Privacy Notice

The ways we collect PII and PHI can be broadly categorized into:

• To communicate with you. This may include: (i) providing you with information you requested from us or information we must send to you; (ii) operational communications, like information regarding your Account, or your subscription to our Services; (iii) changes to our Site, WebApp, or Mobile App, or changes to this Privacy Notice, our Terms of Service or our Cookie Policy; (iv) any questions, reminders, notifications related to your Account or your use of your Account or addressing customer service issues and troubleshooting problems with your Account; (v) to notify and alert you about data breaches, actual or potential fraud, identity theft and other fraud or security-related activities; and (vi) legal disclosures, communications about and related to any legal action, or otherwise required under our legal obligations; and any other reason notifications and alerts may be required by law;
  

• To provide Services. We use your PII and PHI to provide the Services and to manage our business operations such as to register your Account, to authenticate you when you log into your Account, to deliver the Services, and to protect the security or integrity of our Site, the WebApp, the Mobile App, the Content, our Services, and our business.;
  

• To improve our Site, WebApp, and Services and develop new ones: We monitor how you use the Site, the WebApp, the Mobile App, and the Services and use aggregated de-identified and pseudonymized PII and PHI and non-Personal Information, which we or our business partners may use, to monitor trends, so we can improve our offerings, user experience, and design new features;
  

• To detect and prevent any fraudulent or malicious activity and to make sure that our Site, WebApp, Mobile App, Content, and Services are used fairly and according to our Terms of Service;
  

• With your consent, to send you targeted advertisement such as general or personalized notices and promotional messages, or to send news about us;
  

• To comply with any laws and regulations.
  

We may share your PII and PHI with our service providers and our Affiliates that help us with our business operations. If you consented to receive marketing and promotional emails from us, we may share select PII with service providers who help us with marketing and promotional services. We may share with selected third-parties certain demographic and contact information about you, including name, date of birth and any email addresses or phone numbers to verify your identity.

We engage our service providers on separate terms, either their own terms of service or through separate agreements that impose standards for information and data protection and confidentiality and prohibit disclosure or use of your PII or PHI for any other purpose than the one for which we engaged them, unless we or they obtain your explicit consent to use it for any other purpose.

We will not rent your PII or PHI. Other than as provided in this Privacy Notice, we will generally not disclose, transfer or sell your PII or PHI without your explicit consent; however, you acknowledge and agree that we may disclose, transfer or sell your PII and your entire Account Record, including PHI, without your explicit consent under the following limited circumstances:

• Corporate financing, merger, sale, or reorganization: in connection with an actual or potential financing event, merger, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business, as part of a corporate reorganization, assignment, or other change in corporate control. PII relevant to the transaction can be used and disclosed solely for the purposes related to the transaction, including during due diligence, to fulfill any audit requirements and will be protected by security safeguards appropriate to the sensitivity of the information and contractual confidentiality obligations. Disclosure of PHI is generally not part of due diligence and audits but it may be transferred as part of your Account Record upon a change of corporate control.
  

• Protecting and enforcing our rights: where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to establish, defend, and enforce our rights, collect a debt from you, or to investigate suspicion of unlawful activities related to our Platform, Services, or your Account. We may release certain PII when such release is reasonably necessary to protect the rights, the property and safety of ourselves and others.
  

• Legal Requirements: where required by law, or pursuant to a court order, subpoena, search warrant, or other legal requirement issued by a court, tribunal, regulator or government body with competent jurisdiction to compel disclosure of your PII or PHI, such as in criminal investigations. In such instances we will limit our disclosure to the information specifically requested once we satisfy ourselves that the authorities making the disclosure request have the jurisdiction and legitimate grounds to do so.
  

• Normal course of Business: to service providers on whom we rely to conduct our business operations.
  

We take administrative, technical and physical measures to safeguard your PII and PHI against unauthorized access, unauthorized disclosure, theft and misuse.

Although we cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur, we try to minimize these risks by: (1) active monitoring: monitoring access to your PII and PHI through activity logs and regular audits to ensure that no unauthorized access attempts have been made, (2) secure storage: we store your PII and PHI over which we have custody and control in Canada in data centers that are ISO 27001 certified and adhere to global privacy and data protection best practices, (3) network security: we implemented controls to protect against unauthorized access, including segregating our internal systems from our publicly-accessible systems, (4) end-to-end encryption: we encrypt all data transmissions and communications on the Site, WebApp, and our Services from end-to-end using industry-standard transport layer security (“TLS”) or secure socket layer (“SSL”) encryption technology, and (5) training: we implemented policies, procedures that address and train our staff on the handling of PII and PHI. All our staff members and contractors are legally bound to confidentiality.

We do not store your credit card information. Payments are handled by Stripe, a reputable direct payment gateway provider. The data they collect is encrypted according to the Payment Card Industry Data Security Standard (PCI-DSS) and implement additional generally accepted industry standards.

We expect our Affiliates and service providers to protect your PII and PHI that they collect from you directly or that we shared with them, and we may enter into separate agreements with them to protect your data and to limit their use of it to the purpose for which we engaged them.

We take precautions against breaches of our security systems, but you acknowledge and agree that no company can eliminate the risks of unauthorized access to your PII and PHI and no transmission over the internet is 100% secure. Therefore, you provide your PII and PHI to us and our service providers at your own risk.

Despite our rigorous precautions against data breaches, the risk of a breach remains. We have a data breach procedure and if a breach of your PII or PHI in our custody or control occurs we will comply with the stringent breach notification requirements of the Personal Information Protection and Electronic Documents Act (PIPEDA).

IF A BREACH OF YOUR PII OR PHI THAT WAS COLLECTED WITH YOUR CONSENT DIRECTLY BY AND IS IN THE CUSTODY OR CONTROL OF ONE OF OUR SERVICE PROVIDERS, THEN THAT SERVICE PROVIDER’S BREACH POLICIES APPLY.

We keep your PII and PHI that is in our custody and control if we have a legal or legitimate business need to keep it, for example, to provide you the Services to which you subscribe or to comply with information retention requirements in Ontario or Canada.

Once our relationship ends, we generally will continue to store archived copies of your PII and PHI in our custody and control for legitimate business purposes, such as to defend a contractual claim, for audit, and to comply with the law. We maintain a records retention and destruction policy to destroy information when we no longer have a business need for it and are not required by law to keep it.

PII and PHI collected with your consent by our service providers that is under their custody and control is subject to their data destruction policies and the data retention laws applicable in that provider’s jurisdiction.

PII collected by our direct payment gateway provider to process a transaction on the WebApp and the Mobile App is stored only as long as it is necessary to complete your transaction, then it is deleted. We do not collect or store any information related to your payment transactions.

We and our service providers may continue to store and use aggregated de-identified PII and PHI to improve our respective products and services.

The PII and PHI we or our service providers collect from our Canadian and United States Clients will be stored in Canada, however their PII and PHI may be used or stored by our service providers outside of Canada

We may enter into discrete Data Collection and Sharing Agreements with our service providers that require them, among other things, to safeguard your PII and PHI. If your PII and PHI is used or stored outside your home country, these data will be subject to the laws of the country in which they are used or stored, which may differ from and be less protective of PII and PHI than the privacy laws of your country.

Only individuals 18 years of age or older may subscribe to our Services and access the WebApp and the Mobile App.

A parent or a legal guardian of individuals under the age of 18 may register for an account on behalf of a minor.

When you provide PII or PHI to open and Account, interact with a Researcher to be evaluated for a Research Study, or to provide PII to complete a transaction by credit card, you consent to our collecting your PII and PHI required to complete these activities only.

When you register your Account, you can provide your consent to receive marketing and promotional e-mails and to consent to our use of your PII and PHI in our custody and control (in aggregated and de-identified form) for Service improvement purposes, or other outlined purposes.

YOU CAN WITHDRAW CONSENT FOR OUR USE OF YOUR PII OR PHI IN FUTURE USES WITHIN THE SCOPE OF YOUR CONSENT BUT YOU CANNOT WITHDRAW YOUR CONSENT FOR OUR USE OF YOUR PII OR PHI FOR USES THAT BEGAN BEFORE THE DATE ON WHICH YOU WITHDREW YOUR CONSENT. YOU WILL ALSO NOT BE ABLE TO WITHDRAW YOUR CONSENT WHERE OUR USE OR DISCLOSURE OF YOUR PII OR PHI IS AUTHORIZED OR REQUIRED BY LAW.

Please contact visit the Settings tab in your Account or contact us at support@honeybeehub.io if you wish to withdraw your consent for our use of your PII and/or PHI.

You may access third-party websites through links available on our Site, the WebApp, or the Mobile App. These links are provided for convenience only. Once you leave our Site, WebApp or Mobile App and you are redirected to a third-party website or application, you are no longer governed by this Privacy Notice or our Terms of Service.

We have no control over those third-party websites and you access them at your own risk. We recommend that you read the privacy notices of these third-party providers so you can understand how they handle your PII and PHI.

You acknowledge that these links may lead you to third-parties that may operate in a different jurisdiction than either yours or ours. If you provide your PII or PHI to these entities, then your information may become subject to the laws of the jurisdiction(s) in which that site operates or where its facilities are located.

We want to ensure that the PII and the PHI we collect from you and that is in our custody and control is accurate, complete, and up-to-date for the purpose for which it is to be used and will destroy any information that is out-of-date or that is no longer required for the purpose for which it was collected, unless we must keep it to comply with Ontario or Canadian law.

We use reasonable means to ensure that the information in your Account record is accurate. You may update certain PII directly in your Account and you may also request access to your Account Record.

If you have questions or identify any errors in your Account Record, please contact us at support@honeybeehub.io. We will strive to address any correction requests promptly. If we dispute a correction request, we will log the reason for the disagreement.

You may access your Account Record and port the information from us to another entity. If you request a copy of your Account Record, we will provide it to you at no charge. You can request access to your Account record by contacting us at support@honeybeehub.io.

Before we grant you access to your Account records we will first authenticate you to confirm your identity. We will handle all access requests promptly, subject to applicable privacy laws. We will provide you the legends for any special codes, acronyms or other similar information in the disclosed material, so your right of access is meaningful.

To close your Account or to request that the PII or PHI we have about you be deleted, please email us at to support@honeybeehub.io. Once we receive your request and authenticate your identity we will remove your Account from active use. Upon deletion of your Account, we may keep some PII as ‎ described in section 9. However, if you would like to fully delete all PII associated with your ‎ account, please indicate so in your email to us. Please note that any PHI you may have exchanged ‎ with researchers as a result of requesting to join Research Studies may still be accessible to those ‎ researchers.

If you believe that we have not adhered to this Privacy Notice you may challenge our compliance with this Privacy Notice and our compliance with privacy laws applicable to it.

We are not responsible for the PII or PHI handling practices of third-party service providers to whom you may have given your consent to access your information, whether on our behalf or otherwise. If your complaint has to do with the privacy practice of those providers, we will direct you to them.
Please notify our Chief Privacy Officer of your complaint by emailing us at support@honeybeehub.io or by contacting us at: 100 College St., Suite 250, Toronto Ontario M5G 1L5, Canada.

We pledge to address your complaint promptly. If we cannot resolve your complaint to your satisfaction you can file a complaint with the Office of the Privacy Commissioner of Canadaor the Office of the Privacy Commissioner of Ontario. If you are unhappy with the response you receive from us, we hope you would contact us to resolve the issue, but you may also lodge a complaint with the data protection authority in your home country. They can advise you how to submit a complaint.

We may change or update this Privacy Notice from time to time. All changes and updates are logged in the CHANGE LOG section below. When our Privacy Notice changes, the Site, the WebApp, and the Mobile App will display a notice prompting you to review the changes. If we make substantive changes to this Privacy Notice, then in addition to displaying a notice on the Site, the WebApp, and the Mobile App we may also notify you by email at the email address associated with your Account.

The changes to the Privacy Notice will take effect on the date on which they were made or on the date provided in the notice.

By continuing to use the Site, the WebApp and the Mobile App, or the Services after you receive the notice you IMPLICITLY CONSENT TO BE BOUND BY THE PRIVACY NOTICE TERMS IN EFFECT ON THAT DATE ON WHICH YOU VISIT THE SITE, THE WEBAPP, OR THE MOBILE APP.