us," "our" or "Owner") values your ("User") privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, and protect the personal information you provide when accessing and using the Neurapulse website ("Website"), Neurapulse portal ("Service"), and Neurapulse web-based application ("App").

  1. 1. Information We Collect

    • Test Information: When you participate in a cognitive test, we collect your test responses and results.

    • Device Information: We collect information about the device you use to access the App, including your IP address, device type, and browser type.

    • Usage Data: We collect information about how you use the App, Service, and Website including the date and time of your test, IP address, browser type, and pages visited.

    • Account Information: When you register for an account, we collect your name, email address, and other contact details.

    • Campaign Data: Information related to the cognitive testing campaigns you create and manage, including test participant information and test results.

    We collect and process your data based on your consent, which you can withdraw at any time.

  2. 2. How We Use Your Information

    • To provide and maintain the Service

    • To communicate with you about your account and campaigns

    • To administer and score the cognitive test

    • To provide your test results to the manager who requested the test

    • To improve the App, Service, and Website based on usage patterns and feedback

    • To comply with legal obligations and protect our legal rights

  3. 3. Data Sharing and Disclosure

    • With Your Employer or Potential Employer: We share your test results with the manager who requested the test.

    • With Test Participants: We share test results with the test participants whose tests you manage.

    • With Service Providers: We may share your information with third-party service providers who assist us in operating the App, Service, and Website.

    • With Research Partners: Redacted data may be shared with the University of Alberta for research and development purposes.

    • For Legal Reasons: We may disclose your information if required by law or in response to legal processes.

    • International Data Transfer: If we transfer personal data outside Canada, we will ensure that appropriate safeguards are in place to protect the data in accordance with applicable regulations.

  4. 4. Data Collection, Use, and Disclosure

    • What Will Be Released:

      • Neurapulse cognitive responses

      • All information or statements relevant to the Neurapulse assessment processes or results, including any interference or refusal to comply with the assessment process

      • All information or statements obtained during the Neurapulse assessment process that suggest a concern for safety or fitness to work

    • Parties That Will Release and/or Receive Information:

      • Employer/Prospective Employer

      • Employer/Prospective Employer's designated third-party service provider involved within the Neurapulse assessment process and/or information tracking

      • Impirica Inc. (for evaluating assessments, producing results, and research and development)

      • University of Alberta (research partner using redacted data for research and development)

      • Authorized contacts designated by the Employer/Prospective Employer

  5. 5. Data Security

    We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure. In the event of a data breach, we will notify affected individuals, and the appropriate regulators as required by legislation.

  6. 6. Data Retention

    We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Data will be regularly reviewed and securely deleted when no longer needed.

    Further information about retention time

    Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

    Therefore:

    • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
    • Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
    • The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
    • Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

  7. 7. Your Rights

    We collect and process your data based on your consent, which you can withdraw at any time. You have the right to access, rectify, erase, restrict processing, and to data portability. You can exercise these rights by contacting our Data Protection Officer at privacy@neurapulse.com.

    The rights of Users based on the General Data Protection Regulation (GDPR)

    Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:

    • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
    • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
    • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
    • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
    • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
    • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
    • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
    • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

    Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

    How to exercise these rights

    Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users' request, the Owner will inform them about those recipients.

  8. 8. Research and Ethics As a cognitive test participant, your redacted data will be used in an academic study titled: ‘A cognitive performance application to predict driving behavior and fitness for duty.’ This study has been reviewed for its adherence to ethical guidelines by a Research Ethics Board at the University of Alberta. For questions regarding participant rights and the ethical conduct of research, please contact the Research Ethics Office at reoffice@ualberta.ca.

    • Ethics ID: Pro00131244

    • Principal Investigator: Dr. Anthony Singhal, Department of Psychology, asinghal@ualberta.ca

  9. 9. Risks and Benefits of Using the App

    • Risks: Other than minor fatigue, risks do not exceed those encountered in daily life.

    • Benefits: Improved ability for employers/potential employers to identify safe and unsafe workers, mitigate work-related injuries, and enhance workplace safety.

  10. 10. Changes to This Privacy Policy

    We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the App, Service, and Website.

  11. Contact Us

    If you have any questions or concerns about this Privacy Policy, please contact us at privacy@neurapulse.com.