Privacy Policy

Last updated: September 27, 2022

1. General

Individual Users

The Lenica Privacy Policy (the "Policy") governs your use of Lenica’s web site and software programs located at www.lenica.ca, www.peakcognition.app and partner websites, which is operated by Lenica Research Group Inc. and your use of the cognitive training program(s) from the google and apple app store (collectively referred to as “Lenica Services”). This Privacy Policy applies to any and all individuals who access and/or use the Lenica site and program(s) on their own behalf or the individuals to whom they provide access to personal information (the “Individual Users”). To the extent that such individuals are representatives of an organization, such individuals are referred to as “Institutional Users” and are bound by the terms applicable to Institutional Users as outlined below. In the case of teens between the ages of 13 and 18 (hereinafter “Teen” or “Teens”) and children under 13 years of age (hereinafter “Child” or “Children”), these Individual Users are required to obtain the consent of their parent or guardian (hereinafter “Parent” or “Parents”) in order to use Lenica Services.

Institutional Users

This Privacy Policy also applies to medical professionals and representatives of organizations who access and/or use Lenica Services with the authorization of an Individual User or purchase of Lenica Services for distribution or use with Individual Users, such as schools, sporting organizations or medical providers (these type of users are collectively referred to as “Institutional Users”). Any such Institutional Users are required to strictly observe and abide by this Privacy Policy as part of the Terms and Conditions of their access and/or use Lenica Services. Individual Users and Institutional Users are referred to collectively in this Privacy Policy as “Users”.

2. Registration and Collection of Personal Information from Users

Although many aspects of Lenica Services are available to Users without having to register or use the program(s), access to some of the content and functionality of the Lenica Services, including the ability to use and review the results of the program(s), requires that Users register and provide certain information to Lenica. Individual Users are required to provide personally identifying information (namely name, email address, mailing address, age, gender and phone number) when registering for Lenica Services. If purchasing Services for distribution to a Teen or Child, Parents will be required to submit payment information, as well as information which could be used to personally identify their Teen or Child. Individual Users who are Teens and Children are required to provide their Parent’s name(s) and contact information (mailing address, phone number and email address).

If an Individual User uses Lenica services, he/she will also be required to provide Lenica with other Personal Information including, but not limited to, responses to Lenica Services questions, sport and position, dominant hand, gender, age, birth year and athletic performance characteristics. Once an Individual User begins using the program(s) test results will be stored within the Lenica cloud database and associated with that Individual User.

In the case of representatives of Institutional Users, purchasing Services for distribution to Individual Users, payment information must be provided, as well as information about affiliation (e.g. name of the school or sports club, name of medical provider or research institution, including contact information (name, mailing address, phone number and email address).

In this Privacy Policy, all personally identifying information is referred to collectively as “Personal Information".

In order for Lenica Services to be useful for the Users, it is essential that accurate and complete Personal Information be provided. Lenica will retain such Personal Information in its database for the time necessary to fulfill the identified purposes or a legal or business purpose, unless an Individual User or their Parent, as applicable, requests that Lenica delete such information.

Lenica only collects Personal Information which is necessary to provide Users with access to the services it has requested, including the Lenica Services.

Types of Personal Information we may collect include:

identifying information such as name and date of birth;
identification information for identity verification, which may include your email and mailing address;
contact and demographic information such as home address, home and mobile phone numbers and email address, password, marital status, gender and in some cases your work contact details;
financial information, such as bank account and credit card details;
information about your general practitioner, including the general practitioner’s name, contact number, facsimile and clinic address.
health information, including:
- lifestyle, diet, exercise and health related information that you choose to provide us;
- information about your activities, including sporting and other lifestyle interests;
- biometric information and templates, such as voice recognition information and eye-recognition information;
- information about your physical movements and performance when using the hardware (Health Gauge, Apple Watch, Fitbit and other similar devices) or equipment associated with our Services and
technical, analytical and behavioral information generated from tracking technologies which may be embedded within certain components of our Services such as
- Cookies, which are small data files stored on your device’s hard drive either for the duration of your visit (“session cookies”) or for a fixed period of time (“persistent cookies”), in order to collect and store your preferences and other types of information. You may set your browser to reject cookies and to let you know when a cookie is being placed on your computer.
- Technologies deployed by our third party service providers such as Wix Analytics and Google Analytics, which collects information such as time of visit, pages visited, time spent on each page, and type of operating system used to access the Services. By downloading and using a browser plugin provided by Google (available here: https://tools.google.com/dlpage/gaoptout), you can choose to opt out of Google Analytics.

Lenica has developed security safeguards to try to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The methods of protection include:

physical measures (e.g., locked filing cabinets and restricted access to offices);
organizational measures (e.g., security clearances and limiting access on a “need-to-know” basis); and
technological measures (e.g., the use of passwords, encryption-at-rest and encryption-in-transit)

We are committed to ensuring the security of your Personal Information and may use passwords, encryption, firewalls, restricted employee access or other methods, in our discretion. We will use appropriate security measures when destroying your Personal Information such as shredding documents or deleting electronically stored information, in our discretion.

All payment information is encrypted and processed by accredited third-party providers (e.g., Stripe, Paypal), and will not be retained upon successful completion of the transaction unless the User specifically elects to retain such payment information.

3. Use by Lenica of Information Collected From Users

Lenica utilizes Personal Information to create an account profile for each User in order to provide Users with the content and services that they have requested, to provide Users with the results derived from the Lenica Services, to respond to questions about the Lenica Services, and to inform Users of significant changes to this Privacy Policy. Lenica will also use the data collected to enhance existing services and products and for quality assurance across the programs. If the User grants their permission, Lenica will also use Personal Information to inform the User about new products or services from Lenica that may be of interest.

Lenica may also use Personal Information along with the information of all or some of the other users of the Lenica Services to generate aggregated data that does not contain personally identifying information (“the "Aggregated Data"). Lenica uses the Aggregated Data for research purposes, for example, to identify certain trends, identify certain aspects of program(s) which require refinement, the correlation of the program(s) data with certain characteristics of athletic performance and/or general health outcomes. Data used for general research purposes will be de-identified/anonymized and may be made accessible to Lenica partner organizations. For specific research projects, we will collect informed consent for the use of Personal Information and participation in the project will be completely voluntary.

What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Our Company for copies of your personal data.
The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: support@peakcognition.app or info@lenica.ca

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

Keeping you signed in
Understanding how you use our website

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and the location you are in. A mix of first-party and third-party cookies are used.
Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The Our Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

4. Sharing of Information Collected From Individual Users with Institutional Users

Some Institutional Users purchase and distribute Lenica Services that employ an Institution code/link/website feature that automatically allows such Institutional Users to view and access Individual Users’ program results. If Individual Users receive a program with this feature from an Institutional User such as a school, sports club, training institution, medical provider or researcher, or an Individual User elects to share their program(s) results with an Institutional User, Personal Information collected from Individual Users will be shared with that Institutional User, including program(s) results. This information is used by Institutional Users as part of their services such as athletic cognitive training and concussion management program, as it allows athletic trainers, medical providers and coaches to ensure that each Individual User has achieved an acceptable Baseline and to allow those Institutional Users to access stored Baseline tests in the event of an injury. As a condition of use or purchase of the Lenica program(s), all Institutional Users commit to abide by the Terms of Use for the Lenica Site, including this Privacy Policy.

If an Individual User accepts a Lenica program(s) from an Institutional User, that will be clearly identified that Institutional User. If an Individual User elects to use the Institution code/link they will be asked to confirm their agreement to share their Personal Information with the Institutional User who provided the Institutional code/link. The Personal Information shared will be the Individual User’s name, program(s) results, gender, sports, length of time playing sports and birth year. If Individual Users do not wish to share their Personal Information or that of their Teen or Child with that Institutional User, they should not Institution code/link from that Institutional User, and should register directly with Lenica and purchase the program(s) for themselves or their Teen or Child.

5. Sharing of Information Collected From Users with Third Parties

If Lenica has been authorized to do so by a User, Lenica may share the User’s name and contact information with other marketing and/or service providers (“Lenica Partners”). A user can elect to change or withdraw their consent to sharing such information at any time by changing their preferences within their account profile or by emailing info@lenica.ca.

Special Notice for Parents

If a Parent consents to the registration of their Teen or Child for the program(s) using an Institution Code/Link provided by an Institutional User, they are providing their consent to the sharing of their Teen or Child’s Personal Information with the Institutional User identified by that Code/Link. Institutional Users who receive a Teen’s or Child’s Personal Information through the distribution of Institution code/link may only use the Personal Information for purposes of ascertaining whether the Teen or Child has achieved an acceptable result and to access the Teen’s or Child’s Baseline and performance measures.

Parents do not need to consent to the sharing of their Teen’s or Child’s Personal Information in order to register for and use the Lenica services. However, if a Parent does not wish to share a Teen’s or Child’s Personal Information with an Institutional User who has provided an Institution code/link to that Teen or Child, they should not accept an Institution code/link provided by an Institutional User and should register their Teen or Child directly with Lenica.

6.Use of Aggregated Data by Third Parties.

Aggregated Data may be shared with third parties in order to derive information on user patterns such as the time users spend on a certain portion of Lenica Services, the average age of individuals using the program(s), etc. Lenica might also provide certain third parties, such as sports equipment manufacturers or research institutions with Aggregated Data (for example, information such as the percentage of individuals suffering neurocognitive injury who play certain sports such as football, various performance measures and the age/gender of such individuals). Lenica may receive compensation from such third parties for their use of such information. Lenica requires parties who receive Aggregated Data to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases.

7. Use of the Lenica Services by Teens and Children

Lenica Services may be used by Teens and Children only with the express consent and under the supervision of a Parent (or, in the case where an Institutional User such as a school, sports club or medical provider is supervising use of the Lenica Site or the program(s) and/or distributing Institutional Codes to a Teen or Child, with the consent and supervision of such Institutional User acting as the proxy for the Parent within the context of a legally binding, written consent form signed by the Parent which is broad enough to cover such consent and supervision). Lenica does allow a Teen or Child’s Parent or an Institutional User with authority to act on behalf of the Parent to either directly establish a user profile for that Teen or Child or to provide Lenica with verifiable consent to the Teen’s or Child’s registration for Lenica Services.

Parents or Institutional Users who have been authorized by Parents to register a Teen or Child can provide verifiable consent by using any one of the following methods:

Providing a valid credit card as part of the registration and purchase of a Lenica program(s).
Calling the following toll free number: 1-780-937-7342
Printing and e-mailing this Parental Consent Form to the following address: simba@lenica.com
By providing a valid electronic signature in response to an email from Lenica seeking consent to the registration of a Teen or Child.
If the Parent or school official is present when a Teen or Child is registering, they may consent via digital signature at the time of registration.
Parents who create a Parent Account and then purchase and distribute Institution Codes directly to their Teen or Child consent to the collection of Personal Information for such Teen or Child at the time of purchase.

For all users under the age of 18 the Parent or an authorized Institutional User is solely responsible for providing supervision of the Teen or Child's use of Lenica Services and a Parent who registers a Teen or Child shall assume full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate and complete. The Parent also assumes full responsibility for the interpretation and use of any information or suggestions provided through the Lenica Services related to that Teen or Child, as applicable.

If a Parent grants permission to an Institutional User such as a school, sports club or medical provider to register a Teen or Child, for use of Lenica Services, they acknowledge that such Institutional User is responsible for ensuring that the Personal Information is kept secure and that the Personal Information submitted is accurate and complete. In granting permission to the Institutional User to register a Teen or Child, the Parent acknowledges that Lenica cannot be held responsible for any failure on the part of such Institutional User to abide by the Lenica Site Terms of Use or Privacy Policy to which that Institutional User has agreed as part of the registration or testing process, or for any failure on the part of such Institutional User to adequately safeguard the data collected as part of registration or testing.

At any time, an Individual User and the Parents of a Teen or Child may (i) request access to their, or their Teen’s or Child’s Personal Information that Lenica holds on that User, Teen or Child, as applicable, (ii) request correction of any inaccuracies in the User’s or Teen’s or Child’s Personal Information, as applicable, and (iii) request in writing that such Personal Information be permanently deleted from Lenica Research Group database. Such requests should be directed to:

Email: simba@lenica.ca

If a User makes this request, Lenica Research Group will no longer be able to provide certain content and services on Lenica Services.

8. Lenica’s Disclosure of Personal Information

Except as set forth in this Policy or as specifically agreed to by a User, Lenica will not disclose any Personal Information gathered from Users using Lenica Services. Users agree that Lenica may release Personal Information: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in response to a physical threat to an Individual User or others, to protect property or defend or assert legal rights. In the event that Lenica is legally compelled to disclose Personal Information to a third party, Lenica will attempt to notify an Individual User unless doing so would violate the law or court order. In addition, Lenica may disclose Personal Information as described below.

Lenica services programming and service providers may have, or be granted from time-to-time, limited access to Personal Information in the course of providing services to Lenica in support of Lenica Services. Such third-party providers may include vendors and suppliers that provide Lenica with technology, services, and/or content for the operation and maintenance of Lenica Services. These contractors also may have access to User email addresses to send newsletters or special promotions on behalf of Lenica or to send emails for purposes such as conducting market research for Lenica, provided that the User has consented to receive such communications. Access to Personal Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for Lenica. Lenica requires all third-party service providers to execute binding agreements in which the third party agrees to: (1) protect the privacy of Personal Information consistent with this Policy, and (2) not use or disclose Personal Information for any purpose other than providing Lenica with products and services as required by law. Lenica’s third-party service providers may be located outside of Canada. Personal Information may be transferred, stored and/or processed outside of Canada and in that case, Personal Information would be subject to the laws of the country to which it is transferred. That country may have laws that require that Personal Information be disclosed to the government under different circumstances than would Canada.

In the event of a sale, amalgamation, re-organization, transfer or financing of parts of some or all of Lenica’s business, Users’ Personal Information may be disclosed to an acquiring organization, either as part of due diligence and/or on completion of the transaction. If Users’ Personal Information is disclosed to an unaffiliated third party in this context, Lenica will require that third party to agree to protect Users’ personal information in accordance with this Privacy Policy.

9. Lenica’s Ability to Change the Privacy Policy

Lenica reserves the right, in its sole and absolute discretion, to amend this Policy from time-to-time. In the event such an amendment constitutes a "material" change (as defined below) in the collection and/or aggregation of Personal Information, Lenica will notify Lenica Services users in advance of such proposed change and will provide Lenica Services users with the ability to "opt-out" of their registration for Lenica Services. For purposes of this Policy, "material" means a change that expands Lenica ability to collect, use or disclose Personal Information. If, following notice from Lenica regarding an adoption of a material change, Lenica Services users continue to use Lenica Services, such continued use will constitute acceptance of such material change(s). If Lenica Services users decide that any of the material changes are not acceptable, they should immediately stop using the Lenica Services.

10. Complaints

If a User has questions or concerns about this Privacy Policy or about the Personal Information that has been collected by Lenica, please contact Lenica’ Privacy Compliance Officer using the contact information set forth.

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