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Privacy policy

September 29, 2022

MindBridge Analytics Inc. (“
we”/”us”) make the website, www.mindbridge.ai (the “Website”) and its proprietary anomaly detection software application (the “App”) available to companies who subscribe to use our services either through the Website or through an on-premises deployment. This Privacy Policy describes how we collect, store, use and distribute information about visitors and users of our Website and the App (collectively the “Services”). Terms used in this Privacy Policy have the same meaning as given to them in our Terms of Use.

This policy only applies to information that is provided to us by visitors of our Website or users of our Services. We act as the Data Controller of that information. To the extent that our Services are used to process any Personal Information (as defined below) on behalf of Subscribers in the European Union we act as a Data Processor, and the terms of our Data Processing Addendum applies in respect of our processing that personal information on behalf of the Data Controller.

Except as set forth in this Privacy Policy, Personal Information will not be used for any other purpose without the subject individual’s consent. We do not sell contact lists.

Our data protection contact may be contacted at:

Robin Grosset
robin@mindbridge.ai

Collection of Information: We aim to collect, use and disclose only such information as is required to enable us to manage your subscription and account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes and for service improvement (where we may use anonymized and aggregated data for machine learning and other analytical purposes). We will maintain the confidentiality of any Personal Information you provide to us on signing up for our Services or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Two types of information may be collected through the Website and our Services: Personal Information and non-personal information. This Privacy Policy does not extend to the collection, use or disclosure of non-personal information (as defined further below) which is currently not limited by applicable privacy laws.

“Personal Information” is personally identifiable information, such as name, address, e-mail address, credit card information, birth date and gender, or information associated with that information. In the event that you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website or App or be able to access and use the Website or App at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website or App. We may collect Personal Information in respect of the Website or App through registration processes; direct communications ; information

Although the use of certain non-personal information collected, used or disclosed through the Internet as described herein is not restricted (and to the extent that such is the case, the obligations under this Privacy Policy do not apply to such information), we provide information in this Privacy Policy about the collection of such information for the sake of transparency with respect to the operation of the Website. Such non-personal information is collected or derived by us in the course of operating this Website. For example, our web servers may automatically collect non-personal information that is provided through your browser or stored in a cookie when you choose to visit the Website.

Use of Information: We collect information for the following purposes:

  • Registration and access to the Services: In order to order our Services you must provide certain Personal Information to us such as your full name, address and email address. This allows us to know who you are, ensure that you can access your account for the Services, and provide both support and monitor security. Account registration information will not be shared with any other users of the Services.
  • Transactional Notifications: We may provide notifications for certain activities through the Website and the App such as product and service updates and alerts (if you are logged into the Application). Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Service or Privacy Policy.
  • Statistics: we collect statistics about use of the Services through the Website. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.
  • Cookies: Cookies are used by us to track content usage and traffic on the Website. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Website uses cookies to help it compile aggregate statistics about usage of this Website, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html If you. disable cookies, you may not be able to take advantage of all the features of the Website. We do not link any of the information we use in cookies to any personally identifiable information submitted by you when you are on the Website.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site. Functional cookies, persistent and session type, store information to enable core site functionality. Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.

In addition, we may collect your Personal Information through the following logs:
• Website System Logs: System logs of website activity may be collected by the web hosting provider. MindBridge may access these logs to identify and resolve security issues with the Website.
• Application System Logs: The App records events of user activity. These event records may include the user identifier and the users IP address. This information is used to monitor the security of the application, troubleshoot problems, and improve the App.

Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases for security and fraud prevention purposes.

Disclosures & Transfers outside the EEA:  

We use cloud-hosting service providers to provide hosting to us in different jurisdictions (including Canada, the USA, Europe and Australia), which may include hosting your personal information in those jurisdictions. This means that your personal information may be available to foreign government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your personal information. We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of your Personal Information (see further Security below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below).

On-premises deployments of our App result in your data being hosted and stored on your own servers. However, if your use of the App is through the Website, your data will be hosted and stored using our cloud-based servers and accordingly your data may be available to government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of that data.

From time to time we may employ third parties to help us improve the Website and/or the Services. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website and/or the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

Important Exceptions : We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security: The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your account information or password for the Services to third parties.

Retention: We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due legal constraints.

United Kingdom and European Economic Area (EEA) Residents.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances (as more fully described in the table below):

  • Where we need to perform the contract we are about to enter into or have entered intowith
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those
  • Where we need to comply with a legal or regulatory

We will use your personal data in the following circumstances, as more fully described in the table below):

PROCESS

DESCRIPTION OF DATA, PURPOSE OF PROCESSING AND USE

LAWFUL BASIS 

Client set up and support

Data collected: Key personnel name, address, contact details, position, correspondence details:

Purpose of processing and use: we use this data to set clients up on our systems,  and to liaise with clients about projects that we are undertaking with them and to provide on-going client support. 

When corresponding with us by phone, e-mail or otherwise, we ask you to disclose only as much information as is necessary to provide you with or to submit a question/suggestion/comment in relation to our website [or our services or products

MindBridge collects and processes this information on the basis of its contractual relationships with its clients.

Client Services

Data collected: Any personal details that might be contained within the data that a Subscriber might upload  to our Service in order for us to provide our Services to them. This may include (but is not limited to):

a)       Personal details (eg. Name)

b)      Contact details (eg. Email address, contact number, postal address)

c)       Financial details (eg. Salary, bank details, payroll details, and investments)

Purpose of processing and use: to provide the Services to our Subscribers

MindBridge collects and processes this information on the basis of its contractual relationships with its clients.

Sales and marketing

Data collected name, address, contact details, communication preferences.

Purpose of processing and use: we use this data to deliver information about our products and services and subscribe you to publications where you have subscribed to receive same; to send you invites to events etc.

MindBridge collects and processes this information on the basis of the implied or express consent that you give us when you provide this information to us

Website data

We collect data from cookies on our website. See our cookie policy for more information (https://www.mindbridge.ai/cookie-policy/). We use this data to administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes as part of our efforts to keep our website safe and secure.

 

MindBridge collects and processes this information on the basis of the implied or express consent that you give us when you provide this information to us

 

 

 

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details set out below.

 

If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy and, if necessary, obtaining your consent. See further the section of this Privacy Policy entitled ‘Amendment of this Policy’.

If you reside in the United Kingdom or EEA you may have the following additional rights under the GDPR or applicable regulation:

  • The right to access (i.e., the right to be provided with a copy of your personal information);
  • The right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
  • The right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
  • The right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
  • The right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
  • The right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, the right to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
  • The right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
  • The right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and/or
  • The right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).

We will not discriminate against you if you choose to exercise any of these rights.

 

California Residents. California consumers have the right to request any of the following information from us regarding personal information collected about you during the preceding 12 months:

 

  • The categories of personal information collected about you.
  • The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom we share personal information, if any.
  • The specific personal information collected about you.
  • For personal information sold or disclosed to a third party for a business purpose, you have a right to know the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and the categories of personal information that we disclosed about you for a business purpose.

We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your California residency), subject to delays and exclusions permitted by law.  Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.  

 

As a California resident, you have the right to request that we delete any personal information that we have collected about you.  We will honor this request subject to the range of exclusions permitted by law.  For example, we are not required to delete personal information if it is necessary to complete a transaction or reasonably used for an ongoing business relationship or if it is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.

 

As a California resident, you also have the right to opt out of the sale of your personal information to third parties. We do not sell your personal information.  However, we are permitted to share your personal information with a service provider.

 

We will not discriminate against you if you choose to exercise any of these rights.

 

If you wish to exercise any of the rights set out above, please contact using the details set out below.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You may lodge a complaint with your local supervisory authority with respect to our processing of your Personal Information. For a list of Supervisory Authorities in Europe, please see this list on the European Commission’s website:  https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Amendment of this Policy: We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the home page at www.mindbridge.ai. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website signifies your acceptance of any changes.

Access and Accuracy:

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Contact Us: You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions or if you find any errors in our information about you, please contact us at: legal@mindbridge.ai or at:

MindBridge Ai
730 St Laurent Blvd.
Suite 540, Ottawa, Ontario K1G 5L1
Canada