Privacy Policy

1. Introduction

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”).

1.2 This Privacy Policy details the Axem Neurotechnology Inc. practices in connection with the collection, use and disclosure of Personal Information (as that term is defined below) and the circumstances when Axem Neurotechnology Inc. may disclose such Personal Information.

1.3 By visiting the Axem Neurotechnology Inc. Website, you acknowledge that you accept the practices and policies as detailed in this Privacy Policy and you consent to the collection, use and sharing of your Personal Information by Axem Neurotechnology Inc. as detailed in this Privacy Policy.

1.4 This Privacy Policy deals with the treatment of information about identifiable individuals and information which can be used to identify an individual (“Personal Information”) about visitors to the Axem Neurotechnology Inc. Website as well as our prospective and current customers. This Privacy Policy does not extend to the practices of companies or people that are not controlled or managed by Axem Neurotechnology Inc.

2. Commitment

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

4.1 Personal information submitted to Axem Neurotechnology Inc. through the Axem Neurotechnology Inc. Website will be used for the purposes specified in this Privacy Policy or on the relevant pages of the Axem Neurotechnology Inc. Website.

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

5.1 Axem Neurotechnology Inc. may disclose your Personal Information to any of its employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy.

5.2 Axem Neurotechnology Inc. may disclose your Personal Information to any Axem Neurotechnology Inc. Affiliate (which shall mean for the purposes of this Privacy Policy any individual or corporation, partnership, trust, incorporated or unincorporated association, joint venture, limited liability company, or joint stock company that, directly or indirectly through one or more intermediaries, controls or is controlled by or is under common control with such individual or corporation, partnership, trust, incorporated or unincorporated association, joint venture, limited liability company, or joint stock company) insofar as reasonably necessary for the purposes set out in this Privacy Policy.

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.

5.4 Except as provided in this Privacy Policy or otherwise with your consent, Axem Neurotechnology Inc. will not provide your Personal Information to third parties.

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.

6.2 You expressly agree to the transfers of Personal Information described in this Section 6 and as may be provided elsewhere in this Privacy Policy.

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.

9. Amendments

9.1 Axem Neurotechnology Inc. may at its sole discretion and without notice update this Privacy Policy from time to time by publishing a new version on the Axem Neurotechnology Inc. Website.

9.2 You should check this page occasionally to ensure you are happy with any changes to this Privacy Policy.

9.3 Axem Neurotechnology Inc. may notify you of changes to this Privacy Policy by email.

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.

10.5 Website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Axem Neurotechnology Inc. Website. If you refuse cookies, you do so with the knowledge that such refusal will result in a drawback to the extent that certain features of the Axem Neurotechnology Inc. Website may not function properly without the aid of cookies. For more information about how Axem Neurotechnology uses cookies, please see Section 12 below.

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. Cookies

12.1 The Axem Neurotechnology Inc. Website uses cookies.

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

Questions regarding this Privacy Policy or Axem Neurotechnology Inc.’s privacy practices should be directed to our Privacy Officer:

Privacy Officer
Axem Neurotechnology Inc.
Unit 100, 1505 Barrington St.
Halifax, NS, B3J 3K5
Email: privacy@axemneuro.com

Last Updated: June 29, 2018