This policy explains how AXONMED Co., Ltd. ("AXONMED", "we", "us") governs the personal information of people who use the global version of the Bodycheck Care app and related services (the "Service"): who is responsible for it at each stage of its life cycle, how we keep and destroy it, how we handle complaints, how we assess privacy risks and how we record confidentiality incidents. It is our governance policy under Québec's Act respecting the protection of personal information in the private sector (section 3.2), and we apply it to every user of the global version. Our Privacy Policy explains what information we collect, why, who receives it and your rights; "section" below means a section of the Privacy Policy unless we say "this policy".
1. Scope
This policy covers:
- all personal information we hold about users of the global version, in any form: account information, scan photos and results, measurements, health values, workout records, subscription and consent records, messages you send us and technical records (section 3);
- every stage of its life cycle: collection, use, communication, keeping and destruction;
- everyone who works for AXONMED, as an employee or a contractor ("staff"), and, through their contracts, our service providers (section 7).
AXONMED is a small company. This policy is proportionate to the nature and scope of our activities.
2. Roles and responsibilities
The person in charge of the protection of personal information
Seungho Shin, Chief Executive Officer, is the person in charge of the protection of personal information (develop@axonmed.io, +82-70-5236-0724). He is also our Privacy Officer (section 1). He:
- approves this policy and every change to it, and reviews it at least once a year;
- makes sure that staff know and follow this policy, and oversees how we handle personal information;
- is consulted from the start of every project that involves personal information, and approves privacy impact assessments (section 5 of this policy);
- approves each service provider that receives personal information and keeps its contract;
- receives and answers requests and complaints (section 4 of this policy);
- decides how a confidentiality incident is handled and who is notified, and keeps the incident register (section 6 of this policy).
He may delegate some of these duties in writing to a member of staff. If he does, we publish the title of that person on this page.
Responsibilities at each stage of the life cycle
| Stage | What we do | Who is responsible |
|---|---|---|
| Collection | We collect only the information needed for the purposes in section 5, tell you why when we collect it, and ask for your separate, express consent for health information (section 4). We do not collect a new kind of information or use information for a new purpose until the person in charge has approved it, the Privacy Policy has been updated and, where needed, you have given new consent. | Person in charge (approval); staff who build the app and servers (implementation) |
| Use | Information is used only for the purposes in section 5 or purposes directly related to them. Staff access personal information only when they need it to do their work, for example to answer your request, keep the Service secure or fix an error. | All staff |
| Communication | Information is communicated only to the service providers in section 7, under written contracts, or when the law compels us (section 7). Before information is communicated outside Québec, its privacy impact is assessed (section 5 of this policy). | Person in charge |
| Keeping | Information is kept encrypted in private storage in Seoul, Republic of Korea (section 10), for the periods in section 9. Access to production data is limited to the staff who need it and is logged. | Staff with access to production systems |
| Destruction | Information is destroyed at the end of its retention period, as section 3 of this policy describes. | Staff with access to production systems; person in charge (yearly check) |
Every member of staff
- is bound by confidentiality before getting access to personal information, and reads this policy first;
- uses personal information only to do their work;
- never asks a user for a password or a payment card number;
- reports any suspected confidentiality incident to the person in charge without delay (section 6 of this policy);
- passes any privacy request or complaint they receive to the person in charge.
Staff who answer develop@axonmed.io verify the identity of the person making a request as section 11 describes. The person in charge reminds staff of this policy at least once a year and whenever it changes.
Service providers process personal information only on our behalf and on our instructions, under written contracts that require them to protect it, keep it confidential and not use it for their own purposes (sections 7 and 8).
3. Keeping and destroying personal information
How long we keep it. We keep personal information only as long as it is needed for the purposes for which it was collected, or as the law requires. Section 9 sets out every retention period. In summary:
- account information, scan results, measurements, health values, workout records and settings: until you delete them or your account; an account that is not used for 3 years is deleted after notice;
- scan photos and body landmarks: deleted within 7 days of your request, at once when you delete your account, after 12 months without use, and no later than 45 days after we determine that keeping them is no longer necessary;
- subscription and consent records: 3 years after the consent or 1 year after the subscription ends, whichever is later;
- server access records: up to 1 year; email verification records: 30 days;
- privacy requests (including deletion requests) and our replies: 24 months after the request is closed; other emails: 3 years after the conversation ends, or within 7 days after you delete your account, unless we need one for an open refund, dispute or legal claim;
- backups: overwritten within 6 months.
How we destroy it. When a retention period ends, or when you delete information or your account, we destroy the information so that it cannot be restored: database records are erased, photo files are removed from storage (older stored versions of a file expire within 6 months), and encrypted backups are overwritten within 6 months. Automated jobs apply the periods that depend on inactivity. We do not keep paper records of your information.
Anonymisation. If we want to anonymise personal information instead of destroying it, we do so only as Québec law permits (for serious and legitimate purposes, according to generally accepted best practices and the criteria set by regulation), and only after a privacy impact assessment approved by the person in charge.
Yearly check. At least once a year, the person in charge checks that the retention periods are applied, including to backups, older stored versions of files and server access records.
Data stored in Apple Health or Health Connect on your device is not held by us.
4. Questions, requests and complaints
You can ask a question, make a request about your personal information (access, correction, deletion, portability and the other rights in section 11) or complain about how we protect your personal information. It is free, and we will not treat you differently for doing so.
- Write to us. Email develop@axonmed.io, from the email address on your account if you can, with the subject "Privacy request" or "Privacy complaint". You can write in French or English, and we answer in the language you use. You do not need an account or the app.
- Acknowledgement. We confirm receipt promptly.
- Identity. Where needed, we verify that you are the person concerned, or someone you have authorised, as section 11 describes. We never ask for your password.
- Review. The person in charge reviews the request or complaint, the information concerned and what happened, and decides what to do.
- Answer. We answer in writing within 30 days of receiving a question or complaint, and within 20 working days of receiving a request (section 11); access and correction requests are answered within 30 days at the latest. If we refuse a request in whole or in part, we give our reasons and the provision of law we rely on, and tell you how you can challenge the decision. If a complaint is well founded, we tell you what we have done to correct the situation.
- If you disagree. Reply with the subject "Privacy appeal", and we will review the decision and answer in writing within 45 days (section 11). You can also complain at any time to the Commission d'accès à l'information du Québec (cai.gouv.qc.ca) or to the Office of the Privacy Commissioner of Canada (priv.gc.ca). If we refuse an access or correction request, or do not answer it in time, you can ask the Commission d'accès à l'information to examine the disagreement within 30 days.
- Records. We keep each request or complaint and our reply for 24 months after it is closed (section 9), and we use them to improve our practices.
5. Privacy impact assessments
We assess the privacy impact:
- before any project to acquire, develop or overhaul an information system or an electronic service that involves personal information, including new app or server features that collect, use or communicate personal information in a new way;
- before communicating personal information outside Québec, including when a service provider outside Québec keeps or processes it for us;
- before using personal information for a new purpose or anonymising it (section 3 of this policy).
The person in charge is consulted from the start of the project. The assessment is proportionate to the sensitivity of the information, the purpose of its use, its quantity, its distribution and the medium on which it is kept. For a communication outside Québec, it considers the sensitivity of the information, the purposes for which it will be used, the protection measures (including contractual ones) that will apply to it, and the legal framework of the place where it will be communicated, including the personal information protection principles that apply there. We communicate the information only if the assessment shows that it will receive adequate protection, under a written agreement that takes the results of the assessment into account.
Our assessment of communications outside Québec covers the storage of your information in the Republic of Korea (Amazon Web Services, Seoul) and the service providers in the United States listed in section 7 (RevenueCat, Expo, Apple and Google), which receive no scan results, measurements or health values. We review an assessment when the processing changes significantly, and at least once a year as part of the review of this policy.
Privacy by default. The posture and body-composition analyses, which assess your physical characteristics, run only when you start a scan, and the app reads Apple Health or Health Connect only after you connect it (sections 6 and 14). The app contains no ads, advertising identifiers or third-party analytics, tracking or advertising tools (section 3.10).
6. Confidentiality incidents and the incident register
A confidentiality incident is any access to, use or communication of personal information that the law does not authorise, the loss of personal information, or any other breach of its protection.
- Report. Staff report any suspected incident to the person in charge without delay.
- Contain. We take reasonable measures to reduce the risk of injury to the people concerned and to prevent new incidents of the same kind.
- Assess. The person in charge assesses whether the incident presents a risk of serious injury, considering the sensitivity of the information, the anticipated consequences of its use and the likelihood that it will be used for injurious purposes.
- Notify. If there is a risk of serious injury, we promptly notify the Commission d'accès à l'information du Québec and the people concerned, and we may also notify any person or body that could reduce that risk. We notify the Office of the Privacy Commissioner of Canada and other authorities as their laws require (section 10). For scan photos and body landmarks, see also section 9.
- Record. We record every confidentiality incident in our incident register, including incidents that do not present a risk of serious injury. Each entry describes the personal information concerned (or why it is not known), the circumstances, the date or period of the incident, the date or period when we became aware of it, the number of people concerned (or an estimate), our assessment of the risk of serious injury, the dates of any notices to the Commission and to the people concerned (and whether a public notice was given, and why), and the measures taken to reduce the risk of injury. We keep the register up to date, keep each entry for at least 5 years after the date or period when we became aware of the incident, and give a copy to the Commission on request.
7. Changes to this policy
The person in charge reviews this policy at least once a year and whenever a change in the law, the Service or our service providers affects personal information. We publish each new version on this page with its effective date. The English and French versions are changed on the same day.
8. Contact
- Person in charge of the protection of personal information: Seungho Shin, Chief Executive Officer, develop@axonmed.io, +82-70-5236-0724 (weekdays 09:00 to 18:00 Korea Standard Time, GMT+9).
- AXONMED Co., Ltd., Unit 217, 2F, Commercial Bldg., 85 Haemil 3-ro, Sejong-si 30092, Republic of Korea. Business registration number 786-81-04109. Mail-order sales business report number 2026-Sejong-0575.
- Commission d'accès à l'information du Québec: cai.gouv.qc.ca. Office of the Privacy Commissioner of Canada: priv.gc.ca.