Bia Neuroscience Inc. (“Bia”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy to describe the manner in which we collect, use, disclose and otherwise process personal information when you visit our website located at https://getbia.com/ (the “Website”), download and use our mobile application (the “App”, collectively with the Website, the “Platform”), or otherwise interact with us. Through the Bia Smart Sleep Mask, Bia helps measure, control and improve users’ sleep using technology such as neurofeedback, neural soundscapes , and sunrise wake up to guide users’ brains through the sleep stages and personalized insights to allow users to understand how sleep affects their health (the “Services”).
TABLE OF CONTENTS
- Bia Privacy Principles
- Collection and Use of Personal Information
- Sharing of Personal Information
- Information About Our Platform
- Interest-Based Advertising
- Safeguards and Retention
- Your Choices
- Our Privacy Governance Policies and Practices
- Updates to the Privacy Policy
- Contact Us
BIA PRIVACY PRINCIPLES
- You’re in total control of your data
Bía is a steward of your data. Your personal information belongs to you (not us), and you can decide how it is used, subject to applicable laws. Our goal is to make it easy for you to see, export, and delete your own information. - We respect your right to privacy and will protect your information.
We'll work to collect as little information as needed to provide a valuable service, and we will continually look for ways to collect less. - We will never monetize your data.
We don’t sell (or sell access to) your data to third parties for advertising or for any other purposes.
COLLECTION AND USE OF PERSONAL INFORMATION
Means of Collection
We collect personal information that you provide directly to us (through our Website, or through other communication channels) as well as information your devices provide to us automatically.
How we collect and use personal information through the Website and in our other interactions with you
We may collect and use personal information when you:
- Create an account and use the App.
- Use the Services.
- Visit the Website.
- Sign-up to receive marketing emails such as newsletters, offers and promotions.
- Apply for a job at Bia.
- Attend our events.
- Participate in our surveys or research.
- Enter our contests or promotions.
- Contact us with a comment, question or complaint.
Creating an Account and Using the App: To access and use our App, you will be required to create an account and provide personal information such as your first and last name, email address, phone number, and mailing address, and you will be prompted to create a password. We use this information to create and administer your account, and to communicate with you about the Services. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password or other credentials in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately. Once your account is activated, we may collect information to create your profile, and information about your device’s registered locale and language preferences.
Services: To make use of the Services, you must register for an account. To administer the Services, we may collect your sleep data such as movement, light, body temperature, audio, and brain activity through functional near-infrared spectroscopy (fNIRS). We collect this information to gain a deep understanding of sleep activity, to generate neurofeedback to improve sleep, and to create insights and sleep scores based on your sleep data. All audio is analyzed on the device; we do not transfer or store any direct sound recordings to our servers. We may also collect your date of birth, sex, skin tone, weight, height, sleep rating, and other information about you if you choose to provide us with such information. These are completely optional, and are used to better calibrate our sensors and algorithms to your body for more accurate data and insights so that we can ensure that our product works for all.
When using Bía, you may add tags and notes to your sleep data as well as conduct other activities within the app such as cognitive tests (brain games) or sleep quizzes. You may also choose to connect with third-party aggregators (like Apple or Google Health) to sync sleep data, heart rate data, and other activity data from any other wearables you may own. Bía uses this data to generate personalized insights to help you better understand how to improve your sleep and performance.
Payment: If you purchase the Bia Smart Sleep Mask and use the Services, we (or our authorized third-party payment processor) will collect your full name, payment information (including billing address, credit card number, expiry data and CVV code), in order to process the transaction and provide you with the Services you have purchased.
Visiting the Website: You do not have to register to visit or use our Website. However, we do collect some personal information when you visit our Website. Please see "Information about our Website," below, for detailed information regarding the personal information we collect when you visit and use our Website, and the choices you have with regards to that collection.
Marketing Communications: If you sign up to receive email, SMS and other marketing communications, we will collect your name, email address and phone number in order to send you newsletters, offers, promotions, and other information that may be tailored to your interests and preferences. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.
Careers: In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
Events: If you attend one of our events (or visit a booth at an event), we may collect business contact information such as your first and last name, company name, work email address and phone number. We collect this information so that we can communicate with you about the event and contact you about future events.
Surveys and Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other research projects. We will collect certain personal information about you if you choose to participate in a research survey of ours. The information we collect will depend on the particular survey or research project and we will provide you with specific details regarding our information practices for that survey or research project prior to collecting any information from you. The information obtained through our surveys and customer research is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Website.
Contests or Promotions: When you enter a contest or participate in a promotion, we may collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you. We use this information to administer your participation in the contest or promotion. As part of a contest or promotion, we may obtain your consent to share or otherwise publish the content you submit.
Contact Us: When you contact us with a comment, question or complaint through email, phone, or through our “Contact us” form on our website, you may be asked for information that identifies you, such as your name, address, a telephone number, account details, payment information, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and products.
De-Identified and/or aggregated research data : We may modify, de-identify, or aggregate your personal information to generate research data that cannot reasonably be associated with you. We do this to protect your privacy and the security of your information, and to use or share the data, such as to conduct research and analytics, identify usage trends, learn more about sleep, determine the effectiveness of our promotional campaigns and commercial activities, make improvements to the Website and the Services, improve our algorithms, and develop new features. Access to this research database is limited to those with a scientific need like researchers or data scientists. If your non-identifiable data is used for research purposes, then the limitation of liability and indemnity clauses contained within the Terms of Use Agreement are waived with respect to any harms suffered or liabilities incurred as a result of any research activities.
If you don’t want to contribute your data for research and development, you can opt out in the Privacy Settings section of the app.
SHARING OF PERSONAL INFORMATION
We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.
- Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf (including our affiliates). We use service providers to provide services such as hosting Website, processing payments, providing customer and technical support, and providing advertising and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We and our service providers may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States, where we or our service providers are located.
- Legal and Compliance: We and our U.S., Canadian, and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable U.S., Canadian or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
- Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Bia or as part of a corporate reorganization or other change in corporate control.
INFORMATION ABOUT OUR PLATFORM
- Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
- Cookies: Our Website uses a technology called "cookies. "A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.
- Analytics: We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
- Third-Party Links: Our Platform may contain links to other applications or websites that Bia does not own or operate. We provide links to third-party applications or websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked applications or websites. The linked applications and websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such applications and websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked applications and websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every application and website you visit.
In addition, when you install or use our App, we may collect and use the following additional information:
- Usage Data: When you access and use the App, we may automatically collect certain details of your access to and use of the App, including information about the type of device hardware and operating system, unique device identifier, IP address, and language settings of your device. We also collect information about the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
- Information about your Device: As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
INTEREST-BASED ADVERTISING
We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our App in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our App and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third-party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
Please note that even if you opt-out of interest-based advertising by a third-party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We will retain personal information as long as necessary to fulfill the purposes stated herein unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described here, we make backups of certain data, which we may retain for longer than the original data.
YOUR CHOICES
Marketing Communications
As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.
Exercising Your Privacy Rights
We will take reasonable steps to ensure that personal information is not used unless it is accurate and up to date. We request that you regularly review the information you have submitted to us using the Website and promptly notify us if any information submitted is no longer accurate or correct.
Where required by applicable law, you may have the right to access, update, rectify and correct inaccuracies in, and withdraw consent to the processing of, your personal information in our custody or control. You may make such a request or withdraw consent by emailing or writing to us using the contact information set out below. We may request certain personal information for the purpose of verifying your identity when you seek access to your personal information.
To opt out of interest-based advertising, see the “Interest-Based Advertising” section above.
OUR PRIVACY POLICIES AND PRACTICES
We are committed to protecting personal information and have implemented policies and practices that govern our treatment of personal information, including:
- a privacy framework that defines the roles and responsibilities of our employees with respect to the treatment of personal information in our custody and control;
- the designation of a Privacy Officer who is responsible for overseeing Bia’s compliance with applicable privacy legislation;
- practices pertaining to privacy training and awareness for our employees with access to personal information;
- policies and procedures regarding the protection of personal information, including safeguards designed to protect personal information in our custody and control against loss or theft and unauthorized access, use or disclosure;
- processes for responding to data subject requests and complaints concerning the handling of personal information in a timely and effective manner; and
- a framework governing the retention and destruction of personal information that is designed to ensure compliance with our legal and contractual obligations.
UPDATES TO THE PRIVACY POLICY
We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.
CONTACT US
If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to or correction of your personal information, please contact us at:
Andrew Jolie, CMO
+1-844-242-6275