INTRODUCTION
MoCA Test Inc. (“MoCA Cognition”, "Company" or "We") respect your privacy and are committed to protecting it by complying with this privacy policy.
This policy describes:
- Describes the types of information we may collect from you or that you may provide to us when you access the XpressO website located at https://portal.mocacognition.com ("Website") or the XpressO application (“App”, collectively, the “Services”).
- How we collect, use, disclose, and protect the Personal information (defined below) of our Services users ("you").
- Our practices for collecting, using, maintaining, protecting, and disclosing Personal information.
We will only use your Personal Information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
"Personal information" means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
The Services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
Please read this policy carefully to understand our policies and practices for collecting, processing, using and storing your information. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree and acknowledge that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued access to or use of the Services we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, e-mail address, password, and any other identifier we may use to contact you. Note that the only information you have to provide us in order for us to create an account are your name, e-mail address and password. You may also choose to provide other types of information, such as nationality, age, location, company, profession.
We provide an opportunity for any user to unsubscribe from our newsletters or email communications or opt-out of contact for marketing purposes on an ongoing basis by accessing our Website or App, using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing us at [email protected].
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as Test results, demographic information, or other statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website or App feature.
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
- Non-personal details about your Website or App interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
- Automated technologies or interactions, as you navigate through our Website or App. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to Us
The information we collect directly from you on or through our Website or App may include:
- Information that you provide by filling in forms on our Website or App. This includes information provided at the time of registering an account to use the App. We may also ask you for information every time you conduct a Test, before you obtain Test results, and when you report a problem with our Website or App.
- Records and copies of your correspondence (including email addresses), if you contact us.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website and App, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website or App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and App and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website or App according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website or App.
The technologies we use for this automatic data collection may include:
- Cookies (or browser, HTTP or app cookies). A cookie is a small file placed on the hard drive of your computer, on your browser, or within the App. You may refuse to accept cookies by activating the appropriate setting. However, if you do so, you may be unable to access certain parts of our Website or App. Unless you have adjusted your setting (e.g. browser setting) so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or App.
- Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website, App and their contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
- To provide you with notices about your account/subscription, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts with you, or to comply with legal requirements.
- To notify you about changes to our Website, App, or any products or services we offer or provide though it.
- To improve our Website, App, products or services, marketing, or customer relationships and experiences.
- To communicate with you.
- In any other way we may describe when you provide the information.
- Anonymized or de-identified information may be used for research, analytical or quality purposes, without further notice to you.
- For any other purpose with your consent.
We may also use your information to contact you about news, offers, products and promotions that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or use the unsubscribe mechanism at the bottom of our e-mails, or e-mail us at [email protected].
DISCLOSURE OF YOUR INFORMATION
We may disclose anonymized or aggregated information about our users, and information that does not identify any individual, without restriction, including without limitation, for research, analytical or quality purposes.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates.
- In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MoCA Cognition's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MoCA Cognition about our customers and users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MoCA Cognition, our customers, or others.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website or App improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
DATA SECURITY
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where you have chosen or we have given you a password for access to or use certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or App.
DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose, including without limitation for research, analytical or quality purposes, without further notice to you or your consent.
INDIVIDUALS UNDER THE AGE OF 18
Our Services are not intended for individuals under 18 years of age. No one under age 18 may provide any information via the Website or App. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not access or use the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from an individual under 18, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us at [email protected].
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us.
By logging into your account, you may change and delete your personal information. If you want to delete your account as well as your personal information, you may do so by sending us an email at [email protected].
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [email protected] or at [email protected]. Please note that if you withdraw your consent we may not be able to provide you with a particular service, including access to the App or Website.
CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised privacy policy.
We include the date the privacy policy was last revised at the bottom of this page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
CONTACT INFORMATION
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us our Privacy Officer by email at [email protected], or by mail at:
Updated: January 19, 2024