Privacy Policy

At Akompa (Solutions Symbiatech inc.), your privacy is not just a compliance requirement—it's a core value. Whether you're exploring our website, joining our waitlist, participating in our research, or using our web application as a professional, we're committed to handling your personal information thoughtfully, transparently, and securely.

This Privacy Policy applies to visitors of our marketing website (akompa.com) and authenticated Users of our web application (notes.akompa.com). We adhere to applicable privacy laws and regulations, including Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). Our systems are also designed to support, where applicable, our Users' compliance with Quebec's Act respecting health and social services information.

To ensure clarity, this policy uses the following terms:

• User: The professional/clinician (e.g., psychologist or psychotherapist) who creates an account and uses Akompa's secure web application. The User remains primarily responsible for information relating to their Clients that is processed through Akompa in connection with the services they provide, and for the related legal and professional obligations.
• Client: The person (sometimes also called "patient" or "usager") receiving services from a User.

Notice to Clients: If you are a Client of a User of Akompa, please note that this User is primarily responsible for information relating to you in our systems, including elements of your clinical records and transcripts of your sessions. For any questions about that information, or to exercise privacy rights relating to it, you must contact the Akompa User offering you services directly. Akompa will not respond directly to your request to access, modify, or delete your information, except as required by applicable law.

Understanding how we handle personal information depends on the type of data involved.

• Information Akompa collects for its own purposes: When you visit our website, participate in research, create an account, subscribe to our services, or interact with Akompa directly, Akompa is responsible for the personal information it collects directly from you for its own business purposes. This may include, for example, your account information, billing information, email address, professional information, and certain technical or usage information. We determine how this information is collected, used, and otherwise processed for those purposes. In jurisdictions where the terminology is used, Akompa acts as the Data Controller for this information.
• Client-related information: If you are a User of Akompa, you remain primarily responsible for information relating to your Clients (such as identifying information, audio recordings, transcripts, and notes) that is processed through Akompa, and for the related legal and professional obligations. Akompa processes and safeguards such information solely to provide its services to you. In jurisdictions where the terminology is used, you act as the Data Controller and Akompa acts as the Data Processor for this information.

We limit the collection of personal information to what is strictly necessary.

A. From Website Visitors & Research Participants

B. From Authenticated App Users

C. Clinical Data (Processed on behalf of Users)

We use your personal information to send you the following types of electronic communications:

• Service-Related Notices: These include, but are not limited to, security alerts, account verification, and critical system updates. Additionally, Users with active subscriptions will receive automated transactional communications (such as receipts and payment confirmations) directly from our third-party payment processor. Because these notices are necessary for the security and operation of our services, you cannot opt-out of them while your account remains active. By providing your contact information (via waitlist or account registration) and using our services, you expressly consent to receive these communications in accordance with applicable anti-spam legislation (including CASL and CAN-SPAM).
• Marketing Communications: If you have expressly opted-in to receive such communications—for example, by joining a waitlist, signing up for a marketing list, or requesting product updates—we may contact you with newsletters, promotional offers, or early-access information. You have the right to withdraw this consent at any time. You may opt-out of marketing communications by clicking the "unsubscribe" link included in the footer of any such email or by contacting us directly.

We prioritize domestic data residency for sensitive clinical data.

• Primary Clinical Storage (Quebec, Canada): All core databases, Client profiles, session notes, and audio recordings are stored on secure infrastructure and secure database servers located strictly in Quebec.
• Cross-Border Transfers: To provide advanced AI, research, and operational features, certain data may be temporarily processed or stored by third-party service providers located outside of Quebec (e.g., in the United States or European Union). These categories of service providers include:

• AI & Clinical Processing Partners: Specialized AI infrastructure used ephemerally to generate transcripts and clinical notes. Data transits through these secure partners but is not stored by them for more than the intended processing time.
• Operational & Security Partners: Providers used for secure payment processing, transactional email delivery, system error tracking, and customer relationship management.
• Research Partners: Secure platforms used voluntarily for User interviews and product feedback.

Akompa ensures appropriate contractual and organizational safeguards are in place for cross-border processing where required by applicable law. For example, we conduct privacy impact assessments before transferring personal information outside Quebec in order to ensure an adequate level of protection.

• Sub-Processor List: A current list of our authorized sub-processors is available upon request by contacting privacy@akompa.com.

Clinical data and audio recordings transmitted to our AI sub-processors are used ephemerally and strictly to offer you our services. Through strict contractual protections, Akompa ensures that no clinical or personal data is ever used, saved, or shared to train the foundational AI models of these third parties. Akompa does not use this data to improve its own systems either, unless you explicitly agree to join our optional collaborators' program.

We do not sell your personal information. We only share information in the following circumstances:

• Service Providers: We share necessary data with the categories of third-party sub-processors listed above strictly to operate our service.
• Compliance with Laws and Law Enforcement: We may disclose personal information to governmental or judicial authorities if required by law, subpoena, or court order. Because Akompa processes clinical data on behalf of Users, if we receive a legal request for Client data, we will make every reasonable effort to redirect the requesting authority to the User or notify the User before disclosing any data, unless legally prohibited from doing so.
• Corporate Transactions: In the event of a merger, acquisition, financing, or sale of all or a portion of our business, personal information may be shared or transferred as a business asset. We will ensure that any acquiring entity is bound by strict confidentiality obligations and that the processing of clinical data continues to comply with this Privacy Policy and applicable privacy laws.

We keep your personal information only for as long as necessary.

A. Transcripts & Notes:

B. Raw Audio Recordings (Strictly Enforced):

C. De-Identification & Backups:

D. Aggregated System Metadata:

Data in transit is protected using TLS/HTTPS encryption, and data at rest is encrypted using industry-standard protocols. Access to the database is strictly limited to authorized Akompa engineering personnel via secure, authenticated channels.

If Akompa becomes aware of a confidentiality incident, security incident, or data breach affecting information processed through its service, Akompa will notify affected Users without undue delay where required by applicable law and will provide reasonable information and cooperation to support their compliance obligations. Akompa will also maintain a register of confidentiality incidents and, where required by applicable law, notify the Commission d'accès à l'information du Québec as well as any affected person.

We use cookies to ensure our website functions securely and to understand how Users interact with our service. You can manage your cookie preferences via our website interface.

• Necessary Cookies: These cookies are essential for the website to function properly. They include authentication, session management, and language preferences. These cookies cannot be disabled.
• Analytics Cookies: With your explicit consent, we deploy analytics cookies to understand how you interact with our website, measure page visits, and evaluate marketing campaigns. This includes our own first-party analytics stored securely in our database as well as trusted third-party analytics services. These tools collect technical and usage data, which may include your IP address, browser type, device identifiers, and browsing behavior on our site. You can manage or withdraw your consent for these cookies at any time through our cookie preferences manager.

Depending on your location and applicable law (e.g., Quebec or elsewhere in Canada), you may have specific rights regarding your personal information, including rights of access and rectification, the right to withdraw consent in certain circumstances, the right to request deletion where permitted by applicable law and subject to legal, professional, security, and retention obligations, and the right to request a copy of certain personal information in a structured, commonly used technological format where required by applicable law.

How to Exercise Your Rights: To exercise any of these rights regarding your account data, please contact our Privacy Officer at privacy@akompa.com. We will acknowledge your request within 5 business days and respond fully within 30 days, subject to any longer period permitted by applicable law.

Important Note for Clients of Akompa's Users: If you are a Client of a User of Akompa, you must generally exercise these rights directly through that User, who remains primarily responsible for information relating to you in our systems and for the related legal and professional obligations. Akompa will assist the User in responding to lawful requests within the timeframes required by applicable law.

Have questions about this policy or your privacy at Akompa? Please reach out to our designated Privacy Officer at the email below.

• Privacy Officer: Gregory Fortin-Vidah
• Email: privacy@akompa.com
• Address: Solutions Symbiatech inc., rue des Paillettes-d'Or, Sherbrooke (Québec) J1H 0M2, Canada