IN VIRTUO PRIVACY AND CONFIDENTIALITY POLICY

Respecting confidentiality is an important concern at In Virtuo. In accordance with the law on the protection of personal information in the private sector, we are committed to preserving the confidentiality of personal information collected in the course of our activities. The purpose of our privacy policy is to inform you about our practices regarding the collection, use, disclosure, retention and protection of your personal information. By providing us with your personal information, you agree to the terms of this policy and authorize us to process your information in accordance with it.

1. Consent

1.1 Commitment to the protection of privacy

We are committed to protecting the privacy of our users and customers. We collect and use personal information only with their explicit consent and in compliance with applicable laws.

1.2 Acceptance of the terms of our policy

By accessing our website www.invirtuo.com or providing us with personal information, you agree to the terms of our Privacy and Confidentiality Policy. This includes your consent to the collection and use of your personal information in accordance with this policy.

1.3 Right to withdraw consent

You have the right to withdraw your consent at any time. However, this is subject to certain legal or contractual restrictions. We will inform you of the possible consequences of such withdrawal, such as the impossibility of supplying certain products or processing certain requests. Your decision to withdraw will be recorded in our files.

1.4 Exceptions to the need for consent

In certain exceptional circumstances, we may collect, use or disclose personal information without obtaining your prior consent. This may occur in situations where legal, medical or security imperatives make it impossible or impractical to obtain your consent. These situations include, but are not limited to, suspected breach of contract, fraud prevention or detection, or law enforcement purposes.

2. Collection of personal information

For individuals receiving business consulting services from In Virtuo, In Virtuo is committed to respecting and promoting the confidentiality of its clients’ personal information. Furthermore, In Virtuo protects the identity of its clients and does not exchange any information about them, unless it has received their prior written authorization describing the information that may be exchanged with other partners.

For its software, In Virtuo does not collect or exchange any data regarding immersed individuals using its software (e.g. patients, healthcare professionals) during and/or about virtual reality immersions, including, but not limited to, user identification, choice of virtual environments selected, frequency of immersions, user behaviors or reactions, movements in the environment, or options used in menu configurations.

For customers who purchase virtual environments from In Virtuo via a license, In Virtuo protects the identity of the purchasers of its software and does not exchange any information about them, unless it has received their prior written authorization describing the information that may be exchanged (e.g. posting on the In Virtuo website an institution or clinic using its software, or referring patients to an institution or clinic with its software). We record our customers’ names and addresses, e-mail addresses and the name of the licensed product, as well as the start and expiry dates of licenses. Our customers’ banking information is stored at our head office (i.e., not online) and cannot be shared. The alphanumerical keys used for the licenses are generated and maintained with a highly secured system by our subcontractor Soraco Technologies from Montréal, Canada. The following information on our clients is saved on their servers: name and address email address, name of the licensed product, as well as the dates of beginning and end of the licenses. Soraco technologies and its staff do not have access to this information.

For our website, In Virtuo collects the IP address of visitors for statistical purposes only. In addition, we only collect the name and e-mail address of visitors who write to the In Virtuo team with a request for information via our contact link (http://invirtuo.com/contact/).

We use Google Analytics to track visitor activity on the site and generate statistics to better target areas for future promotional offers. The IP address collected is processed solely by our professional team and the information is not shared with any other party.

We only retain personal data where we have a legal basis to do so (e.g. contract signing, expression of legitimate interest and request for quotation and other legal obligations). We implement measures to ensure the security of the site and to protect your personal data from access by unauthorized third parties.

3. Children’s privacy

We do not knowingly collect or solicit personal information from children under the age of 14. By using our website, you confirm that you are at least 14 years of age. If you are under 14, please do not attempt to send us any personal information. If we discover that we have inadvertently collected personal information from a user under the age of 14, we will attempt to delete that information from our files and records immediately. We also encourage website users under the age of 14 to ask their parents or guardians for permission before sending any information about themselves over the Internet.

If you believe that a child under the age of 14 has provided us with personal information, please contact us using the contact details provided on our website.

4. Use and sharing of personal information

We use your personal information only for essential activities, such as processing payments and issuing receipts, managing licenses, responding to your requests (if any) or responding to Health Canada inquiries.

The personal information collected by In Virtuo is accessible only to personnel who absolutely need it in order to efficiently handle financial transactions, activate and maintain licenses, respond to technical support requests and ensure compliance with applicable laws and regulations. In the event of non-payment, certain information may be shared with external collection agencies.

5. Links to other websites

Our website may contain links to third-party websites. When you follow these links, you leave our website. Information exchanged at that time is no longer subject to our privacy policy. We recommend that you read the privacy statements of other websites you visit before providing any information.

6. Security of personal information

To ensure the security and confidentiality of personal information, In Virtuo adopts rigorous security measures, including both physical and technological aspects. Here are a few concrete examples:

• Physical security: Use of electronic locking systems and security locks for access to offices, cupboards and filing cabinets, and restricted access to areas where personal data is stored.
• Access controls: Restrict access to personal data to authorized employees only.
• Staff training: Regular staff training in data security best practices.
• Intrusion detection and monitoring: Set up systems to monitor suspicious activity and detect potential intrusions.
• Disaster recovery plans: Develop plans to rapidly restore data in the event of an incident such as an outage or cyber-attack.
• Stéphane Bouchard, Ph.D., President of In Virtuo (s.bouchard@invirtuo.com).

These measures are designed to protect personal information from unauthorized access, use or disclosure, and to maximize its integrity and confidentiality. While we make every effort to protect your personal data, it is important to keep in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. We therefore cannot guarantee their absolute security.

Each employee, director, volunteer, independent contractor or ad hoc consultant working for In Virtuo or member of the Board of Directors undertakes to respect the personal information we collect. In addition, these individuals undertake to maintain the confidentiality of information specific to our activities and not to divulge it or use it for personal gain or for the benefit of others. This commitment exists from the moment the employee, director, volunteer, independent contractor or ad hoc consultant takes up his or her post, and continues indefinitely.

6. Retention and Destruction of Personal Information

We will only retain your personal data for as long as is necessary for the purposes set out in this privacy policy. We will retain and use it to the extent necessary to comply with our legal obligations, to resolve disputes and to enforce our legal policies.

We will also retain usage data for internal analysis purposes. This data is generally kept for a shorter period, unless it is used to enhance the security or improve the functionality of our website, or we are legally obliged to keep it for longer.

7. Your rights

As part of our privacy policy, we recognize and respect the fundamental rights of individuals affected by the personal information we hold. These rights include:

• Right of access: Individuals have the right to consult the personal information we hold about them. For example, a customer may ask to see the data collected when their license was created.
• Right of rectification: If information is inaccurate or incomplete, data subjects may request that it be updated.
• Right to de-index: Individuals may request that their personal information be withdrawn from circulation, or that any hyperlink associated with their name be de-indexed, if such circulation causes them harm or is in violation of the law or a court order. This right to erasure or forgetting allows individuals to control the availability of their personal information on the Internet.
• Right to file a complaint: In the event of concerns about the processing of their data, individuals may lodge a complaint in accordance with our established process.

Subject to applicable laws, upon receipt of a written request from an individual and after verification of his or her identity, we will inform the individual whether we hold personal information about him or her and will disclose such information to him or her.

We may refuse a person access to his or her information in accordance with applicable laws, in which case we will give reasons for such refusal.

To facilitate these rights, the contact details of our Privacy Officer are clearly indicated in points 6 and 10 of this document for any questions or concerns. These measures ensure that individuals can exercise their rights in complete confidence and transparency.

9. Policy changes

This policy may be updated to reflect changes in our practices or legal requirements. Changes will be posted on our Web site. We encourage you to periodically review this privacy policy to stay informed of any changes.

10. Contact

Any requests or questions regarding this privacy policy may be sent to Stéphane Bouchard, the person responsible for the protection of personal information, at the following address

• By e-mail: s.bouchard@invirtuo.com
• By mail: 5 rue d’Orsonnes, Gatineau, Qc, J8Y 6H2

Policy effective date: May 30, 2018
Last update: August 12 2024