Privacy Policy

This Privacy Policy describes how Sanctuary Cognitive Systems Corporation (“Sanctuary,” “we,” “us,” or “our”) collects, uses and discloses personal information while operating our business, including through our website that links to this policy (the “Sites”) and our social media accounts, and when offering, providing or communicating about our products and services (together with the Site, the “Services”). This Privacy Policy also explains how to exercise your rights with respect to your personal information in our control.

This Privacy Policy applies to personal information (also sometimes referred to as “personal data”), which is information about an identifiable individual. This Privacy Policy does not apply to personal information about our employees, or to information that is not personal information.

Table of Contents

Collection and Use of Personal Information

  • Disclosure of Personal Information

  • Information Collected Automatically

  • Legal Basis for Processing

  • Third Party Sites

  • Security of Personal Information

  • Internal Procedures and Policies

  • Retention of Personal Information

  • Your Rights With Respect to Personal Information

  • Contact Us

Collection and Use of Personal Information

Products and Services. We collect personal information from you to provide our products and services and manage our customer relationships. We are a business-to-business company, so most of the information collected from our customers is business information and not personal information. However, we may collect business contact information for employees and representatives of our business customers, which may constitute personal information in certain jurisdictions. 

Inquiries. If you contact us with an inquiry, we will ask for your name and email address so that we can contact you to respond to your inquiry. You may also choose to provide a telephone number, URL to your business website, or additional comments.

Other. We collect your name, title and contact information if you choose to provide it to us, such as when you register for an event or request information from us. Where permitted by law, we may also collect this information from other sources, such as a business directory or your employer.

In addition to the uses described above, we use the personal information we collect to:

  • understand and respond to your needs and preferences, including recommending particular sites, services and products to meet your needs and preferences;

  • develop, market, sell or otherwise provide Sanctuary’s Site, services and products;

  • market our products, services and events to you, including by email, postal mail or other means. You can opt-out of receiving promotional communications from us by following the opt-out or “unsubscribe” instructions provided in your email, or by contacting us as set out below;

  • establish and maintain a commercial relationship with you, including to establish your identity, respond to your inquiries and requests, administer accounts, collect and process payments, and to fulfill contractual obligations;

  • provide ongoing service to you;

  • develop, manage and improve Sanctuary’s business and operations;

  • protect Sanctuary from error, breach of contract, negligence, fraud, infringement, misappropriation, and illegal activity;

  • engage in a business transactions, including a purchase, sale, lease, license, merger, amalgamation or any other type of acquisition, disposal, securitization of financing or other business transaction involving Sanctuary or a part of its business; and

  • comply with legal or regulatory requirements.

Disclosure of Personal Information

Service Providers: We may transfer (or otherwise make available) personal information to third parties who provide services on our behalf.  For example, we may use service providers to host our Site, store data and provide back-up (including cloud-based service providers), process payments, or provide data analytics. Personal information may be maintained and processed by us or our third-party service providers in the US, in any province in Canada (including, if you are a resident of Quebec, outside of Quebec).  Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. For more information about the way in which our service providers treat personal information, please contact us as set out in the “Contact Us” section below.

Sale of Business:  We may transfer personal information as an asset in connection with a prospective or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Sanctuary or as part of a corporate reorganization or other change in corporate control.

Legal: Sanctuary and our service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian or foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable law. 

Information Collected Automatically

Cookies:  Like other sites, our Site uses various technologies to collect information and track your activity when you visit. In particular, Sanctuary may use cookies (small files sent to your browser to store information) or pixel tags (invisible images placed on certain pages of its sites) to collect information about your use of our Sites and other sites, your equipment, browsing actions and patterns. For example, these tools may automatically collect information such as an identifier assigned to your device, your Internet Protocol address (IP address), the date of your last visit to Sanctuary’s Site, time spent on Sanctuary’s Site or certain pages on Sanctuary’s Site, the files you download from Sanctuary’s Site, browsing habits and the type of browser you use, how you arrived at Sanctuary’s sites and your location. Sanctuary uses this information to help make informed decisions on providing relevant and engaging content for our Site visitors and to improve the Site functionality.

You may be able to control cookies using your browser settings. For example, you may be able to set your browser to block or delete cookies, or to notify you before a cookie is set. If you block cookies, you may not be able to use all the features of Sanctuary’s sites. By continuing to use Sanctuary’s sites without changing your browser settings, you consent to Sanctuary’s use of cookies as described above.

Social Media: We may offer you the opportunity to engage with Sanctuary content on or through third-party social media sites, plug-ins and applications (“Social Media”). When you engage with us or our content on or through Social Media, you may allow us to have access to certain information associated with your social media account, such as engagement metrics and actions. Each Social Media platform has their own privacy policies. You may be able to control the information we receive from Social Media through the privacy settings on the applicable social media site.

Legal Basis for Processing

We rely on one or more of the following legal grounds (as appropriate) to process personal information:

  • To enter and perform a contract with you or to perform any steps you require from us before entering into a contract.

  • To pursue our legitimate business interests in establishing, managing or concluding our relationship with you.

  • Where you have consented to us processing your personal information, or where an exception to the requirement to obtain consent applies.

  • To comply with our legal obligations and establish, exercise or defend our legal rights.

Where personal information is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain of our services.

Third Party Sites

Our Site may contain links to other websites, including social media sites, that Sanctuary does not own or control and that are not governed by this Privacy Policy. We provide links to third party websites as a convenience to the user.  These links are not intended as an endorsement of or referral to the linked websites.  We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Security of Personal Information

Sanctuary takes steps to protect your personal information in Sanctuary’s custody and control from loss, misuse, unauthorized access and alteration by using reasonable physical, organizational and technological security measures. However, no system or security measure is completely secure. Any transmission of your personal information to Sanctuary is at your own risk.

Security of Personal Information

Sanctuary takes steps to protect your personal information in Sanctuary’s custody and control from loss, misuse, unauthorized access and alteration by using reasonable physical, organizational and technological security measures. However, no system or security measure is completely secure. Any transmission of your personal information to Sanctuary is at your own risk.

Internal Procedures and Policies

In addition to the measures to protect your personal information described in the previous section, we have drafted and implemented certain internal procedures and policies regarding our handling of personal information to facilitate our compliance with this Privacy Policy and applicable laws, including the following:

  1. A framework for the keeping and destruction of the personal information, including where we may keep anonymized data;

  2. Defining and describing the roles and responsibilities of the members of Sanctuary personnel throughout the life cycle of the personal information;

  3. A process for dealing with individual complaints and requests for personal information and exercising of the individual’s rights under applicable data protection laws; and

  4. A management and IT policy and procedure for addressing potential data breach incidents involving personal information in the custody of Sanctuary.

If you would like additional information about these procedures and policies, please contact our Privacy Officer using the information found further in this Privacy Policy.

Retention of Personal Information

Personal information is maintained on our servers or those of our service providers and is accessible by authorized employees, representatives and agents who require access for the purposes identified in this Privacy Policy. Sanctuary retains your personal information as long as it is required for the reasons it was collected, to fulfill Sanctuary’s legitimate business needs to retain personal information for auditing, reporting or dispute resolution purposes, or to comply with legal requirements.

Your Rights With Respect to Personal Information

You may request access, updating or correction of your personal information (subject to limited exceptions prescribed by law) by submitting a written request to our Privacy Officer (see “Contact Us” below).  You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a privacy regulatory authority. If you have any questions about these rights, or you would like to exercise any of them, please contact us as described below. We may request certain personal information for the purposes of verifying your identity.

Changes

Sanctuary reserves the right to change this Privacy Policy at any time, and Sanctuary will take reasonable steps to advise affected individuals of any material changes, including by posting the revised Privacy Policy on our Site or otherwise giving you notice of the amended Privacy Policy. You should review this Privacy Policy regularly to ensure that you are aware of any changes made.

Contact Us

Please contact our Privacy Officer at privacy@sanctuary.ai if you have any questions, comments
or complaints about this Privacy Policy or the personal information practices of us or our
service providers.