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Privacy Policy for Heka Santé Inc.

(C/O Paperminds Technologies) Last Revised: February 2, 2025

Introduction

Welcome to Paperminds, a Canadian company specializing in advanced conversational intelligence solutions. At Paperminds ("we", "us", or "our"), we are committed to protecting the privacy and security of our users' personal information. This Privacy Policy outlines how we collect, use, disclose, store, and protect information when you interact with our services, which are being provided in collaboration with Flair Stratégie inc. to conduct market research about travel preferences and experiences. By accessing or using our services, you agree to the terms outlined in this Privacy Policy. If you do not agree with these terms, please do not use our services.

Definitions

  • Service: The services provided by Paperminds, including but not limited to Conversation studies™, Welcome Station™, Feedback Station™, Training Station™ as well as Conversational Studies™ utilizing digital voice personalities for Flair Stratégie inc.
  • Personal Data: Any information relating to an identified or identifiable individual.
  • Usage Data: Data collected automatically from the use of our services.
  • Voice Data: Audio recordings and transcriptions processed during service interactions.
  • Cookies: Small files stored on your device (computer or mobile device).
  • Data Controller: Paperminds, responsible for determining the purposes and means of processing personal data.
  • Data Processor: Any natural or legal person who processes data on behalf of Paperminds.
  • Client: Flair Stratégie inc., the organization for whom Paperminds is providing services.
  • User: The individual using our Service.

Data Processing Agreements

Paperminds maintains Data Processing Agreements (DPAs) with its clients and service providers that outline:

  • Roles and Responsibilities: Paperminds acts as the Data Controller, maintaining primary responsibility for data protection
  • Processing Boundaries: Clear limitations on how data can be processed and used
  • Security Requirements: Mandatory security measures for all parties handling data
  • Confidentiality Obligations: Strict confidentiality requirements for all personnel
  • Breach Procedures: Clear protocols for handling potential data breaches
  • Audit Rights: Paperminds' right to audit compliance with data protection requirements
  • Subprocessing: Rules and restrictions regarding the use of subprocessors

Our DPAs ensure that:

  • Client access to data is limited to specified purposes
  • Processing activities are documented and controlled
  • Data protection standards are maintained throughout the service chain
  • Compliance with Canadian privacy laws is enforced

Information Collection and Use

We collect several types of information through our conversational intelligence solutions to provide and improve our Service to you.

Types of Data Collected

1. Personal Data

While using our Service, you may voluntarily provide us with certain personally identifiable information ("Personal Data"). This includes:

Basic Information:

  • Contact Information: Name, email address, phone number
  • Demographic Information: Age, gender, location, occupation, etc.
  • Professional Information: Job title, industry, company (where applicable)

Conversational Data:

  • Opinions and Preferences: Views on products, services, or topics
  • Experiences: Personal or professional experiences related to discussion topics
  • Behavioral Information: Decision-making patterns, preferences, habits
  • Emotional Responses: Sentiment and emotional reactions to topics
  • Personal Stories: Anecdotes and experiences shared during conversations
  • Feedback: Comments, suggestions, and critiques
  • Purchase Intent: Interest levels and purchasing considerations
  • Lifestyle Information: Habits, routines, and preferences
  • Needs and Pain Points: Challenges, requirements, and desired solutions

We use your Personal Data to:

  • Personalize your experience with our Service
  • Generate insights and analysis for Flair Stratégie inc.
  • Improve our conversational AI capabilities
  • Enhance service delivery and user experience
  • To gain insights about travel preferences and experiences

2. Usage Data

We may collect information that your browser sends whenever you visit our Service or when you access Service through a mobile device ("Usage Data"). This Usage Data includes:

  • Device Information: IP address, browser type and version, operating system
  • Service Interaction: Pages visited, time and date of access, time spent on pages
  • Interaction Patterns: Navigation behavior, response times, engagement levels
  • Diagnostic Data: Crash reports, performance logs, and other diagnostic information

3. Voice Data

During your interactions with our digital personalities, we collect Voice Data, which includes:

  • Audio Recordings: Captured to understand and respond to your inquiries
  • Voice Characteristics: Tone, pace, and speech patterns (analyzed only to understand emotional context and sentiment, never for identification purposes)
  • Transcriptions: Converted text versions of your conversations
  • Interaction Logs: Details of the conversation flow and system responses
  • Emotional Insights: Analysis of emotional states and sentiment derived from voice patterns and conversation content
  • Contextual Information: Background information relevant to the conversation

Important Notes:

  • All data collected is owned and controlled by Paperminds
  • Voice Data is processed to understand emotions, sentiment, and improve conversational interactions
  • Voice analysis is used solely to enhance understanding of emotional context and user experience
  • We do not use Voice Data for biometric identification, individual profiling, or any form of personal identification
  • Only processed insights, not raw data, are shared with Flair Stratégie inc.
  • Voice recordings are processed in a way that maintains anonymity while preserving emotional and contextual understanding

4. Cookies and Tracking Technologies

We use Cookies and similar tracking technologies to track activity on our Service and hold certain information. This helps us provide a better user experience.

  • Session Cookies: To operate our Service.
  • Preference Cookies: To remember your preferences and settings.
  • Security Cookies: For security purposes.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent.

Automated Decision Making in Conversations

Our Service uses automated decision-making specifically for generating responses during conversations:

Nature of Automation:

  • Our AI systems automatically generate responses during conversations
  • Responses are based on the immediate context of the conversation
  • Decisions are made to maintain natural conversation flow
  • Automated responses aim to understand and address user inputs

What Our Automation Does:

  • Generates contextual responses to user inputs
  • Processes natural language to understand queries
  • Provides relevant information based on conversation context
  • Creates conversation summaries for Flair Stratégie inc.
  • Follows pre-defined conversation flows based on Flair Stratégie inc.'s criteria

Eligibility and Decisions:

  • Conversation flows and criteria are pre-defined by Flair Stratégie inc.
  • Any eligibility or qualification criteria are set by Flair Stratégie inc.
  • Conversations may gather information to help inform human decisions
  • Final decisions about services or actions are made by Flair Stratégie inc. representatives

What Our Automation Does Not Do:

  • Does not make final decisions about service eligibility
  • Does not create individual profiles for future use
  • Does not assess or evaluate users beyond the immediate conversation
  • Does not use conversations to make independent judgments about individuals

Important Notes:

  • All responses are generated in real-time for the current conversation only
  • Previous conversations do not influence future interactions
  • Each conversation is treated as a separate interaction
  • Conversation flows follow business rules set by Flair Stratégie inc.

Purpose of Data Collection

Paperminds collects and uses data for the following purposes:

Core Service Purposes:

  • Service Delivery: To provide, maintain, and improve our Service
  • Personalization: To tailor interactions and content to your preferences
  • Quality Assurance: To monitor and analyze usage to improve the Service
  • Research and Analytics: To generate insights and understanding from conversations
  • Legal Obligations: To comply with legal requirements and protect our legal rights

Contact Information Sharing: When you provide contact information during our conversations:

  • We will share this information with Flair Stratégie inc. for follow-up purposes
  • This sharing is based on your implicit consent when you provide contact details
  • Flair Stratégie inc. may use this information to:
    • Contact you regarding your expressed interests
    • Provide requested information or services
    • Follow up on your inquiries
    • To follow up regarding travel-related information shared during conversations

Communication:

  • If you've provided contact information, Flair Stratégie inc. may contact you with relevant information or promotional materials
  • You may opt-out of receiving these communications at any time
  • Paperminds may also contact you regarding service-related matters

Research and AI Training Purposes

Paperminds uses conversational data for research and AI model improvement:

Data Usage for Research and Development:

  • Conversation patterns and trends analysis
  • Service improvement studies
  • Behavioral insights development
  • Statistical analysis of user interactions
  • Development of conversation flows

Voice Data Training:

  • Voice recordings are used collectively to improve our recognition models
  • Multiple recordings are combined into training datasets
  • Individual voices are not identified or tracked
  • Training focuses on patterns across large datasets, not individual characteristics
  • Voice data is used to improve:
    • Emotional understanding capabilities
    • Response accuracy and relevance
    • Conversation flow optimization
    • Overall service quality

Safeguards and Controls:

  • No individual voice profile is created or maintained
  • Training data cannot be traced back to specific conversations
  • Voice recordings are processed as part of large, combined datasets
  • Focus is on collective patterns and improvements, not individual identification
  • Access to training data is strictly controlled and monitored

Important Notes:

  • We do not use voice data to identify or profile individuals
  • Training processes focus on improving overall system performance
  • Voice recordings become part of anonymous training datasets
  • Research and training activities comply with Canadian privacy laws

Legal Basis for Processing Personal Data

Our processing of your Personal Data is based on:

Consent:

  • Informed Participation: At the beginning of each conversation, we inform you that:
    • The conversation will be recorded for quality assurance purposes
    • By continuing the conversation after this notice, you acknowledge and accept this recording
  • Implicit Consent: When you provide contact information during conversations, understanding it will be shared with Flair Stratégie inc.

Legitimate Interests:

  • Service Operation: Processing necessary to:
    • Operate our conversational AI systems
    • Analyze conversations for insights and patterns
    • Improve our conversation quality and accuracy
    • Generate aggregated research findings
  • Quality Improvement:
    • Analyzing interaction patterns
    • Enhancing conversation flows
    • Improving response accuracy
  • Research and Development:
    • Advancing conversational AI capabilities
    • Developing new features and services

Legal Compliance:

  • Processing necessary to comply with Canadian privacy laws
  • Maintaining required records and documentation
  • Responding to legal requests and obligations
  • Protecting legal rights and preventing fraud

Retention of Data

We will retain data only for as long as necessary for the purposes set out in this Privacy Policy.

Conversational Data:

  • Voice Recordings and Transcripts: Retained for up to two years for quality assurance, research, and service improvement
  • Conversation Analysis and Insights: Retained for up to two years
  • Emotional and Sentiment Analysis: Retained for up to two years

Important Notes About Voice Data:

  • Voice recordings are not used for identification purposes
  • We do not train our systems to recognize or identify individual voices
  • While we analyze voice patterns for emotional context and sentiment, we do not create or store voice profiles
  • Voice recordings cannot be deleted based on voice recognition as we do not have this capability
  • If you provided contact information during a conversation, we can:
    • Track and delete that specific conversation record
    • Delete associated contact information
    • Delete any data linked to your provided contact details

Contact Information (when provided):

  • Personal Contact Details: Retained for one year from date of collection
  • Shared with Flair Stratégie inc. upon collection for their follow-up purposes
  • Can be deleted upon request when specifically linked to provided contact information
  • Client's retention period may vary according to their privacy policy

Usage and Technical Data:

  • Service Usage Data: Retained for up to one year
  • Technical Logs: Retained for 90 days
  • Analytics Data: Retained in aggregated form for up to two years

Security of Data

We implement industry-standard security measures to safeguard your Personal Data, including:

Technical Measures:

  • Encryption: Data encryption during transmission and storage
  • Access Controls: Restricted access to personal information
  • Monitoring: Regular security assessments and intrusion detection systems

Organizational Controls:

  • Employee access limited to necessary data only
  • Regular security training for team members
  • Strict confidentiality obligations for all staff

Data Protection Measures:

  • Separation of personal contact information from conversational data
  • Secure storage of voice recordings
  • Encrypted data transmission between our systems and Flair Stratégie inc.

While we strive to protect your data, no method of transmission over the Internet or electronic storage is 100% secure.

Emergency Situations and Data Breach Procedures

Paperminds maintains protocols for handling emergency situations and potential data breaches:

Data Breach Response:

  • Immediate internal notification and assessment
  • Prompt investigation of the scope and impact
  • Documentation of the incident and response
  • Implementation of necessary containment measures

Notification Procedures:

  • Relevant authorities will be informed as required by law
  • Affected individuals will be notified as soon as possible if required by:
    • The nature of the breach
    • The type of data involved
    • The risk of harm to individuals

Emergency Protocols:

  • Business continuity measures to maintain service
  • Data backup and recovery procedures
  • Alternative processing arrangements if needed
  • Emergency access controls and monitoring

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your province, country, or other governmental jurisdiction where data protection laws may differ.

Data Location and Transfers:

  • Primary Processing: Data Processing primarily occurs and is stored in Canada
  • Cloud Services: We use cloud services located in Canada and the United States
  • International Transfers: Your data may be processed in:
    • Canada (primary location)
    • United States (for specific cloud services only)

Data Protection Measures:

  • We ensure adequate protection consistent with Canadian privacy laws (PIPEDA)
  • Data transfers to the US are protected by appropriate safeguards
  • We maintain control over your data regardless of storage location
  • Our service providers must maintain at least the same level of data protection as Paperminds

Client Data Sharing:

  • When sharing data with Flair Stratégie inc., data remains under Paperminds' control
  • Processed insights shared with clients follow our data protection standards
  • Contact information shared with clients remains subject to Canadian privacy laws

By using our Service, you consent to such transfers while understanding that:

  • Your data remains protected by Canadian privacy standards
  • Paperminds remains responsible for your data protection
  • All service providers must meet our privacy requirements

Subprocessors

Paperminds uses certain subprocessors to assist in providing our Services:

Categories of Subprocessors:

  • Cloud Infrastructure Providers: For hosting and processing services
  • Voice Processing Services: For voice-to-text conversion and analysis
  • Analytics Tools: For service performance and usage analysis
  • AI and Machine Learning Services: For conversation processing
  • Data Storage Providers: For secure data storage

Management of Subprocessors:

  • Subprocessors must maintain security standards meeting our requirements
  • Regular audits and assessments of subprocessor compliance
  • Strict controls on data access and processing

Current Critical Subprocessors:

  • Cloud Services: Major cloud providers in Canada and US
  • Voice Processing: Industry-standard voice processing services
  • Storage Solutions: Enterprise-grade storage providers

Subprocessor Requirements:

  • Must maintain appropriate security measures
  • Must process data only as instructed by Paperminds
  • Must comply with Canadian privacy laws
  • Must notify us of any data incidents
  • Must allow audits and inspections

Control and Oversight:

  • Paperminds maintains control over all data processing
  • Subprocessors cannot use data for their own purposes
  • Regular monitoring of subprocessor activities
  • Ability to change subprocessors if needed

Important Notes:

  • Paperminds remains responsible for all data processing
  • Subprocessors cannot make independent decisions about data use
  • All subprocessor activities align with this privacy policy
  • Changes to critical subprocessors will be communicated as needed

Disclosure of Data

We may disclose your Personal Data in the following circumstances:

Client Data Sharing:

  • With Your Consent: When you provide contact information during conversations, we will share this with Flair Stratégie inc. to facilitate follow-up
  • Processed Insights: We share analyzed and processed conversational insights with Flair Stratégie inc. in an aggregated format
  • Note: Raw conversation recordings are not shared with clients

Service Providers:

  • Cloud Service Providers: For data storage and processing
  • Analytics Providers: For service improvement and research
  • AI and Machine Learning Services: For conversation processing and analysis
  • All service providers are bound by strict confidentiality obligations and data protection agreements

Legal Requirements:

  • If required to do so by law
  • In response to valid requests by public authorities (e.g., a court or a government agency)
  • To protect our legal rights or comply with judicial proceedings
  • To prevent fraud or enforce our policies

Business Transactions:

  • In the event of a merger, acquisition, or asset sale
  • During negotiations of any business transfer
  • While ensuring continued data protection under this privacy policy

Important Notes:

  • We only share what is necessary for the specified purpose
  • All data sharing complies with Canadian privacy laws
  • We maintain control over how shared data is used
  • Service providers cannot use data for their own purposes
  • We ensure appropriate safeguards are in place for all data sharing

Your Rights Under Canadian Privacy Laws

Under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, you have the following rights:

For Personal Contact Information (when provided):

  • Access: Request access to the contact information we hold about you
  • Rectification: Request correction of any inaccurate contact information
  • Withdrawal of Consent: Withdraw consent for future contact
  • Deletion: Request deletion of your contact information
  • Note: Deletion of contact information will not affect anonymous conversation recordings

For Conversational Data:

  • Our conversations are recorded anonymously
  • We cannot identify specific individuals from voice recordings
  • We cannot access or delete specific conversations unless linked to provided contact information
  • Voice recordings are used for quality assurance and service improvement only, never for identification

For Usage Data:

  • Access to general information about how our service processes data
  • Understanding of how we use data for service improvement
  • Information about data sharing with Flair Stratégie inc.

Your Right to Complain:

  • Lodge a complaint with the Office of the Privacy Commissioner of Canada
  • Contact your provincial privacy commissioner
  • Raise concerns directly with our Privacy Officer

To Exercise Your Rights:

  • Contact our Privacy Officer using the information provided below
  • Provide any relevant contact information you used in our service
  • Specify which right you wish to exercise

Important Notes:

  • Rights primarily apply to identifiable personal information
  • Anonymous conversation data cannot be linked to individuals
  • We maintain transparency about our data processing practices
  • All requests will be handled in accordance with applicable privacy laws

Data Portability

Due to the nature of our conversational services, data portability has specific limitations:

For Contact Information:

  • You can request your contact information in a structured format
  • Contact details can be provided in standard electronic formats
  • Associated metadata can be included upon request

For Conversational Data:

Technical Limitations:

  • Voice recordings are stored anonymously and cannot be linked to specific individuals
  • Conversations cannot be exported individually unless linked to provided contact information
  • Emotional analysis and insights are generated in aggregate form

What Can Be Provided:

  • Contact information you've provided
  • Dates and times of conversations (if linked to your contact information)
  • Any specific information you've explicitly shared
  • Conversation summaries (where available and linked to your contact information)

What Cannot Be Provided:

  • Anonymous voice recordings
  • Conversations not linked to contact information
  • Aggregate insights and analysis
  • Historical conversations without identifying information

Request Process:

  • Submit requests to our Privacy Officer
  • Provide verification of identity
  • Specify the information you're seeking
  • Allow up to 30 days for processing

Important Notes:

  • Technical limitations may affect our ability to provide certain data
  • Format of portable data will be commonly used and machine-readable
  • Some data may not be available due to anonymization
  • We will explain any limitations affecting your specific request

Provincial Privacy Laws Compliance

In addition to federal privacy laws (PIPEDA), Paperminds complies with applicable provincial privacy legislation:

Quebec Privacy Law (Law 25): As a Quebec-based company, we comply with Law 25 (Act to Modernize Legislative Provisions Respecting the Protection of Personal Information), including:

  • Enhanced transparency requirements
  • Strict data protection and security measures
  • Privacy impact assessments for technology projects
  • Mandatory breach reporting requirements
  • Data portability and deletion rights

Other Provincial Laws: We comply with privacy laws in provinces where we operate or collect data, including:

  • British Columbia's Personal Information Protection Act (PIPA)
  • Alberta's Personal Information Protection Act (PIPA)
  • Other applicable provincial privacy legislation

Additional Provincial Requirements:

  • Data localization requirements where applicable
  • Province-specific consent requirements
  • Local breach notification obligations
  • Special protection for sensitive information

Important Notes:

  • In case of conflicts between federal and provincial requirements, we apply the higher standard of protection
  • Provincial residency may grant additional privacy rights
  • Specific provincial requirements may affect data handling procedures
  • Contact our Privacy Officer for province-specific privacy inquiries

Children's Privacy

Our Service is not intended for individuals under the age of 14.

Terms of Use:

  • Our Service is explicitly intended for users aged 14 and above
  • This is clearly stated in our terms of use
  • By using our Service, users acknowledge they are 14 or older

Data Collection:

  • We do not knowingly collect Personal Data from children under 14
  • However, we cannot verify the actual age of participants
  • Users are responsible for complying with our age requirement

Important Note:

  • While we state age requirements in our terms of use, we cannot technically prevent users under 14 from using the Service
  • We rely on users to honestly comply with our age requirement
  • If we become aware that identifiable Personal Data was collected from someone under 14, we will delete any contact information provided

Cookies and Tracking Technologies

Cookies:

  • Our Service requires cookies to function properly
  • These cookies are essential for the operation of our conversational services
  • By using our Service, you accept the use of necessary cookies
  • While you can manage cookie preferences in your browser settings, our Service cannot function without essential cookies

Browser Controls:

  • You can view and manage cookies through your browser settings
  • However, declining essential cookies will prevent our Service from working
  • This is a technical requirement, not a preference option

Third-Party Services:

  • Our Service may contain links to other sites not operated by us
  • We have no control over and assume no responsibility for third-party sites
  • Third-party services may have different privacy policies and cookie practices

Important Note:

  • Essential cookies are required for our Service to operate
  • This is not optional as they are necessary for core functionality
  • If you do not wish to accept cookies, you will not be able to use our Service

Changes to This Privacy Policy

Policy Updates:

  • We may update our Privacy Policy from time to time
  • The latest version will always be posted on our website
  • The "Last Updated" date will be revised accordingly
  • All changes become effective immediately upon posting

Notification of Changes:

  • Material Changes: For significant changes that affect data handling or user rights, we will:
    • Post a prominent notice on our website
    • Update our conversational scripts to reflect major changes
    • Notify Flair Stratégie inc. of relevant updates
  • Regular Updates: Minor changes and clarifications will be posted without additional notification

Continued Use:

  • By continuing to use our Service after changes are posted, you accept the updated Privacy Policy
  • For conversations that involve contact information collection, the version in effect at the time of collection applies

Review Recommendation:

  • We recommend reviewing this Privacy Policy periodically
  • Pay particular attention when participating in new conversations or providing contact information

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact our Privacy Officer:

Zhen Chen
Paperminds (Heka Santé Inc.)
200-4388 St-Denis Street
Montreal, QC, H2J 2L1
Canada
Email: privacy@paperminds.ai

For more Information about Your Rights and Recourses.
Visit the Privacy Commissioner of Canada website: https://www.priv.gc.ca/en/for-individuals/

Effective Date

This Privacy Policy is effective as of August 1, 2024.

Acknowledgment

By using our Service, you acknowledge that you have read and understand this Privacy Policy and agree to its terms.

Additional Information for Residents Outside Canada

While our primary operations are based in Canada, we recognize that our services may reach users outside of Canada:

  • International Users: Please note that your information may be transferred to, stored, and processed in Canada or the United States where our servers are located.
  • Compliance with Local Laws: We are committed to complying with applicable data protection laws in the countries where we offer our services.

Data Protection Officer

For matters specifically related to data protection, you may contact our Data Protection Officer:

Zhen Chen
Email: office@paperminds.ai

Thank you for trusting Paperminds with your personal information. We are dedicated to protecting your privacy and ensuring that you have a secure and enjoyable experience with our services.