CONFIDENTIALITY AND PRIVACY POLICY

Version effective as of March 14, 2022

This confidentiality and privacy protection policy hereinafter the ” Privacy policy applies to information services for people over the age of 14 in Quebec and Canada in order to help them look after their emotional health (” Services “). These Services are rendered by EmoScienS Inc, a corporation incorporated under the Quebec Business Corporations Act (“ EmoScians “) Where (” we “) via our EmoScienS application (“Application”) or our website at www.Emosciens.com (“Site”) and describes, where applicable, the collection and processing that may be made of the Personal Information of users of EmoScians (“ you ” Where ” user(s) “).

This Privacy Policy is intended to help you understand our practices regarding the collection, use, disclosure and retention of personal information to provide you with our services. We protect your privacy by ensuring the protection, confidentiality, non-alteration, availability and security of the personal information you entrust to us by creating a user account, using the Application or browsing our Site, by email, in person or by telephone, you agree that these will be treated in accordance with what is indicated in this Privacy Policy.

The security of your information and transparency are important to us. We are committed to the highest standards of data protection and thank you for the trust you place in us.

Since 2024, EmoScienS has been using the services of the Hume AI platform for facial expression analysis in order to detect emotions. Hume AI acts as a third-party provider of artificial intelligence technologies. Portrait photos sent to EmoScienS are analyzed using deep learning models deployed by Hume AI. The results of this analysis are then transmitted to EmoScienS to be displayed on the user’s dashboard. The portrait photos sent to Hume AI are temporarily processed to generate emotional metrics. In accordance with their policies, these photos are not retained by Hume AI beyond the time required for processing. Hume AI states that it adheres to high data protection standards as outlined in its privacy policy. EmoScienS uses its services in a way that aims to minimize risks and comply with applicable laws but cannot guarantee or be held responsible for the exact processing practices implemented by Hume AI, which operates as an independent technology provider.

Hume AI’s privacy policy and terms of use are available at: https://www.hume.ai/privacy-policy and https://www.hume.ai/terms-of-use. We encourage our users to review them before using any of our services that involve the capture of facial expressions.

Processing via Hume AI takes place in the United States, which may involve the cross-border transfer of personal data to a jurisdiction whose privacy laws differ from those of Canada and Quebec. EmoScienS does not have direct control over Hume AI’s data processing practices outside of Canada. However, we strive to assess the overall compliance of our providers with recognized privacy principles, notably by reviewing their public policies and favoring providers that demonstrate a commitment to data security. EmoScienS disclaims any responsibility for regulatory obligations or data processing practices implemented by Hume AI outside our jurisdiction.

By using the EmoScienS Services, you are considered a “user” and, as such, you are entering into a user agreement with us. This implies that you accept the terms and conditions of our Terms of Use, as well as this Privacy Policy.

For the purposes of this Privacy Policy, “Personal Information” means any information relating to a natural person that directly or indirectly allows that person to be identified.

As will be detailed in this Privacy Policy, you have a discretionary choice to refuse to share your Personal Information.

In terms of Quebec, Canadian and European laws on the protection of privacy, EmoScienS is designated as responsible for processing the data of EmoScienS.

By using the services of EmoScienS or its Application and by browsing its Site, you acknowledge having read, understood and accepted this Privacy Policy.

If you do not consent to this Policy, please do not disclose your Personal Information to us by not creating a user account or by not using the Application. Send us an email to the coordinates indicated in the section entitled “Contact” if you want us to take the necessary steps to have your Personal Information erased.

1. COLLECTION AND USE OF YOUR PERSONAL INFORMATION

1.1. To create a user account for the purpose of using the EmoScienS Application, you will be asked to share the following Personal Information with EmoScienS: your email address and your first and last name. No other communication of Personal Information is required to use the Application.

1.2. The personal information collected and generated by EmoScienS is as follows and is collected and used for specific and legitimate purposes as described below:

  • User name : necessary for the purposes of identification and personalization of the Services;
  • User’s first name : necessary for the purposes of identification and personalization of the Services;
  • User password : necessary for identification and protection purposes;
  • User’s email : necessary for the purpose of communication with the latter;
  • Authentication question : Question entered by the user. The user is prompted to choose a question to which only he knows the answer. The answer to this question allows the user to recover his password using the forgotten password recovery procedure;
  • Authentication Response : This is the response to the above question. Directly registered by the user;
  • Portrait photos of users : necessary for the creation of emotional profiles. User portrait photos are destroyed following their analysis. They are not stored in any database;
  • Emotional Metrics : Necessary for the provision of the Service. These are the results of analysis of the portraits which in no case can be used for profiling within the meaning of the law applicable to this Privacy Policy.

1.3. Disclosure of personal information on a voluntary basis. If you contact us at the coordinates mentioned below in the “Communication” section, we will then have access to the information that you share with us, including your contact details, and any questions asked or any comments made (for example, by questionnaires). We will then collect this information to respond to you and, if necessary, react to the identified situation.

1.4. As part of these communications and the voluntary disclosure of personal information on your part, EmoScienS undertakes:

  • to maintain confidentiality;
  • to store it in a way that we cannot identify you and;
  • to use them only in this format, for scientific research and teaching purposes (by our responsible researchers and their collaborators) and for statistical and development purposes of EmoScienS, and this, in order to promote emotional health. None of these uses will be made for the purpose of (or in such a way as to) identify you.

1.5. Special case of Biometric Data: “Portrait photos” – By definition, biometric data correspond to a unique physiological signature that makes it possible to differentiate and identify individuals. Note that user photos are considered biometric data. EmoScienS takes a photo of your face (“Portrait Photo”), at regular intervals (by default, 12 images per hour), and the Portrait Photos are saved on your electronic device (eg, computer, telephone, tablet).

1.5.1. The EmoScienS software is not and will never be used to identify you, but only to extract emotional patterns from your facial expressions, and provide you with this data in return.

1.5.2. You have the option to choose the portrait photos you wish to send to our secure server, which forwards them to Hume AI for analysis. Once analyzed, the photos are automatically deleted within a maximum of 24 hours. Neither EmoScienS nor Hume AI stores the photos beyond this period. The results (emotional metrics) are then stored on our servers hosted in Canada. As soon as the portrait photos are transmitted to EmoScienS’s Google Cloud server, they are deleted from your device.

1.5.3. Once they have been processed, the photos are deleted daily from the EmoScienS servers. The photos are only stored for the time required to be analysed, ie a maximum of 24 hours, after which they are destroyed.

1.5.4. Under no circumstances will these partner companies have access to your Personal Information. However, in the event that these companies need access to your Personal Information in order to provide their services, you accept and consent to such access. By written contractual agreement, we will require these companies to process your information in accordance with this Privacy Policy and applicable law, and to sign a non-disclosure agreement. However, we will not be liable for any damages that may result from the misuse of your Personal Information by anyone.

1.5.5. The terms and conditions, and the privacy policies of these third parties are available here, it is your responsibility not to use the services of EmoScienS if you do not agree to these terms:

1.5.6. In Quebec, as of September 22, 2022, the creation of a bank of biometric characteristics or measures must be disclosed to the Commission d’Accès à l’Information (“CAI”) no later than 60 days before it is put into service. . Regarding EmoScienS, this declaration was received by the CAI on January 6, 2022 (#1027679-S).

2. YOUR CONSENT

2.1. Your express consent. By providing us with your Personal Information, you expressly consent to our collection, holding and use of your Personal Information in accordance with this Privacy Policy and applicable laws and regulations. As such, we will only collect and use your Personal Information in the cases provided for by law.

2.2. Non-disclosure. EmoScienS will not disclose your Personal Information to third parties unless such disclosure is permitted by applicable law or unless you expressly consent to the disclosure.

2.3. Withdrawal of your consent. Your participation in the EmoScienS solution is completely voluntary. You may withdraw your consent at any time by writing to the Privacy Representative using the contact information provided below in the “Communications” section. Your request will be processed within 30 days. Withdrawing your consent will not affect the lawfulness of processing based on your consent prior to its withdrawal.

3. USER RIGHTS: ACCESS, DELETION AND CORRECTION OF PERSONAL INFORMATION

3.1. The surname, first name, email, password, authentication question, authentication response, and emotional metrics are kept by EmoScienS always in respect of the purpose of their collections as long as you do not ask them. deletion.

3.2. You have the right to request access to and correct the Personal Information we hold about you. You can also ask us to provide a copy of your Personal Information. The user’s identification information, known to the latter, can be accessed and corrected upon written request sent by email to the Personal Information Protection Officer using the contact details provided below in the “Communications” section. “.

3.3. Special case of biometric data : “Portrait photos” – Portrait photos taken from users will be deleted within 24 hours of their emotional analysis.

3.4. The choice of portrait photos sent to EmoScienS allows the user to control the information concerning him that he divulges. Once these Portrait Photos have been sent to the EmoScienS Google Cloud server, the user can no longer access them insofar as they will be deleted on the same day as their sending. The results derived from the analyzes of the Portrait Photos are accessible on the user’s personalized dashboard. These data, since analyzed, cannot be rectified. However, the user can control the Photos portraits that he sends to EmoScienS to try to rectify the analysis of the Photos portraits generated by the algorithms used by EmoScienS.

3.5. We will retain Personal Information provided to us for as long as we need it to fulfill the purposes for which we originally collected it, unless otherwise required by applicable law. When the purpose for which the Personal Information was collected expires, we will destroy or anonymize it in accordance with industry best practices. In the event that anonymized information is generated from your Personal Information, this information will only be used to serve serious and legitimate interests.

3.6. In accordance with applicable law, you have the right to request the deletion of any Personal Information. To do so, please contact our Privacy Officer using the contact details provided in the “Communications” section of this Privacy Policy. We will delete your Personal Information within a reasonable period of 30 days. Note that certain regulations may require us to retain your Personal Information for a specified period. Also note that we may not be able to delete information that does not allow us to easily identify you. This would be the case for information that has been disassociated from your identity and is used for quality improvement or analytical purposes. Once this data has been anonymized, it may no longer be possible to determine which user it came from.

4. TECHNOLOGY

4.1. Technologies relating to the Application. Certain technologies such as, for example, technical cookies (small file stored by a server in the terminal (computer, telephone, etc.) of a user and associated with a web domain) necessary for the operation of the EmoScienS Application are linked to the general information about your device to ensure the consistency and security of your session when you are logged into your user account. These technologies are required for EmoScienS to function properly, and will be automatically removed if you delete the EmoScienS Application.

Do not hesitate to contact us for any question relating to this subject.

4.2. Cookies and logs relating to the Website. The Website uses cookies to facilitate your navigation on the Website. These cookies do not collect Personal Information about you. You can change your browser settings to refuse cookies. Under no circumstances will this information be used to identify individuals or their browsing habits outside the Website. They will however be used for traditional digital advertising or remarketing.

The Website also uses log files to collect statistics and improve our service. The information compiled is general and does not include Personal Information.

If you use a computer in a public place or if you share a computer with other users, be sure to erase the traces of your navigation stored in the history before ending each session.

You can get more details by consulting our Cookies Policy

5. SECURITY MEASURES

5.1. We put in place the measures reasonably required to preserve the security and confidentiality of your Personal Information. To this end, we only keep this information in a format that does not allow us to identify you. In addition, our Application, platforms and servers are hosted in Canada. Even if we use technologies deemed adequate, the EmoScienS Application and its content – like any technology – is not infallible or immune to unforeseeable events. You should be aware that there is risk associated with the use of any technology. We cannot guarantee that your access or use of the EmoScienS Application or its content, as well as third parties, will not be subject to a data interception or other uncontrollable event (“confidentiality incident”).

5.2. The research team behind the EmoScienS software, as well as the aforementioned subcontractors, have implemented several technical measures to optimize the security of the data collected by the software, including the following:

  • Encryption of electronic devices hosting data, stored data and saved data (as a backup)
  • The transfer of data to GoogleCloud is protected by an SSL encryption protocol.
  • Limited access to collected data. Only three people have access to the data collected by the EmoScienS software.
  • Portrait Photos sent to EmoScienS are automatically deleted from the local memory of the user’s computer, just like Portrait Photos that are not selected for sending. In addition, the portrait photos once analyzed are deleted during the day from the EmoScienS servers in order to limit the risk of breach of confidentiality.
  • Access to the databases collected by the EmoScienS software is impossible via the Internet. The databases are only accessible through a Web programming interface secured by an authentication system.

5.3. If you have any questions about the security of our application, please contact our Privacy Officer using the contact details provided in the “Communications” section of this Privacy Policy.

6. PRIVACY INCIDENT

In the event of a confidentiality incident relating to one of your Personal Information (“personal data breaches”), we will comply with the procedure provided for in applicable law and we invite you to write to us to find out about our Privacy Policy. confidentiality incident. In the event that this privacy incident is likely to cause serious or serious harm to you under the terms of applicable law, we will take all reasonable steps to notify you, as well as apply all required corrective measures and notify any competent authorities. , as well as the authorities of third countries where necessary in accordance with applicable laws.

If you have any questions about the security of the Application or Website, you can contact our privacy officer, Pierrich Plusquellec, whose contact details can be found in section 8.7 “Communication”.

7. HYPERLINKS

The content of the Application or the EmoScienS Website may include links to external websites operated by third parties (“Hyperlinks”). It is important to understand that these hyperlinks are provided for informational purposes only, among other things to facilitate your access to more information regarding emotional alertness and the prevention of emotional disorders. By clicking on these hyperlinks, you will leave the Application or the Website for those of third parties, which may be subject to different privacy protection policies and practices. This Privacy Policy is no longer applicable when you leave our Application or Website. Please consult the privacy policies of these other sites to which you are redirected before providing Personal Information. We are not responsible for the Personal Information collection, use and disclosure practices of other entities that you may access from our Application or Website, and we do not accept any responsibility in this regard. Indeed, we remind you that:

  • these resources are not controlled by us;
  • we do not systematically validate their content and;
  • we cannot guarantee their content.

8. OTHERS

8.1. Complete agreement. This Privacy Policy constitutes, together with the Terms of Use , the set of rules applicable to your use of EmoScienS and its content.

8.2. Amendment. Please note that we reserve the right to modify this Privacy Policy and our Terms of Service at any time. These modifications will then be brought to your attention by a notice displayed on the identification page of the Application and on the home page of the Website.

8.3. Prior to the entry into force of these amendments. These changes cannot have a retroactive effect on the aforementioned documents.

8.4. Acceptance. By continuing to use EmoScienS following modifications that have been publicly revealed or brought to your attention, you are deemed to have fully accepted them; if you do not accept these changes, you must stop using our application and close your user account or delete the Application from your device when these changes take effect.

Last modification: May 26, 2025

8.5. Governing Law and Competent Jurisdiction. This Privacy Policy must be interpreted in accordance with the laws of the province of Quebec and the laws of Canada that apply in this province, excluding any principle that may lead to the application of foreign laws. You irrevocably agree, unless required by law, that any dispute arising from these Terms of Use shall be submitted to a competent court in the judicial district of Montreal, province of Quebec.

8.6. French and English language. If a problem of definition or interpretation arises between the English and French versions of this agreement, the French version prevails.

8.7. Communications. You can contact the Personal Information Protection Officer, Pierrich Plusquellec, at the following coordinates:

Email: info@EmoScienS.com
Phone: 514-360-8855

We strive to respond to any communication within 30 days of a user’s request, and at the latest within the time limits provided for by applicable laws.

If you are not satisfied with the response to your request, you may file a complaint with the Privacy Commissioner of your province or territory, or with the Office of the Privacy Commissioner of Canada. If you reside outside Canada, and we are considered responsible for the processing of your information, you are free to address any complaint concerning the exercise of your rights to the competent authorities of your country of residence.