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PRIVACY POLICY

This Privacy Policy (“Policy”) describes the personal information that EasyAnatomy Interactive Inc. (“EasyAnatomy”, “we”, “us” or “our”) collects from or about you when you use EasyAnatomy’s EasyAnatomy software-as-a-service solution (the “Services”), how we use that personal information, and to whom we disclose it. For the purposes of this Policy, “personal information” means information about an identifiable individual.

Please read this Policy carefully. If you do not understand or agree with this Policy, you should not access or use the Services or provide us with your personal information. This Policy should be read in conjunction with the EasyAnatomy End User License Agreement (“EULA”), into which it is incorporated by reference.

This Policy was last updated on February 8, 2021. We may modify this Policy from time to time. We will provide you with notice of any material changes to this Policy by publishing or communicating the changes through our Services or website or by other means so that you may review and comment on the changes before continuing to use our Services. Your continued use of the Services after we publish or communicate a notice about any changes to this Policy means that you are consenting to the changes.

  1. Accountability and Openness

EasyAnatomy is responsible for personal information under our control.

EasyAnatomy has designated a privacy officer (“Privacy Officer”) who is accountable for our compliance with this Policy, and for ensuring that information about our policies and practices relating to the management of personal information is easily accessible.  All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing, and sent by email to privacy@Easy–Anatomy.com or by mail to:

Privacy Officer
EasyAnatomy Interactive Inc.
200-1019 Wharf Street
Victoria BC
V8W 2Y9
Canada

  1. Consent

By using the Services, you agree to the terms and conditions of this Policy and you consent to our collection, use and disclosure of your personal information as described in this Policy. You may change or withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting the Privacy Officer in writing at the address listed above (see Section 1). In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.

  1. Information Collection and Retention

We collect personal information from you only to the extent that it is necessary for the purposes set out below (see Section 4).

Information that we may collect includes:

  • User Information: We collect personal information from you when you create a user account to use or access the Services or when we need to perform maintenance on your account. This personal information includes your name, e-mail address and other contact information We collect information about your occupation and education in certain circumstances to extend your product trial period. We use this information to conduct market research.
  • Usage Data: We collect information as you use the Services, including information about how you are using the Services, your in-app purchases, your progress reviewing or marking-up content, and the characteristics of those users. This kind of usage data is anonymized and is not used by us to identify you as an individual.
  • Payment Information: When you make a purchase through the Services, we will collect your credit card, debit card or banking information and other financial data in order to process the payment.
  • Technical and Device Information: We collect information about how you access the Services, such as the Internet Protocol (IP) address of your computer or device, the date and time you accessed the Services, and the operating system and device that you are We will not attempt to link this information with your identity without your written permission. We may review server logs and anonymous traffic for system administration and security purposes, for example, to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about website usage. Information such as server log data which contains users’ IP addresses could in the case of a security breach or criminal activity be used to trace and identify individuals and we may share raw data logs with the appropriate authorities for the purpose of investigating these breaches or activities.
  • Additional Data on iOS: We collect information related to your use of the Services via the Facebook SDK, including your Facebook Advertiser ID, details about your device and operating system, a record of product use that includes the number of times you have installed and launched the product, a record of your in-app purchases, and a record of when you end your sessions. The Facebook SDK may also produce a crash report that is only available to Facebook.

Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media.

  1. Purpose – Why We Collect, Use and Disclose Information

We use this personal information for the following purposes:

  • to open and maintain user accounts;
  • to verify your identity and information that you provide to us;
  • to process, track and communicate with you about usage of the Services;
  • to establish, maintain and manage business relations with you so that we may provide you with the information, products or services that you request;
  • internal business purposes, such as administering or improving the Services;
  • to perform internal market research and conduct polls and surveys;
  • to obtain your feedback regarding the Services and our ability to address your needs;
  • to facilitate the use of certain third-party integrations such as the Facebook SDK in the Services;
  • to provide you with information and promotional materials regarding EasyAnatomy and EasyAnatomy’s products and services;
  • to protect us against error, fraud, theft or damage to our goods, our business or our property;
  • to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders; and
  • any other reasonable purpose for which you provide consent.

We reserve the right to use anonymized and aggregated information and data for any purpose (commercial or otherwise).

  1. Disclosure to Third Parties

We may disclose your personal information for the following purposes:

  • Evaluate the Services: In the event that you access the Services through a subscription purchased by an organization, we may share information about usage of the Services with certain users (e.g. instructors) and the organization that has purchased the subscription (e.g. educational institutions) for the purpose of allowing such users and organization to monitor usage and evaluate performance of the Services under the purchased subscription.
  • Required by Law: We may disclose your personal information to comply with any court order, law or legal process, including requests from government agencies, law enforcement authorities and regulators, in accordance with applicable law. We may also disclose your personal information when we believe disclosure is necessary or appropriate to detect, investigate, address and prevent fraudulent or illegal activities or investigate the breach of an agreement, including the
  • Business Transaction: We may disclose and share your personal information to explore and/or undertake a corporate transaction, including a merger, acquisition, amalgamation, IPO, reorganization or sale of EasyAnatomy. In such circumstances, we will enter into an agreement that ensures that your personal information will be used and disclosed solely for the purposes related to the transaction and will be protected by security safeguards appropriate to the sensitivity of the information.
  • Service Providers: We may share your personal information with third-party service providers, suppliers and sub-contractors who assist us in providing the Services. Whenever we share your personal information with these third-parties, we ensure that the information is properly safeguarded at all times at a comparable level of protection the information would have received if it had not been transferred.
  1. Location and Data Transfers

The personal information we collect may be stored and processed in Canada and the United States. We may transfer personal information to a third-party service provider outside of your jurisdiction of residence for storage and processing. In the event that your personal information is transferred outside of your jurisdiction of residence, the government, courts, law enforcement or regulatory agencies of that jurisdiction may be able to obtain disclosure of the date through the laws of that jurisdiction. We will take steps to ensure your information is adequately protected in accordance with the applicable privacy and data protection laws.

  1. Safeguards – How Information is Protected

We maintain reasonable security safeguards to protect your personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords, and encryption technology, maintain our paper files in locked premises, and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information.

We will continually review and update our security policies and controls as technology evolves.  However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by using the Services and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization. Despite our efforts, there is no guarantee against data breaches. In the event of a data breach, we will notify affected users at the first reasonable opportunity of the breach.

  1. Cookies

We may use “cookies” to collect information and improve the Services. A cookie is a small data file that we transfer to your computer or mobile device. We may use “persistent cookies” to save your user ID and login password for future logins to the website. We may use “session ID cookies” to enable certain features of the website, to better understand how you interact with the website and to monitor aggregate usage and web traffic routing on the website. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our website.

We may use the data collected from “cookies” and web browsers for its own purposes, both related to and unrelated to improving our Services. In the event we disclose this data to any third-party for any purposes, it will be used anonymously and stripped of any and all personal or identifying information.

  1. Minors

Minors (persons under the age of majority as defined in your jurisdiction) are not eligible to use the Services unsupervised, and we request that minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use the Services in conjunction with and under the supervision of an adult. We do not knowingly collect, use or disclose personal information from children under the age of 13. If you are the parent or legal guardian of an individual under the age of 13 who may have provided us with personal information, please contact us to have this information removed.

  1. Your Rights

Depending on where you reside, you may have one or more of the following rights relating to your personal information. Some of these rights will be subject to specific requirements or limitations under applicable law. Available rights may include:

  • Opt-out: you may “opt-out” or withdraw your consent at any time to the collection, use, disclosure or any other form of processing of your personal information by us.
  • Access, correct and erase: you may have the right to request access to and obtain a copy of any of your personal information that we hold, to request the correction of any inaccurate, outdated or incomplete information related to you or to request the deletion of your personal information under certain circumstances. You also have the right to know the types of personal information is being collected, whether your personal information is being sold or shared, and to whom it is being sold or shared.
  • Data portability: you may have the right to receive all such personal information which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another entity where this is technically feasible.
  • Objection or restriction of processing:you may have the right to object to or restrict our processing of your personal information under specific circumstances. Where your personal information is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.
  • Rights to object to the sale of personal information: you may have the right to opt-out of the sale of personal information to third-parties.
  • Right to object to processing (including profiling): you may have the right to object to processing where we are relying upon legitimate interests to process personal information. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
  • Right to object to direct marketing (including profiling): you may have the right to object to our use of your personal information (including profiling) for direct marketing purposes.

If you wish to exercise any of these rights, please contact us by sending an email to privacy@Easy–Anatomy.com. We will respond within 30 days. We may not accommodate a request if we believe the change would violate any law or legal requirement. If we cannot accommodate a request, we will provide you with a justification. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service.

  1. Governing Law

You agree that your access to and use of the Services, as well as this Policy, is governed exclusively by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles).

 

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