Last updated March 25, 2024

Thank you for choosing to be part of our community at Light AI Inc. (“Company”, “we”, “us”, or “our”). If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected].

In our Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Service.

This Privacy Policy applies your use of any online service location that posts a link to this Privacy Policy, and all features, content, and other services that we own, control, and make available through such online service location, including, but not limited to and www.light.ai (collectively, “Site”), and our application(s) (“Apps”) (we refer to them collectively in this Privacy Policy as the “Service”).

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. DO WE COLLECT INFORMATION FROM CHILDREN UNDER THE AGE OF 13?
7. WHAT ARE YOUR RIGHTS AND CHOICES?
8. WHAT ARE YOUR EUROPEAN PRIVACY RIGHTS?
9. DO WE MAKE UPDATES TO THIS POLICY?
10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?
Information You Provide
We collect information you provide directly via the Service, such as when you complete surveys (including our COVID-19 survey), register with us, subscribe for newsletters and updates, access our content, contact us, or apply for a job. We may use Service Providers (defined below) to collect this information. We may also collect information regarding your mobile device when you use our Apps. The information we collect may include information that identifies you personally (whether alone or in combination). Some examples of information we may collect include the following:

Contact Data. We may collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.

Demographic Data. We collect demographic information such as your age, gender, ethnicity, COVID-19 tests and symptoms, underlying conditions, and country, province or state. You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically. We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:

Service Use Data. We collect data about the features you use, the pages you visit, the e-mails you view, the time of day you browse, your referring and exiting pages, and other similar information.

Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.

We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:

Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.

Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us to do things such as provide you with additional functionality.

Device Fingerprinting. Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and apps.

App Technologies. There are a variety of tracking technologies that may be included in our Apps, and these are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps may include third party SDKs, which is code that sends information about your use to a server, and is in effect the app version of a pixel. These SDKs allow us to do things such as provide you with additional functionality.

Some information about your use of the Service may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant content to you on the Service.

For further information on Tracking Technologies and your rights and choices regarding them, see the section entitled “What Are Your Rights and Choices?” below.

2. HOW DO WE USE YOUR INFORMATION?
We may use the information we collect about you to:

• Provide you with our Service, as well as any other services, support, or information you have requested
• Operate, develop and improve our Service, and diagnose related problems, including training and maintaining of our artificial intelligence (“AI”) algorithm
• Personalize our Service and communications to you to your interests and needs
• Send you newsletters and information about us
• Combine information we collect about you with other public or private information sources in order to provide you with communications that may be relevant to you and to enhance our Service
• Aggregate data from our Service used for benchmarking and to develop and improve our Service
• Anonymize and aggregate your survey responses and related information with information from other people who have responded to our surveys such that you cannot be identified, and publish the anonymized and aggregated information

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We will not share your information with a third party for that third party’s own use, including for targeting advertising to you; however, we may share your information as follows:

1Service Providers. We may share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as data analytics, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or to use de-identified data for other purposes.

Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.

Consent. We may share your information for any other purpose disclosed to you and with your consent.

Anonymous and Aggregate Information. As described above, we may anonymize and aggregate your survey responses and related information with information from other people who have responded to our surveys such that you cannot be identified, and publish the anonymized and aggregated information. For information on your rights and choices regarding how we share your information, please see the section entitled “What are Your Rights and Choices?” below.

4. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?
Your personal information will be transmitted to and stored on our servers in Canada. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will use reasonable efforts to protect your personal information, transmission of personal information to and from our Service is at your own risk. You should only access the Service within a secure environment.

6. DO WE COLLECT INFORMATION FROM CHILDREN UNDER THE AGE OF 13?
The Service is intended for a general audience and is not directed to children under thirteen (13) years of age. We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA or market to children under 13 years of age. By using the Service, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 13 years of age has been collected, we will take reasonable measures to promptly delete such personal from our records. If you become aware of any personal we have collected from children under age 13, please contact us at [email protected], and we will remove such personal information to the extent required by COPPA.

7. WHAT ARE YOUR RIGHTS AND CHOICES?
Review and Update of Information You may access, update, or remove certain information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the section entitled “How Can You Contact Us About This Policy?” below.

We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. European data subjects have additional rights as set forth in the section entitled “What Are Your European Privacy Rights?” below.

Tracking Technology Choices
Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

App Technologies. You can reset your device advertising Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074. For information on how to do this on Android devices, visit Google.com. You can stop all collection of information via an app by uninstalling the app.

Location-Identifying Technologies. The location data collected through the Service depends on your device settings and permissions. You can exercise choice over the location data collected through our Service by (i) for GPS data, disabling location in your device settings or disabling location permissions to that app; (ii) for Bluetooth data, disabling Bluetooth and any Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning option in your device settings. You can stop collection of all location data via an App by uninstalling the App.

Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.

Communications
E-mails. You can opt-out of receiving e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “How Can You Contact Us About This Policy?” below with the word UNSUBSCRIBE in the subject field of the e-mail.

Please note that you cannot opt-out of non-promotional e-mails, such as those about your ongoing business relations with us.

8. WHAT ARE YOUR EUROPEAN PRIVACY RIGHTS?
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us as set forth in the section entitled “How Can You Contact Us About This Policy?” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority.

9. DO WE MAKE UPDATES TO THIS POLICY?
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact us by email at [email protected] or by mail to:

Light AI Inc.
2500 – 700 West Georgia Street
Vancouver, British Columbia
Canada V7Y 1B3