Privacy Policy

Last updated: October 20, 2020

This policy describes how Optania Solutions Inc. ("Optania", "we", "us") collects, processes, uses and shares personal information and personal data about users of Ali, the robot companion through the Ali mobile application (the "Application"). This policy does not apply to Optania’s other activities.

In this policy, the term personal data refers to information about an identifiable individual.

The contact details of the data controller under this policy are as follows:

• Optania Solutions Inc.
• 284 rue de l’Hôtel-de-Ville
• Saguenay (Québec) G7H 4W7
• vieprivee@optania.com

Basis for Data Processing

Our processing of personal data is primarily based on the following principles:

• We process your personal data to the extent necessary to provide you with services as agreed by you or your educational institution.
• We may process some personal data because you have specifically consented to its processing. You may withdraw your consent at any time.
• We process some personal data on an anonymous basis in order to improve the operation of the Ali chatbot, including for machine learning purposes.

Data We Collect

Information from a third party

We collect some personal data from your educational institution. This data may include:

• First name
• Email address assigned by the Cégep
• Gender
• The organisation (component) you attend (Name and 6 digit code)
• List of study programs (Program code and name)
• Student’s current session index
• Unique identification key issued by the student management system

Information from you

We collect information that you voluntarily provide to us through the Application. This information may include:

• Any information you enter into the Application during a conversation with the chatbot.

ATTENTION: You never need to identify yourself directly to the chatbot, it knows who you are because your identity is authenticated by your educational institution.

Data collected automatically

We collect certain data automatically as you interact with the Application for the purpose of customising and refining the Application as well as detecting misuse. This data may be recorded during each interaction with the Application and may include:

• Your device’s operating system;
• Your device’s language setting;
• The IP address from which your device accesses the Application;
• The country, state, or city and the postal code where your device is located;

How is Your Data Used?

We use your personal data for the purposes described below. Some uses involve data that you specifically consent to, while other uses are necessary to provide services to you or are based on our legitimate interests.

Authentication

We use the personal data provided by your educational institution to identify you, to ensure that you are authorised to use the Application, and to introduce you to resources relevant to your situation through the Application.

Communicating with you

We may use the personal data you have transmitted to us (for example, your name and email address) to communicate with you about your data and our services, but only if you have provided us with such data and agree to receive communications from us. We comply with all applicable regulations regarding unsolicited electronic mail. If you no longer wish to receive electronic communications from us, you may notify us at any time by writing to us at: vieprivee@optania.com.

Conversations

We use the content you provide to us during conversations with the Ali chatbot to enable the chatbot to continue the conversation with you. This data is processed by a natural language understanding engine in order to provide you with answers adapted to your situation.

We use data provided by your educational institution to identify you to the institution`s personnel or counsellors when you specifically consent for us to contact these individuals on your behalf or to assist you.

Machine learning

We use your personal data to train our models and conversational motors in order to better respond to the needs of the student population. The data that is used for machine learning is anonymised and does not identify you.

Other than the responses provided by the chatbot, no decision affecting your rights or student status are made for you through our models based on your personal information.

Research

Your personal data may be used for basic and applied research purposes. Only pseudonymized data is shared for research purposes and thus the researchers involved do not have access to your identity.

No commercial use

We do not use your personal data for commercial purposes and do not allow anyone else to do so. We may use research or analysis results that do not include personal data to develop other products or services intended for commercial exploitation.

How is Your Data Stored?

We store collected personal data until you request that we destroy it, our business no longer requires its storage, or its destruction is required by your educational institution. We do not, however, make a commitment to store collected personal data for any specific period of time. Your conversations with the chatbot may be stored on an anonymous basis.

The collected personal data is stored electronically on servers located in Canada. These servers are operated by our service provider, Amazon Web Services, who has made a written commitment to us to treat your personal data as confidential.

Personal data collected about individuals outside of Canada is transferred to Canada. Canada is recognized as a suitable jurisdiction for transfer of personal data from the European Union.

How is Your Personal Data Protected?

Pseudonymisation

We use pseudonymization to protect your personal data. This means that your specific personal data such as your first name, your Cégep-assigned email address and your unique identification Key issued by the student management system are encrypted among your other stored personal data, which is only associated with a unique dummy identifier.

Security

Your personal data is hosted by our service provider, Amazon Web Services, who is committed to using industry-standard security measures to maintain data integrity and confidentiality.

Personnel

Our employees and providers are aware of the sensitive and confidential nature of the personal data that is collected, particularly sensitive data, and are trained in the appropriate security measures to prevent unauthorised access to personal data.

Notification

In the event that an unauthorised access to personal data is discovered or reasonably suspected, we will take all the steps required by law to notify the appropriate individuals and authorities.

Who Has Access to Your Data?

We only share your personal data as described in this policy, where we have your express consent, or where it is expressly permitted or required by law. Your personal data may be shared with the categories of persons described below for the identified purposes.

Employees

Your personal data is only accessible to our managers and employees who need access to it to carry out the uses set out in this policy. The vast majority of our employees are not authorised to access personally identifiable information.

Service providers

We share some personal data with our hosting and technology infrastructure providers for the sole purpose of providing hosting services for our software solution. No secondary use of personal data by our providers is permitted.

Sharing with educational institutions

We share some personal data with counsellors or your educational institution when you specifically consent to such communication through the Application.

Except where the law expressly permits or requires the disclosure of personal data without your consent, we do not share your personal data with your educational institution.

Researchers

We share pseudonymized data with researchers for basic and applied research purposes. This data does not contain personally identifiable information and remains subject to the individual`s right to consent withdrawal, erasure and objection.

Legal obligations

We may disclose personal data if expressly permitted or required by law, or if so compelled by a competent authority. We will not disclose sensitive personal data except as expressly required by law or as permitted by law in the event that an individual`s life or safety is at risk.

Company transfer

In the event that the sale or restructuring of all or part of our company is planned, we may share the personal data we collect with the persons or organisations involved before and after the transaction, whether or not the transaction is carried out. In such a case, these persons or organisations agree to keep the personal data confidential and to use it exclusively for the purpose of evaluating the feasibility or appropriateness of the transaction and in accordance with this policy.

What Are Your Rights Regarding Your Personal Data?

Accessing your data?

To access your personal data or to have your personal data amended if it is inaccurate, you may write us a request at vieprivee@optania.com or the data controller’s address listed at the beginning of this policy.

We will respond to your request promptly (within 30 days of receipt), by providing you with access to the personal data we hold about you. Where required by law, we will provide you with your data in a commonly used machine-readable format.

Deletion

You may request the deletion of your personal data. To make such a request, please email us at vieprivee@optania.com. We will respond to your request as quickly as possible (within 30 days of receipt). You cannot use the Application without allowing us to collect your personal data. Data already submitted will continue to be used for machine learning purposes but will not be associated with your identity.

Complaints

Our processing of personal data is governed by the laws and regulations applicable in the province of Quebec and the Quebec authorities are competent to receive any complaint or claim relating to the processing of your personal data.

Verification

We may verify the identity of individuals seeking to access their personal data. Information collected for this verification will not be used for any other purpose.

Policy Modification

We may modify this policy from time to time to reflect changes in our personal data management practices. In the event that a change is made, the new policy will be available via a URL link (www.optania.com/ali/privacy).

We will notify you of any important changes to our privacy policy via the Application or by email within a reasonable time of the new policy coming into effect. If we process your personal data on the basis of your explicit consent, we will not process your data for any new purpose without your explicit consent.

Additional Information

For any additional information regarding the processing of your personal data, you may contact us at the address indicated at the beginning of this policy.