Privacy Policy

ZENPATH PRIVACY POLICY

EFFECTIVE DATE: DECEMBER 22, 2021

Welcome to Zenpath.

Zenpath Inc. (“Zenpath”, “we”, “us”, or “our”) wants you to be familiar with how we collect, use, transfer and disclose your personal information. This Privacy Policy (“Policy”) applies to personal information we collect through your use of the Zenpath related mobile and web applications, website, as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively the website and web and mobile applications shall be referred to herein as the “Apps”, and all else including our content, products and services shall be collectively referred to herein as the “Services”) and any other interactions you have with us. It is mutually understood that the terms of this Policy are incorporated in our Terms of Use (“Terms”).

By clicking “I agree”, by installing or using our Apps, by using or accessing our Services, or otherwise signalling your acceptance or interacting with us, you consent to the collection, use, transfer and disclosure of your personal information by Zenpath in accordance with the terms of and for the purposes set out in this Policy, as they may be amended from time to time. You further agree to revisit this Policy from time to time to review any updates or changes. If you are using the Apps or the Services as a representative or agent of an entity, you are agreeing to this Policy on behalf of that entity. Before you input any personal information, including personal health information, into the Apps and/or Services, we will request and you must provide your express consent to our collection, use, transfer and disclosure of your personal information as described in this Policy.

The information you share with Zenpath allows us to provide the products and services you need and want while giving you the best user experience we can. We respect the trust you place in us and the privacy of the information you share. Part of providing superior customer service includes making sure that we are building a relationship of trust with you. We do this by letting you know in a clear and prominent way how we collect, use, share and most importantly protect your personal information.

We reserve the right to make changes to this Policy at any time and for any reason. We will alert you about any changes by updating the “Effective Date” of this Policy. Any changes or modifications will be effective immediately upon posting the updated Policy on the Apps and/or Services, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Policy by your continued use of the Apps and/or Services after the date such revised Policy is posted.

SUMMARY OF PRIVACY POLICY

We may collect the following personal information when you register with us, install, use or access our Apps and Services, or otherwise provide your information or interact with us:

First name,
Nickname,
Email address,
Personal health information related to how you are feeling (physically and/or mentally).

We use Cookies, other similar tracking technologies, and Google Analytics to collect website and App usage information, including Internet Protocol (“IP”) address and browser configuration of your device, the date and time of your request, the uniform resource locator of the referring and/or exiting websites.

We may use your personal information for the following purposes:

provide you with our Apps and Services;
to provide you with support and handle inquiries;
to improve the quality and functionality of the Apps and Services;
for statistical purposes
if you choose, to present you with relevant content, marketing materials and advertisements, by analyzing your interests from how you use our Apps and Services;
to communicate with you about our Services, including updates or newsletters;
to conduct surveys and market research;
to ensure that our Apps and Services remain functioning and secure;
to investigate, prevent or act on any illegal activities or violations of our Terms of Service; and
to comply with any applicable law and assist law enforcement agencies as required.

We use artificial intelligence (i.e. regression, clustering and classification algorithms to build AI models for recommendations, virtual assistants and chatbots) to collect and process information such as users’ to-do’s, habits, roles, goals and responses to our questions, surveys and homework. We process such information to better understand our users (i.e. why do you want to do this task, what does completing this task mean to you, how are you feeling today, etc.) in order to improve your user experience by offering better recommendations in-App (in terms of ordering your personalized task/action item list), and suggesting useful roles, values, principles, actions, habits, and goals.

We may share your personal information with the following parties:

Individuals or organizations who are our advisers or consultants;
The following advertising, marketing and analytics service providers:

Google Analytics: www.google.com/policies/privacy/partners/;

To a third party in the event of a change of ownership, or a grant of a security interest in, all or part of Zenpath;
Other service providers, including individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading our computer systems, provide email solutions, hosting services, or other systems with whom we sync to-do lists, calendars and process the meaning of user submitted text (i.e. Google Calendar, Google Tasks API, Trello (https://www.atlassian.com/legal/privacy-policy), Google Cloud Natural Language (https://cloud.google.com/natural-language)).

You have the following choices:

We will request your opt-in for the use of cookies and similar tracking technologies on our website and Apps. You may opt-out or disable cookies and other tracking technologies thereafter through the settings in your browser.
We will request your opt-in to send you push notifications upon registration. If you no longer wish to receive these notifications (after you opt-in), you may turn them off at the browser or mobile device level, or by emailing us at privacy@zenpath.io.
You may sign up for our mailing list in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing e-mails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting us at privacy@zenpath.io.
You may contact us to opt out of the use or sharing of your personal information, including for marketing or advertising purposes, and/or the provision of your personal information to our business partners for such purposes.
We use Google Analytics on our website (not within the Apps). You may control your advertising preferences or opt-out of certain Google advertising products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

Contact Us

For more information on our Policy, our privacy practices, or to obtain access to or correction of your personal information, please contact us at privacy@zenpath.io or at:

Zenpath Inc.
4 Allanbrooke Dr.
Etobicoke, Ontario, Canada
M9A 3N8

FULL VERSION OF PRIVACY POLICY

1. TYPES OF PERSONAL INFORMATION AND PURPOSES OF COLLECTION

Personal information means any information about an identifiable individual, which means any information that relates to you and identifies you personally, either alone or in combination with other information. Zenpath may collect various types of personal information, including personal health information, as described below.

We may collect the following types of personal information from you:

Information You Provide to Us: We collect personal information that you voluntarily provide to us when you register for a Services account (“Account”), such as your first name, nickname, and email address, among other things, in order to use our Apps and/or Services.

We may occasionally request from you and you may otherwise voluntarily provide us with information which personally identifies you, including but not limited to, user support, feedback, and surveys.

We may receive personal information about you from a broad range of activities through our Apps and Services, including, but not limited to, your inputs into the Apps and Services and general correspondence with us, our virtual assistant and chatbots.

With your consent to this Policy, we may collect personal information, including but not limited to personal health information, and other personal details, from you if you answer or respond to in-App questions, questionnaires, and homework. Your responses to questions may include descriptions of how you are feeling (i.e., physical and mental health), your goals, values, principles, roles, and habits, etc.
Financial Data: Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information from the Apps and/or Services. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processors and you are encouraged to review their respective privacy policies and contact them directly for responses to your questions.
Automatically Collected Information: We collect and use certain information and data regarding your access and use of our Apps and Services. When you visit our Apps via a web browser and/or mobile device, our servers record the information that your browser automatically sends whenever visiting or using a website, including your web request, the Internet Protocol (“IP”) address and browser configuration of your device, the date and time of your request, the uniform resource locator of the referring and/or exiting websites.
Cookies and Tracking Technologies: We use cookies to collect usage information when you visit our Apps and to improve App functionality. Cookies are small text files placed on your hard drive that assist us in providing a more customized App experience. Cookies help us to enhance functionality and navigation for users, to count users and to recognize users, and to personalize the services and improve your experience.
Internet Based Advertising: Additionally, we may use third-party software to serve ads on the Apps and/or Services, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help mange and optimize your online experience with us.
Disabling Cookies: If you wish to disable cookies, please refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may be unable to access some customized features on our Apps, however disabling cookies will not prevent you from transacting with us.
User Communications: When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve the Apps and Services. This may include any recommendations, comments or direct messages you post or send to other users.
Website Analytics: We may also partner with selected third-party vendors such as Google Analytics and others to allow tracking technologies and remarketing services on the Apps and/or Services using first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Apps and/or Services, determine the popularity of certain content and better understand online activity. By accessing our Apps and/or Services, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain optout cookies, plug-ins, or settings.

We identify the purposes for which we collect, use and disclose your personal information. We only collect personal information for purposes that would be considered reasonable in the circumstances and only such information as is required of the purposes of providing our Apps and Services. We use only fair and lawful methods to collect personal information.

We collect your personal information in order to provide you with our Apps and Services; to provide you with support and handle inquiries; to personalize and improve the quality and functionality of the Apps and Services; for statistical purposes; to present you with relevant content, marketing materials and advertisements, by analyzing your interests from how you use our Apps and Services; to communicate with you about our Services,

including updates or newsletters; to conduct surveys and market research; to ensure that our Apps and Services remain functioning and secure; to process transactions, including billing, account management and other administrative matters; to investigate, prevent or act on any illegal activities or violations of our Terms of Use; and to comply with any applicable law and assist law enforcement agencies as required.

We use artificial intelligence (i.e., regression, clustering and classification algorithms to build AI models for recommendations, virtual assistants and chatbots) to collect and process information such as users’ to-do’s, habits, roles, goals and responses to our questions, surveys and homework. We process such information to better understand our users (i.e., why do you want to do this task, what does completing this task mean to you, how are you feeling today, etc.) in order to improve your user experience by offering better recommendations in-App (in terms of ordering your personalized task/action item list), and suggesting useful roles, values, principles, actions, habits, and goals.

This Policy does not cover anonymized aggregated information from which the identity of an individual cannot be determined outside of this provision. By using our Apps and/or Services, you consent to the use of your personal information to generate de-identified and/or aggregated data that cannot reasonably be linked to you or used to identify you. Zenpath reserves the right to take your personal information and render it non-identifiable (de-identify, anonymize, and aggregate), following which we may use this anonymized and aggregated information for any reason whatsoever, in our sole and absolute discretion.

We may also use statistical or aggregated information about the Apps’ use and share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to business partners, affiliates and other third parties, at our sole discretion.

Our use of personal information is limited to the purposes described in this Policy. Zenpath does not otherwise sell, trade, barter, exchange or disclose for consideration any personal information we have obtained.

2. CONSENT

As required by applicable law, Zenpath will obtain your consent before, or when, we collect, use and/or disclose your personal information. By clicking “I agree”, by installing or using our Apps, by using or accessing our Services, or otherwise signalling your acceptance or interacting with us, you consent to the collection, use, transfer and disclosure of your personal information by Zenpath in accordance with the terms of and for the purposes set out in this Policy, as they may be amended from time to time. Before you input any personal information, including personal health information, into the Apps, we will request and you must provide your express consent to our collection, use, transfer and disclosure of your personal information as described in this Policy. Otherwise, Zenpath will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your personal information for any new and additional purpose.

We may collect personal health information from you if you answer or respond to in-App questions, questionnaires and homework. Your responses to questions may include descriptions of how you are feeling (i.e. physical and mental health). We collect this information in order to better understand what things mean, improve the overall quality of the system and help us to offer better recommendations for you. We also let you track your progress over time, compare your information against similar baselines and help you set and achieve personal goals.

At any time, subject to contractual and legal restrictions, you may withdraw or change your consent to our use of your personal information, or notify us if you do not wish us to use your personal information for any purpose other than for the purposes specifically identified when you provided it to us.

It should be noted that in certain circumstances, our Apps and Services can only be offered if you provide us with personal information. If you choose not to provide us with the required personal information, we may not be able to offer you our Apps or Services. We will inform you of the consequences of the withdrawal of consent, if applicable.

Under certain exceptional circumstances, Zenpath may have a legal duty or right to collect, use or disclose your personal information without your knowledge or consent. In accordance with applicable laws, we will not disclose your personal information without your consent, except where your information is required to be disclosed: (i) for the purposes of completing a business transaction, such as a sale of our business, merger, amalgamation or similar transaction; (ii) for law enforcement purposes; (iii) for the purpose of complying with a legal requirement; (iv) where information is public as permitted by law; (v) where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or (vi) where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain.

Where required or permitted to disclose personal information without consent, we will not disclose more information than is required.

3. SHARING OF YOUR INFORMATION

We are careful to share your personal information in ways that respect your privacy. We may share information we have collected about you in certain situations. All information that has been shared has been shared for a business purpose. Zenpath may disclose your personal information as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on the Apps and/or Services, or on our behalf, including but not limited to, payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Online Postings

When you post comments, make contributions or provide other content via the Apps and/or Services this information may be viewed by all users and may be publicly distributed outside the Apps and/or Services in perpetuity. Further, this information may be shared between users to improve the quality of the Apps and/or Services (e.g., collaboration, shared tasks, in-App mentorship, etc.).

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit or use the Apps and/or Services. These companies may use information about your visits to the Apps and/or Services and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company (if applicable) and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Social Media Contacts

If you connect to the Apps and/or Services through a social media network, your contacts on the social network may see your name, profile photo, and descriptions of your activity on the Apps and/or Services.

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline honor commitments we made in this Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third part directly.

4. STORAGE, CROSS-BORDER TRANSFER AND SAFEGUARDING YOUR PERSONAL INFORMATION

Information that we collect is stored on servers managed by Amazon Web Services (Canada Central) using standard physical, technical and organizational security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification, or disclosure. We further protect personal information by restricting access to it to those employees that require access to the information in order to provide our Apps and Services. Please note that confidentiality and security can never be 100% assured when information is transmitted or stored electronically.

We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by our third party service providers who assist in providing services to you.

Zenpath may transfer personal information to service providers which may be located outside of Canada where privacy laws may offer different levels of protection from those in Canada. Your personal information may also be subject to access by and disclosure to law enforcement agencies under the applicable foreign legislation.

5. RETENTION OF YOUR INFORMATION

We keep your personal information only as long as necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to conclude that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. We will take due care when destroying personal information so as to prevent unauthorized access to the information.

6. MANAGING YOUR INFORMATION

Access. Zenpath permits the reasonable right of access to your personal information. Upon written request and authentication of identity, we will provide you with access to your personal information under our control, subject to any legal requirements and applicable exceptions to the right of access. We will make the information available within thirty days (30) or provide written notice where additional time is required to fulfill the request. Where an access request is refused, we will notify you in writing and provide our rationale for refusal along with a list of next steps available to you.
Accuracy. If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third party service providers to whom the information has been disclosed.

Depending on your use of our Apps and Services, you may have the following choices:

Cookies Settings and Preferences. You may disable cookies and other tracking technologies through the settings in your browser. While doing so may negatively affect your experience with the use of our Apps and Services, it will not prevent us from transacting with you.
Push Notifications. We use push notifications to send you periodic alerts and updates related to your Account and our Apps and Services. When you first register for an Account, you choose to approve or deny receiving push notifications. If you no longer wish to receive these notifications, you may turn them off at the browser or mobile device level, or by emailing us at privacy@zenpath.io.
Marketing e-mails. You may sign up for our mailing list in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing e-mails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting us at privacy@zenpath.io.
Opt-Outs. You may contact us to opt out of the use or sharing of your personal information, including for marketing or advertising purposes, and/or the provision of your personal information to our business partners for such purposes.
Online behavioural advertising. We use Google Analytics on our website (not within the Apps). For more information on how Google Analytics collects and processes information, as well as how you can control the information sent to Google, please review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You may control your advertising preferences or opt-out of certain Google advertising
products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

7. LEGAL DISCLAIMER

We may provide links to, or automatically produce search results for, third-party websites or resources, or third-party information referencing or linking to third-party websites or resources. Zenpath has no control over such third-party websites and resources, and you acknowledge and agree that Zenpath is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. Zenpath is not responsible for the privacy or security practices or the content of external websites, services or products.

8. CHILDREN

In order to use the Apps and/or Services, you must register for and maintain an active Account. You must be at least 18 years of age, or the age of legal majority in your jurisdiction (if higher than 18), to obtain, maintain, and use an Account. Accordingly, Zenpath does not knowingly permit persons under the age of 18 (or age of legal majority) to register for an Account and use our Apps and/or Services, and does not knowingly collect or solicit personal information of such individuals. If you are a parent or guardian and become aware of any data we have collected or received from a child under the age of legal majority in your jurisdiction, please contact us at privacy@zenpath.io and we will make reasonable attempts to delete that information.

9. HOW TO CONTACT US FOR QUESTIONS, COMMENTS OR COMPLAINTS

Zenpath responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our Policy and procedures.

Please contact our Privacy Officer by emailing us at privacy@zenpath.io or at:

Zenpath Inc.
4 Allanbrooke Dr.
Etobicoke, Ontario, Canada
M9A 3N8

Please note that if we are unable to resolve your privacy concerns, you may have the right to complain to the Office of the Privacy Commissioner of Canada or the appropriate provincial Information and Privacy Commissioner.