1. INTRODUCTION

This Privacy Policy describes the policies and procedures of PrecisionOS Technology Inc. (or “we“, or “PrecisionOS”) related to collecting, using, storing and disclosing personal information of individuals. In this Privacy Policy, “Personal Information” refers to information about identifiable individuals and information which can be used to identify an individual. 

PrecisionOS’s virtual reality surgical simulation solutions allow our customers to provide orthopedic training programs, using virtual reality, to their end users (collectively, the “Services”).

 This Privacy Policy explains what we do with your Personal Information when: 

PrecisionOS may amend this Privacy Policy from time to time as our business and Services evolve.

The Services are provided through the use of Oculus Quest devices, which are virtual reality headsets created by Oculus VR, a division of Facebook Inc. This Privacy Policy does not apply to the privacy practices of Oculus VR or any other third party. For more information on how Oculus VR and Facebook Inc. collect, use and disclose Personal Information, please review their applicable privacy policies.

  1. COLLECTION OF PERSONAL INFORMATION 

2.1 Customers

In order to provide the Services to our customers, we collect name, contact information and billing information. In particular, administrative users are required to submit this Personal Information to create an account on the Analytics Portal and use the Services.

2.2 End Users:

In the course of providing the Services, we collect Personal Information regarding the individuals who are using the Services. We may collect some or all of the Personal Information listed below:

  • name
  • institution
  • usage data (such as levels, events and milestones, metrics, date/time of usage)
  •  email address
  • IP address
  • type of user (resident, surgeon, sales rep)
  • location coordinates

Where indicated, users have the option whether to provide the Personal Information.

2.3 Website Users

We collect a limited amount of Personal Information from our Website visitors which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes log data such as the device’s IP address, browser type, the web page visited before you came to our website, date and time stamps associated with transactions, system configuration information and other interactions with the Website. If you contact us via the Website, we will collect any information that you provide to us, for example your name and contact details to order to respond to the inquiry.

  1. USE OF YOUR PERSONAL INFORMATION

3.1 End Users

Our primary purpose for using your Personal Information is to Provide the Services, including: 

  • Allowing you to access and use the PrecisionOS Services;
  • Analyzing training results and other performance data associated with surgical training conducting through the PrecisionOS Services;
  • Providing you with assistance (including technical assistance) in relation to your use of the Services; 
  • Personalizing and optimizing your experience of the PrecisionOS Services and providing you with software updates; and 
  • Ensuring compliance with the terms of our agreement with your organization. 

We may also use your Personal Information for other purposes if we have a legal basis for doing so, including:

  • Ensuring compliance with our own obligations under applicable law and regulations; 
  • Complying with court orders and other lawful access processes; and
  • Using your Personal Information to help us to establish, exercise or defend legal claims.

3.2 Marketing

We use Personal Information of users in order to let you know about, and invite you to participate in, our products and service offerings. We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in in accordance with applicable laws. You can opt out of receiving marketing communications at any time.

  1. DISCLOSURE OF PERSONAL INFORMATION

Where appropriate and in accordance with applicable laws and, we may share your Personal Information in the following ways:

  • Organizations who procure/administer the Services: When end users use the Services on behalf of organizations who are providing the VR training or otherwise administering the PrecisionOS account, Personal Information of end users is made available to the organization that holds the PrecisionOS license.
  • Third-Party Applications: We may share your information with a third-party application with your consent, for example when you choose to access PrecisionOS through such an application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you before allowing this feature to be employed. 
  • Service Providers, Business Partners and third parties: We may use certain trusted third-party companies and individuals to help us provide, analyze, and improve the PrecisionOS Services (including but not limited to data storage, maintenance services, chat tools, database management, web analytics, payment processing, and improving the features of the PrecisionOS Service). These third parties may have access to your Personal Information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.  For a current list of our data processors, please view our Sub-processors Page.
  • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your Personal Information may be transferred as part of that transaction. If required under applicable law, we will notify you and/or your organization (for example, via email and/or a prominent notice on our website) of any change in control or use of your Personal Information, or if either become subject to a different Privacy Policy. 
  1. SAFEGUARDING PERSONAL INFORMATION

We are committed to taking all reasonable and appropriate steps to protect the Personal Information that we hold from misuse, loss, destruction or unauthorized access. We do this by having in place a range of appropriate technical and organizational measures.

  1. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR? 

We will not keep your Personal Information for longer than we are permitted to do so under our agreement or as is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to preserve it or if we require it to enforce our agreements. 

When we are no longer permitted under our agreement with your organization or it is otherwise no longer necessary to retain your Personal Information, we will delete the Personal Information that we hold about you from our systems. While we will endeavour to permanently erase your Personal Information once it reaches the end of its retention period, some of your Personal Information may still exist within our systems, for example if it is waiting to be overwritten.

  1. HOW CAN YOU ACCESS OR CORRECT PERSONAL INFORMATION THAT WE HOLD ABOUT YOU? 

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

  1. COOKIES

When you visit the Website or access the Services (including through Oculus Quest), we may collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. You have the option of opting in or opting out of cookies collection. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this as “Device Information”.

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

 

“Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.

The Website uses “cookies” to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your email address or identity.

We may use “persistent cookies” to save your registration ID and login password for future logins to our service. We may use “session cookies” to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. We also use session cookies to verify your age, keep track of items you have viewed and store such items in your cart while you are browsing.

We may  use third-party ad companies (Google and Facebook) to help provide some of our advertising services. These third parties may place cookies on your computer and collect data about your online activities across websites or online services when you are logged into the third-party service, including for targeted advertising. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

For more information on your choices regarding third-party analytics and marketing tools, please visit the links below:

  • Facebook: https://www.facebook.com/settings/?tab=ads
  • Google: https://www.google.com/settings/ads/anonymous

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

  1. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”)

PrecisionOS generally processes Personal Information in order to fulfill contracts we have with our customers and end users and to pursue our legitimate business interests. Otherwise, PrecisionOS will obtain consent from an individual in respect of processing of Personal Information if required by law to do so.

 

Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals located in the EEA who wish to exercise these rights, should contact PrecisionOS using the contact information below in Section 13 to exercise these rights. However, where PrecisionOS is a data processor of personal data on behalf of our customer (the data controller), the request may be forwarded to the applicable data controller.

Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.

  1. RESIDENTS OF CALIFORNIA PRIVACY RIGHTS

Subject to certain limitations, the California Consumer Privacy Act provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights. PrecisionOS does not sell (as that term is defined in the CCPA) the Personal Information we collect.  

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information listed below.

  1. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.

  1. CHILDREN’S PRIVACY

Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

 

  1. ADDITIONAL INFORMATION

Questions regarding this Privacy Policy or PrecisionOS’s privacy practices should be directed to our Privacy Officer:

Attention: Privacy Officer

PrecisionOS Technology Inc.
500-321 Water St.
Vancouver, BC V6B 1B8
Email Address

privacy@precisionostech.com