Privacy Policy

1. Introduction

This Website privacy policy (“Website Privacy Policy”) provides information on the collection, storage, use, sharing, disclosure and transfer (“Processing”) by MindPort (“we”, “our”, or “us”) of information that relates to an identified individual or to an identifiable individual, as defined under applicable data protection laws (“Personal Data”) in connection with visitors (“Visitors” or “you”) of the MindPort websites that refer or link to this Privacy Policy (collectively - “Website”). It also provides you with information about your privacy rights in relation to such Processing of your Personal Data.

2. Scope of the Website Privacy Policy

This Privacy Policy applies to the Processing of Visitors’ Personal Data in relation with their visit of our Website only. Processing activities performed by MindPort in relation to our products are governed by our Platform Privacy Policy.

3. Who is responsible for processing your personal data?

MindPort is responsible for processing your Personal Data.

• For the purpose of such Personal Data Processing activities identified under this Website Privacy Policy, MindPort is deemed Data Controller or Business, as such are defined under applicable data protection law.

• If you have any questions about this Website Privacy Policy or about our data protection practices pursuant to Article 27 of the General Data Protection Regulation (“GDPR”), you can contact us. See how to contact us below.
  
  

4. Which Personal Data do we process about you and how?

MindPort collects and processes Personal Data that directly identify you (e.g. name, email, contact details, etc.) and that indirectly identify you (e.g. unique identifiers, behavioral data, etc.), from various sources.

• Details
  
  We collect and process Personal Data about you:
  
  When you provide such personal data directly to us When you contact us, request information, or give us feedback via our Website, we may collect the following categories of Personal Data about you:
  
  

• Identification and contact data

• First and last name, email address, and telephone number

• Professional or Employment-Related Data

• Job position, workplace, and industry

• Any other Personal Data you voluntarily choose to provide

• Personal Data in information request or feedback you send us

• 
  
  When you provide such personal data indirectly to us
  
  We may collect Personal Data about you with the help of third parties. For more information about this Processing, please refer to our Platform Privacy Policy.
  
  When you use our Website and such personal data is collected automatically
  
  When you visit or interact with our Website, we may collect or generate through cookies the following categories of Personal Data about you:
  
  

• Unique identifiers

• IP address, cookie IDs, device IDs, web beacons, pixels, and other similar technologies (as described in our “Cookies Policy")

• Device and technical data

• Domain server, type of device/operating system/browser used to access the Sites, local and language settings; session logging, heatmaps and scrolls; screen resolution, ISP, referring or exit pages; and date and time of your visit.

• Digital behavioral data

• Web page interactions (clicks, browsing, zooms and other interactions), referring web page/source through which you accessed the Website, and statistics associated with the interaction between device or browser and the Website.

5. Why do we use your Personal Data?

We process your Personal Data for various purposes including to administer our Website, to develop and improve the performance of our Website, respond to your requests, for our legitimate interest and to respond to a request from a regulator or to defend a legal claim in order to comply with applicable laws.

Below you will find a summary of the purposes for which we process your Personal Data with the legal basis for this processing:

Purpose of processing & Legal basis

• Communicate with you and to inform you of MindPort's products, services and events (collectively - “Marketing Communications”) as further described in the Platform Privacy Policy 

  • Consent or legitimate interest

• Administer and protect our Website, prevent and to investigate fraud and other misuses

  • Legitimate interest and compliance with a legal obligation

• Analyze, develop, improve and optimize the use, function and performance of our Website. Customize or personalize your experience

  • Consent or legitimate interest

• Fulfill your requests and respond to your inquiries, such as to send a requested report

  • Legitimate interest

• Protect the rights, safety, property, or operations of MindPort, you, or others

  • Compliance with a legal obligation

• Respond to regulator, law enforcement authorities, other government officials request or your data subject requests

  • Compliance with a legal obligation

• Resolve disputes and defend a legal claim

  • Compliance with a legal obligation

6. How long do we keep your Personal Data?

Your Personal Data will be stored by us and our service providers in accordance with applicable data protection laws and data protection authorities guidelines to the extent necessary for the processing purposes set out in this Website Privacy Policy. Subsequently, we will delete your personal data in accordance with our Data Retention Policy or take steps to properly render the Personal Data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes).

•  Below you will find a summary of the data retention related to each purpose of processing:
  
  

Purpose of processing & Data retention

• Administer and protect our Website, prevent and to investigate fraud and other misuses

  • For the time necessary to administer and protect our Sites and then archived as required by applicable law or regulation

• Customize or personalize your experience

  • 13 months

• Fulfill your requests and respond to your inquiries, such as to send a requested report

  • 2 years from the request

• Communicate with you and to inform you of Marketing Communications

  • 2 years from your last contact or as soon as you request that we stop contact you for this purpose

• Analyze, develop, improve and optimize the use, function and performance of our WebsiteCustomize or personalize your experience

  • 13 months

• Protect the rights, safety, property, or operations of Dust, you, or others

  • As required by applicable law or regulation

• Respond to your data protection requests and requests or communications from law enforcement authorities or other government officials

  • For the time necessary to respond to the request or communication and then archived as required by applicable law or regulation

• Resolve disputes and defend a legal claim

  • In case of a dispute, until the settlement of the dispute ; in case of a legal claim, for the duration of the proceedings and until the ordinary and extraordinary means of recourse are exhausted with regard to the decision rendered.

7. When and with whom do we share your Personal Data?

Your Personal Data is shared for business and commercial purposes within MindPort and with third parties such as service providers, and, upon request and in line with legal requirements, with government, judicial and law enforcement entities.

In connection with one or more of the purposes outlined in the Sections above, we may disclose your personal data to:

MindPort subsidiaries and affiliated companies

We may share, disclose and transfer your Personal Data with future subsidiaries and affiliated companies for all purposes mentioned in Section 5 above.

Service providers

We may share your Personal Data to third parties (including our affiliates) to perform services complementary to our own, namely: hosting, data analytics, consulting, development, support, marketing and advertising, data and cyber security. Our service providers may perform the services on our behalf, under our instructions, in accordance with our agreement and in compliance with appropriate technical and organizational security measures to protect your personal data. A list of these providers is available upon request. See how to contact us below.

Other third parties

We may disclose your Personal Data to third parties, including government authorities or public authorities, courts, intergovernmental or supranational bodies for legal processes or protection of life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary, including:

• To comply with laws, regulations, legal process or to respond to lawful requests;

• To enforce or apply our agreements;

• To protect the rights, interests, property, or safety of Dust, our customers, you and others;

• In connection with claims, disputes, or litigation;

• To protect you and others from fraudulent, abusive, or unlawful use of the Website, and other fraudulent activity.

• Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
  
  

8. How do we transfer your Personal Data globally?

Your Personal Data may be accessed, processed and stored in other countries in which MindPort handles operations, including countries outside of the Canada.

MindPort has implemented safeguards to ensure an adequate level of data protection where your Personal Data is transferred to countries outside the Canada.

9. How do we secure your Personal Data?

We use industry-standard physical, procedural and electronic security measures to protect your Personal Data held with us and our service providers. However, please note that we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.

10. What are your privacy rights and how can you exercise them?

You have rights for the Personal Data we process about you. You can choose to object to our Processing of your Personal Data, restrict our use of your Personal Data, delete, change or correct your Personal Data, access your Personal Data by contacting us.

Subject to applicable data protection laws, you have privacy rights in respect of the Personal Data we process about you:

• request confirmation that we are processing your Personal Data;

• request a copy of Personal Data we hold about you;

• request that we update Personal Data we hold about you or correct such data that is inaccurate or incomplete;

• restrict the way in which we use your Personal Data (e.g., if we have no legal right to keep using it, if your Personal Data is inaccurate or unlawfully held);

• object to our Processing of your Personal Data relating on grounds to your particular situation or if your personal data is processed by us for direct marketing purposes, object at any time to the processing of your personal data for such marketing;

• withdraw the consent that you have given us to process your Personal Data where we process it on the basis of your consent;

• request that we delete the Personal Data we hold about you; and

• lodge a complaint with the relevant data protection authority regarding our Processing of your Personal Data.

To exercise one or more of the rights mentioned above, please contact us as outlined in Section 12 below. Please note that as part of your data subject request, we may require additional information and documents, including Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Sections 5 and 6 above.

11. Children’s Privacy

Our Website is not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using our Website, we will prohibit and attempt to block such use and will make reasonable efforts to promptly delete any Personal Data stored with us with regard to such person. If you believe that we might have any such data, please contact us as outlined in Section 12 below.

12. How to contact us?

You may contact us regarding this Website Privacy Policy or our Processing of your Personal Data us at info@mindport.ca

13. Updates and Amendments to this Privacy Policy

The “Effective Date” at the top of this webpage mentions when this Website Privacy Policy was last revised. We may update and amend this Website Privacy Policy from time to time. Any changes will become effective when we post a revised version of this Website Privacy Policy on this Website. Your use of our Website is subject to the terms in the version of this Website Privacy Policy that is posted on this Website at the time of your visit. We encourage you to review this Website Privacy Policy periodically to remain informed about our handling of your Personal Data.

14. External Links

We are not responsible for the privacy practices of other websites that our Website may contain links to. We encourage you to pay attention when you leave our Website for the website or application of a third party and to read the privacy policies of each and every website or service you visit.