Privacy Policy

INTRODUCTION

  • MoCA Test Inc., a corporation incorporated under the laws of the province of Quebec, having its registered office located at 4896, boulevard Taschereau, suite 230, Greenfield Park, Quebec, J4V 2J2, Canada (“MoCA Cognition”, “Company”, “we”, “us” or “our”), respects your privacy and is committed to protecting it by complying with this privacy policy (“Policy”).
  • This Policy describes the types of information we may collect from you or that you many provide to us when you use the MoCA Cognition website (www.mocacognition.com) (“Website”), the MoCA Duo mobile application (“App”), the Montreal Cognitive Assessment (“MoCA”) available on the Website, the digital MoCA available on the App (“Digital MoCA”), and the training and certification program for administering and scoring the MoCA (“Training and Certification”) available on the Website (collectively, the “Services”), and how we use, protect, and share Personal Information when you use the Services.
  • “Personal information” means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. We will only use your Personal Information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
  • Please read this Policy carefully to understand our policies and practices. By accessing and/or using the Services, you agree and acknowledge that you understand, accept, and consent to the policies and practices described in this Policy. This Policy may change from time to time. Your continued access to and/or use of the Services indicates that you understand, accept, and consent to those changes, so please check the Policy periodically for updates.

INFORMATION WE COLLECT, HOW WE COLLECT IT, AND WHY

  • We use different methods to collect your information, including through direct interactions with you when you disclose it to us, and using automated technologies or interactions.
    • Information you disclose to us
      • Certain Services are intended solely for healthcare professionals with appropriate qualifications and/or licensure in their jurisdiction, as well as academics, researchers, or other individuals involved in medical research (“Restricted Services”). Such Restricted Services include accessing, downloading, administering, scoring and/or interpreting (“using”) a paper-based MoCA or Digital MoCA, as well as completing Training and Certification.
      • Certain Services may be accessible without disclosing any of your Personal Information, however full access to the Services, including to the Restricted Services, require that you create an account and disclose certain Personal Information.
      • Account Registration
        • To register an account, you must provide your first and last name, email address, the country where you practice, your profession and the institution for which you work or are affiliated and a password (“Registration Information”).
        • We collect your first and last name, and email to create and manage your account. You email and password must be entered every time you log into your account. We request information about your profession and institution you work for or are affiliated with to verify that you meet the eligibility criteria of being a healthcare professional, academic, researcher, or other individual involved in medical research.
        • Purchases
          • Certain Services are available for purchase, including the Training and Certification Program, and subscription to the Professional package of the App. To purchase a Service, you will be asked to provide payment details, including name of credit or debit card holder, card number, expiration date, and CVV number as well as billing address. Please note that any payment information will be collected and processed by directly payment platforms PayPal® and Moneris®, and not directly by us. Please refer to their respective privacy policies.
        • Free Training and Certification
          • Training and Certification is available at no cost for full-time (a) students, faculty members, professors, and academic researchers, or (b) employees of a publicly operated healthcare institutions. To obtain such Training and Certification, you will be required to provide sufficient proof of your full-time employment or student enrollment, for example a copy of your schedule or a letter from your employer.
        • Marketing, Promotional, Forms, Surveys or Other Communications
          • We may use your email address or other contact information you gave us from time to time to provide you with information about new features, products, or services that may be available on our Website or via our App, or to send news and information regarding MoCA Cognition or its products or services. Such communications will be sent to you in accordance with applicable laws. You can withdraw your consent to receiving these promotional communications at any time by following the instructions in the email or other form of communication, which will provide for an unsubscribe mechanism that can be readily performed.
          • Certain survey forms available on various pages throughout our Website and App may ask users to voluntarily provide a limited amount of demographic information. We may contact you by email, using the email address or other contact information collected when you filled out one of the forms on our Website or App, with the option to participate in research studies or registries. In addition, we may conduct online surveys that ask you for demographic data, such as your postal code or zip code, age, or product use.
          • Providing such demographic information and participating in such surveys or other studies are always voluntary. MoCA uses the responses on aggregated de-identified basis to improve the products and services it offers. We do not link your individual responses to Your Personal Information at any time. MoCA uses this information for internal marketing research to help us better serve our users.
        • Alerts about Upgrades and Updates
          • Our Website and App may notify you, via emails or otherwise, of any update or upgrade that need to be made to the Services or your account for the Services to function properly. This notification or email will be provided or sent to you as long as you maintain an account on our Website. You can withdraw your consent to receiving these communications at any time by following the instructions in the email or other form of communication, which will provide for an unsubscribe mechanism that can be readily performed, in which case we will use other means to bring that information to your attention in accordance with applicable law. You may also receive promotional emails about new products that maybe pertinent to enhance the cognitive testing experience. You can also unsubscribe form theses communications.
    • Information collected automatically through cookies and other automatic data collection technologies
      • As you navigate through and interact with our Website and App, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
        • Details of your visits to our Website or App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
        • Information about your computer and internet connection, including your IP address, operating system, and browser type.
      • The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and App and to deliver a better and more personalized service, including by enabling us to:
        • Estimate our audience size and usage patterns.
        • Store information about your preferences, allowing us to customize our Website or App according to your individual interests.
        • Speed up your searches.
        • Recognize you when you return to our Website or App.
      • The technologies we use for this automatic data collection may include:
        • Cookies (or browser, HTTP or app cookies). A cookie is a small file placed on the hard drive of your computer, on your browser, or within the App. You may refuse to accept cookies by activating the appropriate setting. However, if you do so, you may be unable to access certain parts of our Website or App. Unless you have adjusted your setting (e.g. browser setting) so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or App.
        • Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
    • Patient Information collected and generated when using the App
      • To administer the Digital MoCA to a patient, subject or individual (“Patient”) using the App, you must create a profile for each Patient (“Patient Profile”), which requires collecting certain information such as name, date of birth, gender, years of education, spoken language and dialect, preferred language, and any other additional health information you may want to disclose about your Patient (“Patient Profile Information”). Patient Profile Information is required to like MoCA Data to the Patient and to allow you to retrieve past MoCAs completed by the Patient.
      • The App collects answers to MoCA questions in order to generate MoCA scores, sub-scores and other metrics such as time to completion (collectively “MoCA Data”)
      • The App collects audio and screen recordings during the administering of a MoCA, which are anonymized and not linked to individual Patients. This data is used exclusively to train and improve our machine learning algorithms, ensuring the App’s accuracy and effectiveness.
      • Before using the App, you as the Patient’s healthcare professional or academic, researchers, or other individuals involved in medical research, are responsible for obtaining explicit consent from your Patient before creating a Patient Profile and administering a Digital MoCA or that you are authorized to do so under applicable laws. Such consent must cover the following:
        • Collection of Patient Profile Information (name, date of birth, gender, years of education, spoken language and dialect for the purpose of creating an account and using the App;
        • Collection of response to MoCA questions to generate and store MoCA Data; and
        • Collection of audio and screen recordings during administration of the MoCA for the purpose of training and improving the Digital MoCA’s machine learning algorithms.
      • You must ensure that Patients understand the purpose of the data collection, the purpose of the data collection, and measures in place to protect their privacy and comply with applicable laws and regulations, including encryption, secure storage practices, and access controls.
      • If your Patient does not consent to the sharing and use of their Patient Profile Information, you can use a nickname or other unique identifier in lieu of their name and not disclose any additional information aside from years of education which is required for the Digital MoCA. Alternatively, you may administer a paper-based MoCA which does not collect any Patient Personal Information.

LAWFUL BASIS FOR PROCESSING

  • The Website and App process personal data based on explicit consent in accordance with the General Data Protection Regulation (GDPR), specifically under Article 9, which allows for processing sensitive health data for healthcare purposes. In Canada, data processing is conducted in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), adhering to principles of consent, accountability, and transparency. Additionally, anonymized data may be processed to enhance the Website and App, conduct AI model training, and monitor usage.

TRANSFERRING INFORMATION

  • We may transfer information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website and App improvement and optimization) and who are contractually obligated to keep such information confidential, use it only for the purposes for which we disclose it to them, and to process the information with the same standards set out in this policy.
  • We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the General Data Protection Regulation. Any transfers of data between Canada and the European Economic Area (EEA) are conducted with appropriate safeguards, to ensure the security and privacy of data.

DATA SECURITY

  • We implement various security measures to protect data processed by the App, including encryption, secure storage practices, and access controls. While no system is completely secure, we strive to maintain the highest standards of data protection.

DATA RETENTION

  • Except as otherwise permitted or required by applicable law or regulation, we will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once the data is no longer needed, it is securely deleted, de-identified or anonymized in accordance with applicable data protection regulations. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose, including without limitation for research, analytical or quality purposes, without further notice to you or your consent.

INDIVIDUALS UNDER THE AGE OF 18

  • The Services are not intended for individuals under 18 years of age. No one under age 18 may provide any information via the Services. We do not knowingly collect information from individuals under 18. If you are under 18, do not access or use the Services, or provide any information about yourself to us. If you believe we might have any information from or about an individual under 18, please contact us at [email protected].

RIGHTS TO ACCESS, CORRECT, AND DELETE PERSONAL INFORMATION

  • Healthcare professionals, academics, researchers, or other individuals involved in medical research: You have the right to access, correct, or request the deletion of your personal information collected via the Website or the App. If you wish to exercise any of these rights, please contact our support team at [email protected].
  • We will respond to such requests in accordance with applicable privacy laws and ensure that your personal data is managed appropriately. Please note that there may be certain legal or regulatory obligations that prevent us from fulfilling some requests in specific circumstances.
  • Patients: Patients have the right to access, correct, or request the deletion of their personal information collected through the App. If you wish to exercise any of these rights, please contact the healthcare professional administering the App, or reach out to our support team at [email protected].

CHANGES TO OUR PRIVACY POLICY

  • We may update this Policy from time to time to reflect changes in our practices or legal requirements. We encourage you to review this Policy periodically. The “Last updated” date at the bottom of this Policy indicates the latest revision date.

CONTACT US

If you have any questions about this Policy or our privacy practices, you can email us at [email protected] or write to us at the following address:

MoCA Test Inc.

4896 Taschereau Blvd, suite 230,

Greenfield Park, Quebec, J4V 2J2

Canada

 

Last updated: January 7, 2025