This Luci App Policy only applies to our Services. Please review our Corporate Privacy Policy (“Corporate Policy”) to understand the handling of Personal Information that is collected through: (a) our website, lucilab.ca/en (“Website”), including when Personal Information is provided through the Website to participate in our research studies; and (b) offline interactions (except for those individuals using our Services – in which case this Luci App Policy applies). If there is a conflict between the Corporate Policy and this Luci App Policy and you are using our Services, this Luci App Policy will take priority to resolve the conflict.

In this Luci App Policy, the terms “Personal Information”, “Sensitive Information” and “Lifestyle Information” have the following meanings:

• Personal Information: means information in any form as interpreted by applicable privacy laws about an identified individual or an individual whose identity may be inferred or determined from such information.
• Sensitive Information: means Personal Information that discloses or reveals sensitive information such as race, ethnicity, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health and medical data, sexual orientation and criminal offence history.
• Lifestyle Information: means the information that you will be required to provide to us if you apply for our Interactive Services, which includes Personal Information and could include Sensitive Information, such as information about your lifestyle habits in the areas of general health, physical activity, nutrition, and intellectual stimulation.

Please note that you are not required to provide Personal Information to download the Luci App. In such cases, only device information and aggregated or anonymized information is provided to us through cookies or other tracking technologies. We cannot directly identify you through such data. However, when you choose to apply for our Interactive Services, you will be required to provide us with Personal Information, such as Lifestyle Information, which can also include Sensitive Information.

While you may use some of the functionality of the Luci App without creating a profile or registration, if you want to receive our Interactive Services, we will require registration and your information, including Personal Information.

• If you download the Luci App without creating a profile or registering – we will only collect information which does not directly identify you through the use of cookies and other tracking technologies.
• If you apply for our Interactive Services – you will be asked to create a profile or register with us and provide Personal Information through the Luci App so that we can register you and assess your eligibility for our Interactive Services. For certain Services, such as participating in research studies, you may be asked to provide similar or even additional Personal Information outside of the Luci App but in those cases, we will request your express consent.
• If you are accepted to receive our Interactive Services – you will be asked to provide various types of Personal Information to us, including Lifestyle Information. Information will be collected through a variety of ways, including through our Luci App, by telephone, email, chat and videoconference.

It is your choice to provide us with any Personal Information, including your Lifestyle Information, however if you do not provide this information, you will not be able to use a large part of our Services, including our Interactive Services.

Please see the kind of Personal Information that we could collect from you. Please do not provide us with any information that includes identifying information about another person without that person’s explicit consent. If you disclose any Personal Information relating to other people in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Luci App Policy.

If you download the Luci App without creating a profile or registering :

If you apply for our Interactive Services :

If you are accepted to receive our Interactive Services : 

Other situations where you voluntarily provide Personal Information to us :

If the Personal Information is required or permitted by law or with your consent :

We have implemented commercially reasonable administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. For example:

• We have designated a Chief Privacy Officer who oversees Lucilab’s compliance with this Luci App Policy and applicable privacy laws;
• Access to your Personal Information by our employees is strictly limited to those who need to access it and only to the extent necessary to perform their roles. Those within Lucilab who can access your Personal Information are: (a) the Advisors to provide the Interactive Services; (b) the information technology (“IT”) department to diagnose and address any technical issues (including the security, confidentiality and integrity of your Personal Information and the management of our IT systems); (c) the marketing department to send you communications (if you have opted in to receive such communications); and (d) the research department to recruit and provide support to participants for research studies (if you have opted in to participate in such studies), to better understand risk factors related to dementia and to analyze the data to help the Advisors provide and improve their Interactive Services; and
• We take measures to safeguard the Personal Information provided to our service providers. For example, we: (a) transfer only the Personal Information they need to perform their duties as described in Question 4 above; (b) enter into written contracts which bind them to obligations of confidentiality; (c) de-identify the Personal Information when we are able to do so; and (d) store and process all Personal Information within Canada.

To illustrate, we currently use: Vonage for our videoconferencing Interactive Services sessions.

The Interactive Services sessions (video and audio) are transmitted through Vonage’s servers and stored by our hosting provider (including questionnaire responses, chat and video recordings of sessions). The servers for both Vonage and our hosting provider are located in Canada. Vonage may have access to the sessions but only to facilitate our Interactive Services by: (a) allowing participants and Advisors to communicate via videoconference; and (b) transferring the videoconference sessions to be stored on our hosting provider’s servers in Canada. Vonage implements administrative, physical, and technical safeguards to help protect the Personal Information we provide. For example, all media traffic (video, voice, and data) is by default encrypted in transit and Vonage does not save or store the video recordings. However, like us, Vonage cannot absolutely guarantee the confidentiality or security of your Personal Information. Please review Vonage’s privacy policy and terms of use (“Vonage’s Terms”) to understand its use of Personal Information and the Risks Associated with the Use of Electronic Communications. By providing us with your Personal Information and continuing to use our Interactive Services, you agree to Vonage’s Terms.

Please help us prevent unauthorized access to your account by ensuring that the proper level of care and security is exercised on your end – e.g. technological controls such as anti-virus tools for your computer, keeping your password confidential and avoiding the use of personal identifiers (e.g., last name, street address, etc.) during our Interactive Services sessions, as we want to avoid, as much as possible, linking Sensitive Information to your personal identifiers.

While we strive to protect your Personal Information, neither we nor our suppliers can ensure or warrant the security and privacy of your Personal Information or other content you transmit using the Services, and you do so at your own risk. If you become aware of any data incident or breach, please contact us immediately.

Non-Personal Information will not contain any information that could be used to contact or identify you. Non-Personal Information may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand user activity, marketing strategies and for entering into commercial contracts in order to provide our users with the Services. We may also analyze the Interactive Services sessions on an aggregated basis with the goal of eventually automating certain aspects of our Services.

a) Collected or Created Non-Personal Information: Through the use of the Tools, we or our service providers: (i) collect Non-PI about your use of our Luci App; and (ii) may analyze and/or combine all of the information we receive, including Personal Information and information about your use of the Luci App, with information from other users to create the Non-PI. Please note that the aggregated/anonymized data may be retained indefinitely.

b) Purposes for collecting or generating the Non-PI: We use the Non-PI:

i. To better understand, customize and improve user experience with our Luci App and our product or service offerings;
ii. To help us with our marketing strategies regarding our products and services based on your use of the Luci App;
iii. To automate certain aspects of the Services such as providing standard recommendations to achieve a certain lifestyle improvement;
iv. To compile statistics, analyze trends and otherwise administer and improve our Services; and
v. To understand from which geographical regions users have accessed our Luci App.

c) Tools Used: Third parties, including Google LLC ‘s (“Google”) and Pendo.io Inc.’s (“Pendo”) analytics Tools, may use cookies, web beacons, and other storage technologies to collect or receive information from our Luci App and elsewhere on the internet and use that information to provide measurement and other analytical services. Please find below details about the Tools we or our suppliers use to collect Non-PI:

i. Cookies Generally. We and our service providers use “cookies” (a small text file sent by your computer each time you visit our Luci App and unique to your browser). When you use our Luci App, our servers automatically receive certain information such as your Internet Protocol address, the address of the webpages you visited that had Lucilab features, browser type and settings, the date and time of your request, how you used Luci App and cookie data (collectively “log data”). We use both “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). To find out more about cookies, visit https://www.allaboutcookies.org/.

ii. Luci App Performance and Visitor Activity Monitoring. We may use analytical tools, provided by our suppliers, to monitor the performance of our Luci App and visitor activity in order to tailor and improve our Luci App and its content. For example:

A. We use Google Analytics, a web analytics service provided by Google. We use Google’s Tool to track website performance and collect visitor insights.  To opt out, please visit: https://tools.google.com/dlpage/gaoptout.

B. We use the information collected through Pendo’s analytics Tool on an aggregated basis to:

• • • Improve our Services by better understanding how the Luci App is used by our users (e.g., how people navigate in the app, which features are used and in what proportion, when, etc.); and
    • Diagnose technical problems. Note that in rare cases, Lucilab may use the information on an individual user level but only on an “as needed” basis (e.g., by understanding the use of our Luci App by a user, additional information is provided which helps us diagnose bugs particular to a user).

We may also use the information collected through Pendo’s analytics Tool on an aggregated basis to:

• • • Display online help and interactive tutorials in the Luci App;
    • Promote new app features; and
    • Conduct surveys to measure participant satisfaction.

We do not share identifying information with Pendo.  However, if you still wish to opt out, please contact us. Please note that if you withdraw your consent, we may not be able to provide our services and products to you, including our Interactive Services.

iii. Social Media Plugins. A plugin is a piece of software that adds a specific functionality or type of content to a website. For example, the Luci App uses social media plugins, which, when clicked, connect to Lucilab’s profile pages on various social media platforms. Our Luci App uses social media plugins provided by companies such as Meta Platforms, Inc. (formerly known as Facebook, Inc.) and LinkedIn Corporation to provide you with the opportunity to access our profile pages on third-party social media platforms. By clicking on a social media plugin, you acknowledge that you will leave our Luci App and access a third-party social media platform, and you understand that your Personal Information may be collected, used and/or shared in accordance with such third-party social media platform’s privacy policy.

iv. Device information. This information is used to help us deliver content appropriate to your device’s capabilities. To learn more about what information your device may make available to us, please check the policies of your device manufacturer or software provider. In addition to log data, we or our service providers may also collect information about the device you are using to access our Luci App (such as the type of device and browser used).

d) General information about opting out: Please find below general information on opting out. Please note that the information below is only provided for your convenience. We cannot guarantee its integrity or that the information is current or accurate.

i. Do Not Track: Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you. These features are not all uniform, and some browsers may not be set up to honor such requests. Please note, however, that Lucilab may not always be able to recognize Do Not Track signals from your browser. Options you select are browser and device specific.

ii. Cookies: As explained in Section 6c)(i), Tools such as “necessary” cookies are used to make our Luci App work and to enable its basic features. Since they are necessary for our Luci App to function, by using our Luci App, you agree to their use for the foregoing purpose. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The “Help” section of your browser may tell you how to prevent your browser from accepting cookies. For more information about cookies and how to opt-out, please consult https://www.allaboutcookies.org/verify and https://www.aboutads.info/choices.

Except as listed below, our policy is that we will not sell, rent, share, or authorize any third party to use your Personal Information without your consent. We also prohibit our service providers from using Personal Information other than for the specific purposes for which we provide it to them. Please rest assured that our suppliers only receive the Personal Information they need for the performance of any contract we enter into with them. Below is a summary of why we may transfer or disclose information, including Personal Information.

a) To obtain services to fulfill the purposes for which the Personal Information was collected: We use service providers to help us:

• develop and host the Luci App;
• assess cognitive performance through an analytical tool;
• schedule chat and videoconferencing sessions with you and to send you reminders about them;
• to provide the Services to you including the Interactive Services (e.g., via video conferencing);
• customize the Services provided to you, including to guide you through our Luci App;
• manage our servers and other information systems;
• analyse and maintain our Services; and
• process and store information provided to us including Personal Information.

b) For research purposes and improvement of our Services: We may anonymize and/or aggregate Personal Information and provide it to research institutes and other partners for: (a) the purpose of advancing research on Alzheimer’s disease or related dementias, including for the publication of research articles; and (b) the goal of eventually automating certain aspects of our Services. If your personally identifiable information will be shared with these research partners, we will seek your prior express consent.

c) To reorganize, restructure or change the ownership or control of our company (purchase, transfer, or sale of services or assets): We may disclose Personal Information to third parties such as purchasers or financing companies in connection with a merger, acquisition or sale of all or a portion of our assets or other similar transaction but only if required and only to the extent necessary to achieve the purpose.

d) To comply with applicable laws, to respond to requests by government agencies or to protect our, your or others’ property, safety, or other interests: We may share your Personal Information to courts and law enforcement, regulatory or other authorities in Canada or authorities in other jurisdictions if we are required to do so or if we believe it is necessary to protect us against potential liability, investigate and defend against claims or allegations, investigate and protect against fraud, protect the security and integrity of our Services, ensure compliance with our policies, including this Luci App Policy, and protect the rights and property of Lucilab and others.

As mentioned above, we may disclose your Personal Information for other purposes with your consent or if permitted or required by law. If you have any questions or would like more details about our service providers or any other third parties, and the information we provide to them, please contact us.

Unless specified otherwise in this Luci App Policy, we will delete Personal Information we have under our control in the following circumstances:

• The purpose for which the Personal Information has been collected/obtained has been fulfilled, can no longer be achieved or the Personal Information is no longer necessary for the original purpose;
• Consent has been withdrawn; or
• Applicable laws, ethical requirements and/or contractual obligations do not permit the contemplated processing.

Where one of the above circumstances arise, your Personal Information will be destroyed, deleted, or made anonymous. After deleting your Personal Information, we may retain non-personally identifiable information and may continue to use it as permitted by this Luci App Policy and in accordance with applicable laws.

You may always request, as specified in the following section, that your Personal Information be deleted, but please note that we and our suppliers may be required to retain some of this information to comply with our legal obligations (in which case, we will comply with your request to delete the information only after we have fulfilled such obligations).

Applicable laws may provide you with certain rights and choices, such as if:

• you wish to know how your Personal Information is collected, used or otherwise handled;
• you wish to access, update, correct or request deletion of your Personal Information;
• you wish to withdraw your consent to the processing of your Personal Information, or to restrict or object to our processing of your Personal Information;
• you wish to better understand how automated decision making is used;
• you wish to request a copy of your Personal Information that we process;
• you have a question or complaint about this Luci App Policy or the manner in which your Personal Information is processed by us or our suppliers. We however hope that you will first contact us, so that we work with you to resolve any complaint or concern you might have; or
• you want to report a privacy or security breach in relation to your Personal Information.

Feel free to contact us for any of the above reasons or if you have any questions or requests not covered above. We will take reasonable steps to verify your identity before responding to your requests. Please note that the rights above may not be an absolute right and may be subject to certain exceptions. Your rights may differ depending on where you live or could be subject to certain legal restrictions, as applicable laws may allow or require us to deny or partially deny your request.

The type of consent we obtain or whether or not we need to obtain consent depends on the circumstances and on the applicable laws where you reside.

• Consent. For example, when you contact us with a question and provide your phone number, we consider that you have given us your implied consent to contact you and answer your question in accordance with this Luci App Policy. In other situations, such as when applying for our Interactive Services, we may ask for your express consent, either by verbally consenting, signing a document, or ticking a box.
• No Consent. Sometimes it may not be possible or may be inappropriate to obtain your consent, and in those cases, we may collect, use, or disclose your Personal Information without your consent. For example: (a) if it is clearly in your interests (such as a medical emergency or a threat to your safety); (b) to comply with a warrant or other court order; (c) to investigate the breach of an agreement or applicable law; (d) to recover a debt; or (e) as otherwise legally required or permitted.

You can withdraw your consent to the collection, use and disclosure of your Personal Information, subject to our legal or contractual restrictions. However, if you refuse to provide certain information or withdraw your consent, this may limit our ability to provide you with certain services, products and functionalities.

The Personal Information provided to us is stored and processed in Québec, where Lucilab is located, as well as on the servers of our hosting provider which are located in Canada. We protect your Personal Information in accordance with applicable laws, this Luci App Policy and our contractual obligations wherever it is processed and whether it is held by us or by our hosting provider. Since some of our service providers are located outside of your province or territory of residence (but within Canada), where permitted by law, we reserve the right to store and process your Personal Information outside of your province or territory. Sometimes, these other provinces or territories in Canada do not provide the same level of protection as those in your province or territory. Governmental, legal, or regulatory agencies may access or disclose your Personal Information under authority of law. Though stored and processed within Canada, encrypted Personal Information may transit through servers which are located outside of Canada. By providing us with your Personal Information and continuing to access and/or use our Services, you consent to the transfer of your Personal Information outside of your province or territory in the event that such transfer is necessary for the purposes set out in this Luci App Policy.

For your convenience, our Services may link to or refer to websites or platforms that are not owned or operated by Lucilab. These links or any use of third-party trademarks should not be construed as an endorsement or recommendation of these third parties or their websites or platforms by Lucilab. The Luci App Policy does not apply to such other websites and platforms and we are not responsible for the privacy practices or content of any website or platform not controlled by us. Your use of these links or references will be at your own risk. If you have any concerns, we urge you to review the terms of those other websites or services for more information about their applicable policies.

Note that our Luci App links to certain social media providers (e.g., Facebook and LinkedIn) where we have our company profile or account. If you choose to post content or otherwise interact, we will be able to view such interactions but we do not collect any of the information posted on those sites. Information collected through third-party apps, tools, widgets and plug-ins (such as relating to your use of a Facebook “Like” button) is collected directly by the providers of these features. This information is subject to the privacy policies of those providers of the features, and we are not responsible for those providers’ information practices.

We do not intentionally collect or use any Personal Information from minors. We do not knowingly allow children to communicate with us or use or order any of our Services. If you become aware that your child is using or has used any of the Services without your consent or that someone is using or has used the Services on your child’s behalf without your consent, please contact us. If we learn that we have collected any Personal Information from a child without verification of parental consent, we will delete that information from our database as quickly as possible.

Lucilab reserves the right to modify this Luci App Policy at any time. Any modifications to the Luci App Policy will be posted on this page. Please review this Luci App Policy from time to time to ensure that you are aware of any such modifications. Your continued use of the Services, including the Luci App, following the posting of any modifications or updates to the Luci App Policy constitutes your acceptance of those changes.

You can write to us by clicking here or contacting the Chief Privacy Officer:

Chief Privacy Officer
160 Saint-Viateur Street E, Suite 801, Montreal (QC) H2T 1A8
[email protected]
1-844-LUCILAB (582-4522)