Privacy Policy

KROWDX SAFE ENTRY PRIVACY POLICY

Updated May 5, 2022

What Does Our Privacy Policy Include?

KrowdX Inc. (“KrowdX”, “our”, “we”, “us”) takes data privacy seriously and we are committed to keeping your personal information safe. We created this Privacy Policy to explain the measures we take to protect your personal information, your rights to your personal information, and to be transparent with how we use and disclose the information you provide to us. If you do not understand any aspects of our Privacy Policy, please feel free to contact us as described at the end of this Privacy Policy. We may update this Privacy Policy from time to time by posting a new version online.

Our Privacy Policy focuses on the information we collect and use when we provide the KrowdX Safe Entry Mobile Application (the “KrowdX Safe Entry App”) and related products, applications, and services to assist business customers test, manage, and monitor COVID-19 test results within their organization and to enable individual consumers to undergo and receive results from a COVID19 test (collectively, the “Services”) as well as information we collect directly through our website and other interactions. The KrowdX Safe Entry App is used to provide customers with test instructions and to display the results obtained from the KrowdX Safe Entry Testing System used with a Nostics Test Cartridge and a Nostics Sample Wand for collection of the test specimen (collectively called a “Safe Entry Test”). If you are an individual consumer, you must download and install the KrowdX Safe Entry App onto a compatible mobile smart device that you own or are authorized to use in order to receive your COVID-19 test results, and you must connect your mobile device to the KrowdX Safe Entry Test via a secure data connection.

Our Policy focuses on Personal Information – information that is about an identifiable individual, such as contact information (e.g., name, client number, employee number), Safe Entry information, including COVID-19 test results, and any other information that is or can be used alone or in combination with other information to identify an individual (collectively, “Personal Information”). When we use the term “De-Identified Information”, we mean information that has been aggregated, de-identified and/or anonymized such that it is no longer identifiable. Please read this policy carefully to understand how we treat personal information.

What Information Do We Collect?

We collect three types of information: (1) information we receive directly from our business customers in order to provide the KrowdX Safe Entry App and Services on their behalf, including information about authorized users of the Services and information about test subjects, (2) information that we collect through use of the KrowdX Safe Entry App, including information about test subjects that we collect directly from individual consumers, and (3) information we collect through our website and other interactions.

Our business customers are organizations across various sectors and industries. We rely on our business customers to comply with applicable privacy laws when collecting, using, or disclosing personal information of employees or other individuals through the Services, including by providing appropriate privacy notices and obtaining appropriate consent to collect, use, and disclose personal information through KrowdX Safe Entry App and Services. If your organization uses our Services, we encourage you to first contact your organization directly and/or review their applicable privacy policy if you have any questions regarding the personal information we process on behalf of your organization.

Information We Collect:

Business Customers:

Account Information. In order to use the Services, each authorized user at a customer is required to create an account and provide first and last name, client or employee number where applicable, email address and a password they create. We also collect Device Information and other information about the authorized user’s use of the KrowdX Safe Entry App as set out below.

Test Subject Data:

The authorized user of the KrowdX Safe Entry App for an organization must create a separate profile for each test subject. To create a profile, we collect sample ID (or, alternatively, first name) and the test subject’s Safe Entry COVID19 test results which are stored under the applicable profile.

COVID-19 Test Result Data:

The KrowdX Safe Entry App will display the test results automatically on your compatible mobile smart device via a secure data connection.

Camera, Audio, Images & Video:

With your consent, the KrowdX Safe Entry App may access your mobile device’s camera and audio for additional limited purposes. You may have the option to these mobile device features to: 1) scan a QR code located on the KrowdX Safe Entry Testing system to match it to your profile in the KrowdX Safe Entry App; 2) scan a barcode, badge, or other code to confirm your identification, if your user account is associated with other services provided by KrowdX.

SSID:

The mobile application uses SSID and WiFi to connect to the internet and for additional location capabilities described in this policy.

Mobile device and technical information.

When you use the KrowdX Safe Entry App, we collect technical information such as the type of mobile device you use, your device-operating characteristics, a unique device identifier, and other information about your session on the KrowdX Safe Entry App. We use this information to provide you with the KrowdX Safe Entry App and to improve and enhance our Services. We also use technologies, such crash logs, that provide mobile identifiers and details about your mobile device manufacturer and operating system, to collect technical information about your use of our Services that resulted in a crash or error. We use these tools to improve the quality of our service.

Customer service requests.

When you contact us, such as when you contact us through the Services to inquire about our services and products or obtain support for our services and products, we collect your name and email address. We use this information that you provide to us to respond to your inquiries and to tell you new opportunities, products or services.

Device and geolocation information.

When you use our Website, we may collect information about how you use the Website and the device you use to access it. This includes information like your device IP address, device ID, type of browser/operating system, and information about the pages you viewed. We use this information to ensure our Website can be used on your device, to personalize and tailor your experience on the Website, and to improve the functionality of the Website by understanding general usage traffic and trends.

Business Customers and Individual Consumers

Customer Support Data:

When you use the KrowdX Safe Entry App to request information from us, contact customer support, or otherwise communicate with us, you provide additional information to us which we use to respond to your request or inquiry.

Device and Browsing Information:

In order to administer and receive the results of a KrowdX Safe Entry COVID-19 test, you are required to download and install the KrowdX Safe Entry App and connect your mobile device to the KrowdX Safe Entry system through your device’s data connection. We collect technical information when you use the KrowdX Safe Entry App or other Services or visit our website. This includes information such as the type of computer or mobile device you use, your device operating characteristics, a unique device identifier such as IP address, and other information about your session including average time spent on our website or the KrowdX Safe Entry App and date and time of your use. We use this information to improve the quality of our service. In addition, the KrowdX Safe Entry App generates run time data and the date and time of the Safe Entry Test).

How Do We Use and Share Personal Information?

We may use Personal Information for the following purposes (subject to applicable legal restrictions):

To provide Safe Entry COVID-19 test results to an individual consumer who uses the KrowdX Safe Entry App.
To provide the Services on behalf of our customers, including to provide Safe Entry COVID-19 testing and to analyze COVID-19 testing results across customer locations (if requested).
To communicate with our business customers and individual consumers, provide updates, respond to customer requests, and provide customer support.
To improve and enhance our Services, including developing new products, features, and functionality.
To create De-Identified Data.
For other specific purposes that we provide you with notice of at the time the information is collected.
For compliance purposes, including enforcing our Terms of Use or other legal rights.
For security purposes to protect our KrowdX Safe Entry App and Services.

We may share Personal Information in limited circumstances (subject to applicable legal restrictions) as follows:

To subcontractors, service providers and other third parties we use to provide services that support our business on our behalf (such as storing data, sending communications, performing analytics services) and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. Our service providers may be located in the U.S., Canada, or other foreign jurisdictions.
As required by applicable law, which can include providing information as required by statute, regulation or in response to a subpoena, court order, legal process, or government request (which may include lawful access by foreign courts, law enforcement or other government and national security authorities in those jurisdictions in which we or our service providers operate).
To report, either directly or indirectly, to the U.S. Food and Drug Administration and/or Health Canada adverse events related to medical device problems where required by applicable law.
In connection with a prospective or completed merger, sale, or other asset transfers in connection with a corporate transaction, in which we are acquired by or merge with another company.
As otherwise permitted or required by law.

De-Identified Information.

We may use and share De-Identified Information created by us without restriction, including to create aggregate data for research, product development or enhancement, or statistical analysis such as to understand testing outcomes.

Other Uses With Your Consent.

In addition to the sharing described elsewhere in this Policy, we will share Personal Information with companies, organizations, or individuals outside of KrowdX only when we have consent to do so.

How Do You Access And Update Your Personal Information?

Subject to limited exceptions under applicable law, you can access, update, and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by contacting us as set out in the “How Can I Contact You If I Have Questions?” section of the Privacy Policy.

If we receive a request from a test subject or other individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.

How Is Your Information Protected?

We use reasonable physical, technical and administrative security measures and safeguards in compliance with industry standards and applicable privacy laws to protect the confidentiality and security of Personal Information. Access to Personal Information will be limited on a need-to know basis to internally within KrowdX and any third parties who provide services to us that need to access your personal information for the services. It will also be disclosed if required by law. However, even with these safeguards, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. You should report any security violations or breaches to us by contacting us at support@krowdx.io.

Where Will Your Information Be Maintained?

The KrowdX Safe Entry App is operated and managed on secure cloud-based servers located and operated within Canada and the United States. Your Personal Information (including COVID-19 test results) will be transferred to and stored on servers located in Canada and the United States. For United States citizens that reside outside the United States, you recognize that your information will be subject to U.S. laws, which may be different than required under the laws of any location where you reside. When you contact KrowdX customer support either by email or phone, data will also be transferred to Canada.

How Long Will Your COVID-19 Test Results Be Retained?

If you are an individual consumer, we retain your COVID-19 test results on the KrowdX Safe Entry App for twenty four (24) months, based on the anticipated need to access your test results as it relates to your Safe Entry record and the projected longevity of the Sars-CoV-2 virus and its variants. If you wish to retain the test result for a longer period of time, you can print or download a copy to your mobile device for your personal use. If we change our retention period, we will update this Privacy Policy accordingly.

We retain personal information on behalf of our business customers for as long as necessary to provide the Services and in accordance with our contract with the customer.

What choices do I have?

Camera Access. If you have enabled camera access so that you can use the Safe Entry app, you can remove this permission in the setting for the KrowdX Safe Entry App on your mobile device.

How Will You Know If This Policy Changes?

We may change this Privacy Policy from time to time in the future. We will post any revised version of the Privacy Policy on this page and at other places we deem appropriate.

How Can I Contact You If I Have Questions?

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or about the manner in which we or our service providers treat your personal information, or otherwise need to contact us, please email support@krowdx.io, or by regular mail at: KrowdX Inc. 250 Pl. d'Youville, Montréal, QC H2Y 2N6, Canada

KrowdX and Safe Entry System are registered trademarks of KrowdX Inc.