This policy applies to personal information that is collected through the sites (whether websites or mobile applications), services, products and social media accounts of Sanctuary Cognitive Systems Corporation and its affiliates (“Sanctuary”) and describes how Sanctuary collects, uses and discloses personal information of users of its sites, services and products, and other individuals (“you”) in operating its business.

Personal Information

Personal information is any information about an identifiable individual or that permits an individual to be identified, but does not, in most circumstances, include business contact information.


Sanctuary is committed to protecting personal information and is accountable for its collection, use and disclosure of personal information in accordance with this policy and applicable privacy legislation.


Sanctuary collects, uses and discloses your personal information with your consent (which may be express or implied) or as required or permitted by law. By providing Sanctuary with your personal information (whether through Sanctuary’s sites or otherwise), you consent to Sanctuary’s collection, use and disclosure of that personal information in accordance with this policy.

Subject to legal and contractual requirements, and upon reasonable notice, you may withdraw your consent to Sanctuary’s further collection, use and disclosure of your personal information by contacting Sanctuary at the email address provided below. If you refuse or withdraw consent, Sanctuary may be unable to provide you with certain products, services or information.

Nature of Collection

Sanctuary collects personal information, wherever appropriate, directly from you or from interactions with you, but may also collect personal information from other sources. The personal information Sanctuary collects may include your name, address, email address and other information relevant to Sanctuary providing products and services to you. Sanctuary limits its collection of your personal information to the information that is necessary to fulfil the purposes Sanctuary identifies to you or as otherwise required or permitted by law.

Our Purposes for Collection, Use and Disclosure

Sanctuary collects, uses and discloses your personal information so it can:

  • communicate with you, including to send you information about products, services and events that may be of interest to you;
  • 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 sites, services and products;
  • establish and maintain a commercial relationship with you, including to establish your identity, respond to your enquires 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 or provisions.

If Sanctuary needs your personal information for any other purpose, Sanctuary will identify that purpose and obtain your consent.

Sharing of Personal Information

From time to time, Sanctuary may disclose your personal information to service providers retained by it to perform services on its behalf or any third party or parties, where you consent to the disclosure or where disclosure is required or permitted by law. Sanctuary does not sell personal information.

Storing of Personal Information

Your personal information is stored either at Sanctuary’s premises or the premises of its service providers. Sanctuary only 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.

Our Sites

Like other sites, Sanctuary uses various technologies to collect information and track your activity when you visit Sanctuary’s sites. 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 its 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 sites, time spent on Sanctuary’s sites or certain pages on Sanctuary’s sites, the files you download from Sanctuary’s sites, browsing habits and the type of browser you use, how you arrived at Sanctuary’s sites and your location. Sanctuary does not correlate this information with any personal information Sanctuary possess unless Sanctuary has your consent.

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.

Other Sites and Social Media

Sanctuary’s sites may have links to other sites or services not provided by Sanctuary, including social media sites that Sanctuary may use along with you. These sites or services may have different privacy practices and policies than Sanctuary and Sanctuary recommends that you review their privacy policies to determine if they are acceptable to you. While Sanctuary is not responsible for those privacy policies and practices, Sanctuary is responsible for any personal information it collects, uses or discloses on those sites or services under this policy.


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.

To the extent Sanctuary has arrangements with service providers to store or process personal information on Sanctuary’s behalf, its policy is to require them by contractual or other means to provide comparable protection while the information is stored or processed by them. However, some of Sanctuary’s service providers may be located in countries whose data protection laws are not as protective as those in your country of residence and, despite the measures that Sanctuary has in place, these laws may permit government and national security authorities to access personal data in certain circumstances.

Access, Correction, Inquiries and Complaints

If you wish to access or correct your personal information in Sanctuary’s custody or control or ask a question or make a complaint about Sanctuary’s personal information practices under this policy, please contact by email at

Sanctuary will evaluate any requests to access or modify your personal information in accordance with this policy and applicable laws, and subject to the protection of its confidential information and that of third parties. Sanctuary may also need to confirm your identity, before proceeding with any such requests.


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

Revised: May 21, 2021