1.1 Axem Neurotechnology Inc. provides its website visitors with access to information, updates and certain products and services that the company may make available from time to time (the “Services”) through this website (the “Axem Neurotechnology Inc. Website”).
2.1 Axem Neurotechnology Inc. is committed to creating a safe and secure online environment and safeguarding the privacy of its website visitors.
3. Collecting Information
3.1 Website visitors may access the Axem Neurotechnology Inc. Website while remaining anonymous and without disclosing any Personal Information.
3.2 During a visit to the Axem Neurotechnology Inc. Website, Axem Neurotechnology Inc. may collect, store and use the following kinds of Personal Information from website visitors, including but not limited to:
(a) information about your computer and about your visits to and use of the Axem Neurotechnology Inc. Website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to Axem Neurotechnology Inc. for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(c) information that you provide to Axem Neurotechnology Inc. when using the Services on the Axem Neurotechnology Inc. Website, or information that is generated in the course of the use of those Services;
(d) information contained in or relating to any communication that you send to Axem Neurotechnology Inc. or send through the Axem Neurotechnology Inc. Website;
(e) any other Personal Information that you choose to send to Axem Neurotechnology Inc.
4. Using Personal Information
4.2 Axem Neurotechnology Inc. may use your Personal Information to:
(a) contact you;
(b) administer the Axem Neurotechnology Inc. Website and business;
(c) enable your use of the Services available on the Axem Neurotechnology Inc. Website;
(d) send you non-marketing commercial communications;
(e) send you email notifications that you have specifically requested;
(f) send you the Axem Neurotechnology Inc. email newsletter, if you have requested it (such circulation can be terminated at any time at your request and notification to Axem Neurotechnology Inc.);
(g) provide aggregated and anonymized statistical information only to third parties about Axem Neurotechnology Inc. users;
(h) address any queries and/or complaints made by or about you relating to the Axem Neurotechnology Inc. Website;
(i) maintain Axem Neurotechnology Inc. Website security and prevent fraud.
4.3 Axem Neurotechnology Inc. will not, without your express consent, supply your Personal Information to any third party for the purpose of their or any other third party’s direct marketing.
5. Disclosing Personal Information
5.3 Axem Neurotechnology Inc. may also disclose your Personal Information:
(a) to the extent that Axem Neurotechnology Inc. is required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise, protect or defend the legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) of Axem Neurotechnology Inc.;
(d) to the purchaser (or prospective purchaser) of any business or asset that Axem Neurotechnology Inc. are (or are contemplating) selling.
6. International Data Transfers
6.1 We may from time to time employ third parties to perform tasks on our behalf and we may need to share Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we may engage include companies and individuals employed by us to facilitate our services, including the provision of maintenance services, database management, Web analytics, customer relationship management, and general improvement of the Services, and businesses who engage our services (to the extent provided for above).
Axem Neurotechnology Inc. uses the following sub-processors, which are located in the United States: Amazon Web Services, MailChimp, Hubspot, Google, Monster Insights. Accordingly, Personal Information that Axem Neurotechnology Inc. collects about its visitors and users may be stored and processed in the United States.
7. Retaining Personal Information
7.1 This Section 7 sets out the Axem Neurotechnology Inc. data retention policies and procedure, which are designed to help ensure that Axem Neurotechnology Inc. is compliant with its legal obligations in relation to the retention and deletion of Personal Information.
7.2 Personal Information that Axem Neurotechnology Inc. processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 Notwithstanding the other provisions of this Section 7, Axem Neurotechnology Inc. will retain documents (including electronic documents) containing Personal Information:
(a) to the extent that Axem Neurotechnology Inc. is required to do so by law;
(b) if Axem Neurotechnology Inc. believes that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend the legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) of Axem Neurotechnology Inc.
8. Security of Personal Information
8.1 Axem Neurotechnology Inc. will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your Personal Information.
8.2 Axem Neurotechnology Inc. will store all the Personal Information you provide on its secure servers.
8.3 You are advised that Axem Neurotechnology Inc. uses third party vendors to provide the necessary hardware, software, networking, storage and related technology required to run the Axem Neurotechnology Inc. Website. By using the Axem Neurotechnology Inc. Website you acknowledge that your data may be stored on a third-party storage server and transmitted through third party networks.
8.4 You acknowledge that the transmission of information over the internet is inherently insecure, and Axem Neurotechnology Inc. cannot guarantee the security of data sent over the internet.
10. Your Rights
10.1 You may instruct Axem Neurotechnology Inc. to provide you with any Personal Information Axem Neurotechnology Inc. may hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, Axem Neurotechnology Inc. may accept a photocopy of your passport certified by an attorney or bank plus an original copy of a utility bill showing your current address).
10.2 Axem Neurotechnology Inc. may withhold Personal Information that you request to the extent permitted or required by law.
10.3 You may instruct Axem Neurotechnology Inc. at any time not to contact you for marketing purposes.
10.4 In practice, you will usually expressly agree in advance to the use by Axem Neurotechnology Inc. of your Personal Information for marketing purposes.
11. Updating Information
11.1 We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
11.2 Please let Axem Neurotechnology Inc. know if the Personal Information that Axem Neurotechnology Inc. holds about you needs to be corrected or updated.
12.2 A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.3 In particular, Axem Neurotechnology Inc. uses Google Analytics and HubSpot cookies on the Axem Neurotechnology Inc. Website. The Google Analytics cookie generates a unique ID for each browser session another built-in Google Analytics feature then anonymizes IP addresses. Cookies do not typically contain any other Personal Information that may personally identify a user, but Personal Information that Axem Neurotechnology Inc. stores about you may be linked to the information stored in and obtained from cookies.
12.4 Most browsers allow you to refuse to accept cookies.
13. Child Users
13.1 Protecting the privacy of young children is especially important to Axem Neurotechnology Inc. Axem Neurotechnology Inc. does not knowingly collect or maintain Personal Information from persons under 13 years for age (“Child Users”). The Axem Neurotechnology Inc. Website is not directed to Child Users. If Axem Neurotechnology Inc. becomes aware of Personal Information that has been collected from a Child User without verified parental consent, Axem Neurotechnology Inc. will delete such information.
14. Residents of the European Economic Area (“EEA”)
14.1 Axem Neurotechnology Inc. generally processes Personal Information in order to fulfill contracts we have with our end users and to pursue our legitimate business interests listed above. In circumstances described throughout this policy, Axem Neurotechnology Inc. will obtain express consent from an individual in respect of processing of Personal Information.
14.2 Individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individual End Users, Customers or prospective Customers located in to the EEA who wish to exercise these rights, should contact Axem Neurotechnology Inc. using the contact information below.
15. Additional Information
Axem Neurotechnology Inc.
Unit 100, 1505 Barrington St.
Halifax, NS, B3J 3K5
Last Updated: June 29, 2018