BioTwin (“BioTwin”, “we”, “us” or “our”) takes all reasonable measures and makes all reasonable efforts to protect the privacy and security of your information. This privacy policy (“Policy”) describes how we collect, use and disclose your personal information and how this personal information can be consulted and corrected when necessary. This Policy also explains how cookies are used on our Website.

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By visiting www. Biotwin.ai(“Website”), importing your information or data to the website, using the BioTwin application (“App”), importing information or data to the App, contacting us by any mean, or agreeing to receive emails from BioTwin, you accept the terms and conditions of this Policy.

This Policy does not extend to websites or apps operated by third parties. BioTwin is therefore not liable for their privacy policies, procedures and practices.

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1. Collection of Information

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We collect your personal information in different ways, when you access the Website, download the App, provide us with your information through the Website or App, request information, contact us by telephone or by email.

We collect general personal information, including information such as your name, age, email address, sex, and ethnicity.

We collect biometric and biological personal information through our questionnaires and forms, from blood, urine, saliva and sweat samples using collection devices as well as from existing third party applications, notably Strava, Facebook, LinkedIn, Garmin, and Fat secret. Collected biometric and biological personal information includes:

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• Biometrics Information

• Medical History Information

• Dietary Habits Information

• Physical Activity Information

• Sociodemographic Information

• Professional Information

• Connected Devices Information

• Related Software Information

• Information from surveys, forms and questionnaires

 

If you provide BioTwin personal information concerning another person, you must first obtain that person’s consent.

 

We may collect data relating to your visit to our Website. This information may include your IP address, the date, time and duration of your visits as well as the web pages you consulted. Our Website, like most other commercial websites, also uses cookies. These are files that are installed on your computer hard drive or web browser in order to collect information such as your language of preference, browsing history and browser type and version, all for the purpose of optimizing your experience on our Website. We use cookies to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. These cookies cannot be used to extract personal information. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to disable all cookies. Disabling cookies on your browser could

adversely affect your browsing experience on the Website.

 

If you refuse to or withdraw your consent, BioTwin will not be able to provide the features and services otherwise available through the Website and App.

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2. Use and Communication of Information

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We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We use or disclose your personal information mainly:

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• to operate, maintain, enhance and provide all features of the Website and App, to respond to comments and questions and to provide support to users of the Website and App;

• to provide customers with requested health information as part of the services and features of the Website and App, including assessments based on artificial intelligence to generate health profiles, provide assessments between biometric and biological information, and provide health information concerning the customers’ levels of stress, risk of injury, heart health, risk of diabetes, intolerance management, and bone health, as well as phenotype profiling, in order to improve wellness and support healthcare decisions;

• to provide the requested Biotwin services, to help us develop new products and features and to improve our services and product through pilot and research projects among others.

• for internal purposes such as data analysis, research, development and auditing;

• to understand and analyze the usage trends and preferences of our users, to improve the Website and App, and to

  develop new products, services, feature, and functionality for the Website and App;

• to send you communications subject to applicable laws; or,

• for any other purposes authorized or required by law.

• to Partners and/or Third Parties. In these situations, your personal informations will only be shared and/or disclose to provide or improve our services or product for research and development and to fulfill contractual obligations. At any time and upon request we can inform you about the identity of any Third Party or Partner we disclose personal information to.

 

When we disclose your personal information to service providers, we take reasonable measures to ensure that the rules set forth in this Policy are complied with.

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In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of BioTwin, in whole or in part, your personal information may be transferred as part of the transaction.

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3. Retention of Information

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Your personal information is stored under Microsoft’s Cloud Azure or on our internal servers located at our place of office. Your personal information may also be stored and processed in any country where we have facilities or in which we engage service providers. By using our Website, you consent to the transfer of information to countries outside your country of residence which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

 

BioTwin has implemented various physical, administrative and technical safeguards designed to protect the confidentiality and security of personal information under our control. However, no method of transmission over the Internet, or method

of electronic storage, is 100% secure.

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BioTwin will maintain your personal information for as long as necessary to provide the features and services on the Website or App, or as required by applicable laws, regulations, or government orders.

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4. Right to Access, Correct and Withdraw

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On written request and subject to proof of identity, you may access the personal information that we hold, and ask that any necessary corrections be made, where applicable, as authorized or required by law.

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At every moment, upon written request and subject to proof of identity, you may withdraw your consent to the use and disclosure of your personal information.

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However, to make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information.

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5. Surveys, Forms, and Questionnaires

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From time to time, BioTwin may invite you to participate in surveys fill out forms, or respond to questionnaires that BioTwin, its clients or a third party may administer. These surveys are optional, and may include personal information. They may also include questions about your personal health information, biometric information, or other personal information, as well as your experience with our services and their specific features. Such surveys are meant to help us to provide the services and features of our Website and App, and to better understand the needs and requirements of our customers so we can continue improving our products and services.

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6. Update

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We will update this Policy from time to time to reflect changes to our practices, technology, legal requirements and other factors. Please check the “Last Updated” legend at the bottom of this page to see when this Policy was last updated. When changes are made to this Policy they will become immediately effective when published in an updated Policy posted on this page unless otherwise noted. Your use of the Website and App following these changes indicates your consent to the practices described in the updated Policy. We recommend that you visit and review this Policy regularly to stay informed on our most current practices and to stay up to date on the use of your personal information.

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7. Contact

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If you have any questions or comments about this Policy or your personal information, to make an access or correction request, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer can be reached by email using the following contact information:

Legal@biotwin.ai

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Last Update: 2022-04-01