Introduction
Miinga Inc. (“We”, “Our”, “Us”) is a Canadian company located in Iqaluit, Nunavut dedicated to providing mental health and emergency resources for individuals in remote northern communities. Because We respect the right to privacy, We have developed this Privacy Policy (“Privacy Policy”) to inform users (“You”, “Your”) about Our privacy practices regarding the data collected in relation to the use of Our mobile Miinga application (the “Application”). The Application does not collect information that can be used to directly or indirectly distinguish, identify, or contact a specific individual (“Personal Information”).
Scope of This Privacy Policy
In keeping with Our commitment to Your privacy, this Privacy Policy will apply to:
- The type of information We collect, use, and disclose;
- How the information We gather is used and to whom it is disclosed;
- Your ability to opt-out of future notifications and withdraw consent; and
- Security procedures We have put in place to protect your information from loss, misuse, or alteration.
Our Commitment to Privacy
We recognize the importance of privacy and are committed to protecting the privacy of all of those who use Our Application. This Privacy Policy sets out Our practices regarding the collection, use, and disclosure of Personal Information in connection with the Application.
Application
This Privacy Policy applies to all information We collect for the purpose of providing access to and use of the Application. We may require the involvement of trusted third parties required to facilitate the provision of the Application. We strive to provide the highest level of privacy possible, and therefore require that any third parties offer no less protection than that offered in this Privacy Policy and as otherwise required by law to meet the data protection requirements of Canada’s federal Personal Information Protection and Electronic Documents Act (PIPEDA).
Information We Collect from You
5.1 How We Collect Information from You
We collect information from You when You interact with the Application through:
- Access and Use of the Application: To access or use the Application, You may be required to provide certain information.
- Communicating with Us. You may voluntarily disclose information to Us via direct email or the feedback feature within the Application.
5.2 Personal Information
We may collect Personal Information from You that You voluntarily submit to Us, including information that You provide when engaging with the Application. We do not collect any Personal Information from a user unless they explicitly and intentionally consent to provide it. Under no circumstances do We collect any sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation. If You are simply using the features of the Application, We do not gather any Personal Information about You.
Personal Information that is not voluntarily submitted is not collected as outlined in this Privacy Policy.
5.3 Collection of Aggregate Data
We may aggregate data related to the use of the Application (“Aggregate Data”). We may use Aggregate Data to improve the Application or provide other products and services, create derivative or new products, develop analytics, or for other research purposes.
Purposes for Which We Collect and Use Your Information
6.1 Application optimization and improvement:
To improve the Application and provide users with the best possible experience, We may collect and analyze certain data related to the performance and use of the Application. Such data relates only to the use of the Application and is not associated with any Personal Information or information specific to a particular user. We use this data only for Our legitimate business purposes and improving the Application.
Consent to the Collection of Personal Information
As described throughout this policy we do not collect or use your personal information within the functionality of the application. However, your personal information may be captured in circumstances where you seek information from us or provide feedback (see 7.1 below). In these circumstances we use Your Personal Information only with Your meaningful legal and voluntary consent, or as required by law. Your consent provided for the use of Personal Information is for the specified, explicit, and legitimate purposes as outlined in this Privacy Policy, and/or as otherwise specified prior to You providing express consent. You may withdraw Your consent to the use of Your Personal Information by contacting Our Privacy Officer at info@miinga.ca. When We collect information from You, You will be given the opportunity to opt-out of receiving further information from Us. We will explain the consequences if You decide to withdraw Your consent for Us to use Your Personal Information. Any request to withdraw consent will be processed within the legally required time periods.
You may explicitly and intentionally provide Us with, and consent to, Our collection of certain information, including Personal Information by:
7.1 Email Request for Information:
We use links integrated within the Application to provide You with the opportunity to contact Us via email or the feedback feature in the Application to ask questions, request information and materials, or provide comments and suggestions. If You chose to email Us, We may request additional Personal Information from You, such as Your name, email address, and/or telephone number, to help Us satisfy your request. When Your request is concluded We do not retain your Personal Information.
By corresponding with Us, downloading, accessing, or otherwise using the Application, You consent to our collection, use, and disclosure of Your Personal Information in accordance with the terms of this Privacy Policy.
New Consent Required
Before We collect, use, or disclose Your Personal Information for a new purpose, We will disclose the new purpose and request Your consent.
Withdrawal of Consent or No Consent Provided
You can withdraw Your consent to the use, and disclosure of Your information, including Personal Information at any time by contacting Us and informing Our Privacy Officer at info@miinga.ca.
Disclosure without Consent
We will only disclose Your Personal Information to third parties, government authorities, or law enforcement to the extent that We are permitted or required to do so by law.
Accuracy of Collected Information
We implement policies and procedures to ensure that the Personal Information in Our possession is accurate, complete, and up to date. You can submit updates to Your Personal Information to Our Privacy Officer at any time.
Access to Personal Information
An individual may request access to the Personal Information that We hold about themselves at any time. We will respond to requests for access promptly and within the legally mandated time frame subject to any refusals permitted or required by law. Any refusals to grant access will be accompanied by associated reasons and information regarding available recourse. Requests for access to Personal Information can be directed to info@miinga.ca.
Retention of Personal Information
We retain Personal Information only for as long as needed to perform the purposes identified in this Privacy Policy. Once Personal Information is no longer required for the purpose for which it was collected, We will apply all commercially reasonable safeguards to safely and securely destroy said Personal Information.
Statistical Information About Your Use
When You use the Application, We may automatically collect statistical data about Your use. This information does not identify You personally, but rather provides Us with information about Your usage for Our legitimate business purposes. We may monitor statistics such as how many people use the Application, which resources are most frequently used, which locations receive the greatest interactions, and device information. We use these statistics about Your use only to help Us improve the performance of the Application.
Linked Third Party Websites and Resources
The Application contains links to third party websites and resources for information purposes only. We are not responsible for the privacy practices, privacy statements, acceptable use policies, or any other content regarding these other websites. We strongly recommend that You read the privacy policies and terms and conditions of use of any third party to understand how they collect, use, and disclose information.
Security Procedures and Safeguards
We consider the protection of all Personal Information We receive from You to be critical to Our corporate mission. Please be assured that We have security measures in place to protect against the loss, misuse, and alteration of any information We receive from You in accordance with applicable law.
16.1 Procedural Safeguards:
We maintain physical, technological, electrical, and procedural safeguards in connection with the collection, disclosure, storage, use, and deletion of Personal Information. Proof of Your identity may be required upon request to disclose Personal Information in Our possession to You.
16.2 Technological Safeguards:
As with any transmission over the Internet, there is always some element of risk involved in sending Personal Information. To try and minimize this risk, We encrypt all information that You submit in relation to Our Application.
16.3 Personnel Safeguards:
Our employees who have access to Personal Information receive privacy training and are required to respect the confidentiality of such information pursuant to their employment agreement with Us. Restrictions on access to Personal Information at the personnel level include restricted access to physical locations in which Personal Information is held, as well as technological protections (e.g., passwords). Disclosure and access to Personal information by personnel is limited to the extent required to reasonably fulfill the specific purposes for which it was provided.
Notification of a Security Breach
In the event that a security breach of the above-mentioned safeguards involving Personal Information in Our control presents a real risk of significant harm, a notice of the breach will be provided without undue delay to the affected individual(s).
Changes to this Privacy Policy
We may revise or update this Privacy Policy from time-to-time. If a material change is made to this Privacy Policy and/or the way We use Your Personal Information or other data, We will post prominent notice of the nature of such changes on the first page of this policy. You may be required to read and acknowledge Your consent to any such changes in this Privacy Policy. A copy of this Privacy Policy will be available within the Application.
Inquiries Regarding This Privacy Policy
Questions, complaints, or requests for further information regarding this Privacy Policy or Our practices related to the collection, use and disclosure of Personal Information should be directed to info@miinga.ca. Please specify "Privacy Policy" in the subject line of Your email. All complaints We receive related to Personal Information are investigated.
This Privacy Policy was last modified on February 28th, 2024.