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This Privacy Policy (“Privacy Policy”) describes the data protection practices of Medici Technologies Inc. d/b/a Gemma (“Gemma,” “we,” “us,” and “our”), including when you visit any Gemma website that links to this Privacy Policy (the “Website”); use any affiliated mobile application (the “App”) that link to or contain this Privacy Policy; or otherwise provide data to Gemma. We refer to the Website, App, and other services provided by Gemma together in this Privacy Policy as the “Services.” This Privacy Policy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Use.

We and our service providers comply with the laws and regulations under applicable privacy laws in Canada, and specifically the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Health Information Protection Act (Ontario) and the regulations thereunder.


Table of Contents:
  1. Information We Collect
  2. How We Use Your Information
  3. How We Disclose Your Information To Others
  4. How We Protect Your Information
  5. Your Choices & Consent
  6. Third Party Services and Notice About Health Information
  7. Retention of Your Information
  8. Right to Your Data
  9. Changes to Our Privacy Policy
  10. Contact Us
1. Information We Collect

We obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.

Information You Provide to Us
We collect a variety of information that you provide directly to us. For example, we may collect your name and email address on our Contact Us page so we can reply to a message you post there. We collect your information when you open an Account and when you interact with our medical team on our App. For example, we will collect identification and contact information, such as your name, mailing address, date of birth, and payment information to be able to properly identify you, contact you, and process a credit card payment for your subscription to our Services. We will also collect information that you disclose to our medical team on our App, such as your medical history, surgeries, allergies, and other information that a medical professional may need to determine if you are eligible to receive the Services. You are under no obligation to provide us with all or some of the information required to open an account and to receive the Services, however it might preclude you from receiving our Services.

We may also collect information from you through:

The exact types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:

Information We Collect Through Automated Means
We collect certain information about your use of the Services and the devices you use to access the Services, as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies, SDKs, and similar tools, to assist in collecting this information.

When you use our Services, we collect and analyze information such as your IP address, the geographic location of your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services, error logs, and other similar information.

Our Use of Cookies and Similar Online Tools. To collect the information discussed in this Section, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies to offer you a more tailored experience.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

Information We Collect From Social Media and Other Content Platforms

When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.

If you access the Services through a third-party connection or log-in (e.g., through a social network or third-party authentication tool), you may allow us to have access to and store certain information from such third parties depending on your settings on such services. If you do not wish to have this information shared, do not use these connections to access the Services. For a description of how these third parties handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.

Similarly, if you choose to connect your App to third-party platforms or tools, or with other apps on your device (e.g., health or fitness monitoring platforms or tools, or your contacts, photos, or calendar), such third parties and tools may allow us to have access to and store additional information as it relates to your use of the Services (e.g., to access your calendar to help you schedule an appointment). If you do not wish to have this information shared, do not initiate these connections.

Information We Receive From Other Sources

We work closely with third parties (including, for example, third party intermediaries, such as the physicians, medical professionals, and pharmacies with whom we partner to provide you with the Services and their health care services, sub-contractors in technical, advertising networks, analytics providers, and search information providers). Such third parties will sometimes provide us with additional information about you.

2. How We Use Your Information

In connection with providing you with the Services, we may use your information for our business purposes to:

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use and share such combined information in accordance with this Privacy Policy.

Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

3. How We Disclose Your Information To Others

We may share your information for business purposes in the following ways:

4. How We Protect Your Information

We take a variety of technical and organizational security measures to protect your information against unauthorized access, disclosure theft or misuse. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk. Where you have chosen a password that enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the Services

5. Your Choices & Consent

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you. You may also withdraw your consent from our further use of your information and close your account. If you do so, we may still use your information for the purposes to which you consented before you withdrew consent and we may keep information about you and your previous transactions with us for audit purposes, to ensure the integrity of our data, and to fulfill legal requirements.

6. Third Party Services And Notice About Health Information

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices, including data privacy and security process and standards of any third parties, including physicians and other health care providers using the Services, the manufacturer of your mobile device and other IT hardware and software, and any other third party mobile application, website, or service to which our Services may contain a link. These third parties may at times gather information from or about you. We have no control over the privacy practices of these third parties. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

7. Retention Of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

8. Right To Your Data

You may request a copy of your account information, and we will provide it to you at no charge. You can request your account information by contacting us at​.Before we grant you access to your account information, we will first authenticate you to confirm your identity. We will handle all access requests promptly, subject to applicable privacy laws.

9. Changes To Out Privacy Policy

We may change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically. The date this Privacy Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the Privacy Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Website or App after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this Privacy Policy.

10. Contact Us

If you have any questions about this Privacy Policy or Gemma’s privacy practices, please contact us at:

Medici Technologies Inc.
4035 Rue Saint-Ambroise #314
Montreal, QC H4C 2E1