Privacy Policy

Privacy Policy 

This Privacy Policy for Mindshift Project Inc. (doing business as Mindshift Peer Connect) ("we," "us," or "our"), describes how and why we might access, collect, store, use, disclose, and/or share ("process/processed/processing") your personal information when you use our services ("Services"), including when you: 

1. Visit our website at (URL TBD) or any website of ours that links to this Privacy Policy. 

2. Download and use our mobile application Mindshift Peer Connect, or any other application of ours that links to this Privacy Policy. The platform is designed to facilitate professional networking, referrals, peer consultation, and support among regulated professionals. It is not intended for the provision of healthcare services, medical advice, diagnosis, or treatment, and must not be used to collect, use, or disclose patient health information. 

3. Engage with us in other related ways, including any marketing or events. 

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed.  

If you do not agree with our policies and practices (including this Privacy Policy), please do not use our Services.  

If you still have any questions or concerns, please contact us at support@themindshiftproject.ca. 

Summary of Key Points 

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by browsing our table of contents below and then reviewing the corresponding section you are looking for. 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us. 

Do we process any sensitive personal information? We do not intentionally collect or request sensitive personal information (such as information about health, racial or ethnic origin, sexual orientation, or religious beliefs). Users are prohibited from submitting such information to us. However, if users choose to voluntarily provide sensitive personal information as part of user-generated content or otherwise, it may be processed by us. Users do so at their own risk. 

Do we collect any information from third parties? We do not intentionally collect any personal information from third parties except as provided in this Privacy Policy. Any payments made for our Services are handled by Google and Apple. All payment data is handled and stored by Google and Apple. We use RevenueCat to manage subscriptions, validate purchases, and synchronize subscription status across platforms. RevenueCat does not process or store payment information and does not handle funds. 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information. 

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information. 

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe. 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights. 

How do you exercise your rights? The easiest way to exercise your rights is by emailing us on support@themindshiftproject.ca. We will consider and act upon any request in accordance with applicable data protection laws. 

Want to learn more about what we do with any information we collect? Review the Privacy Policy in full. 

Table of Contents 

1. WHAT INFORMATION DO WE COLLECT? 

2. HOW DO WE PROCESS YOUR INFORMATION? 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 

6. HOW LONG DO WE KEEP YOUR INFORMATION? 

7. HOW DO WE KEEP YOUR INFORMATION SAFE? 

8. DO WE COLLECT INFORMATION FROM MINORS? 

9. WHAT ARE YOUR PRIVACY RIGHTS? 

10. CONTROLS FOR DO-NOT-TRACK FEATURES 

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

12. DO WE MAKE UPDATES TO THIS POLICY? 

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY? 

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 

1. WHAT INFORMATION DO WE COLLECT? 

Personal information you disclose to us. 

In Short: We collect personal information that you provide to us. 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: 

1. names 

2. email addresses 

3. job titles 

4. usernames 

5. passwords 

6. contact preferences 

7. contact or authentication data 

8. billing addresses 

9. college registration number or licensing details 

10. app-specific user id for purchases made through payment partners (such as Google Play or Apple in-app purchase) 

11. product or subscription type for purchases made through payment partners (such as Google Play or Apple in-app purchase) 

12. transaction ids for purchases made through payment partners (such as Google Play or Apple in-app purchase) 

13. purchase dates for purchases made through payment partners (such as Google Play or Apple in-app purchase) 

14. subscription status (active, expired, etc.) for purchases made through payment partners (such as Google Play or Apple in-app purchase) 

15. address (including city, country, latitude, longitude, user-selected location information) collected through google maps API integration 

16. encrypted password (hashed using bcrypt) 

17. profession 

18. governing professional body 

19. user profile information (profile image, biography/profile description) 

20. user content information (chat messages, uploaded images/documents/pdf files/audio files/video files) 

21. device and notification information (one signal player ids, device notification identifiers required for push notification delivery) 

Sensitive Information. We do not intentionally collect or request sensitive personal information (such as information relating to health, racial or ethnic origin, sexual orientation, religious beliefs, or other protected characteristics). We are not designed for the collection or processing of such information, and users are expressly prohibited from submitting sensitive personal information, including any patient or client information. 

However, we allow users to create profiles, communicate, or share content. If a user voluntarily includes sensitive personal information as part of such user-generated content, that information may be processed and stored by us. Users do so at their own risk and are responsible for ensuring that they do not share information that they are not authorized to disclose. 

We take reasonable steps to discourage the submission of sensitive personal information and to limit its use where identified, but we do not actively monitor all user content. 

Payment Data. All subscription and in-app payments are processed through Apple In-App Purchase (iOS) and Google Play Billing (Android), in accordance with their platform requirements. We use RevenueCat to manage subscriptions, validate purchases, and synchronize subscription status across platforms. RevenueCat does not process or store payment information and does not handle funds. 

We do not collect any payment data. All payment data is handled and stored by Google and Apple.  

You may find their privacy policy link(s) here: https://policies.google.com/privacy and https://www.apple.com/legal/privacy/.  

Application Data. We also may collect the following information if you choose to provide us with access or permission: 

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings. 

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's Bluetooth, calendar, storage, sms messages, sensors, reminders, microphone, contacts, camera, and other features. If you wish to change our access or permissions, you may do so in your device's settings. 

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed. 

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings. 

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

Information automatically collected 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services. 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. 

Like many applications, we automatically collect certain technical information when you use our Services. This information is collected to ensure the functionality, security, and performance of the application, and is not used for advertising or behavioral tracking purposes. 

The information we collect includes: 

1. Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this may include your IP address, device information, system activity, error reports, and details about how you use the application. 

2. Device Data. We may collect device information such as your computer, phone, tablet, or other device used to access the Services. This may include your IP address, device and application identifiers, operating system, hardware model, and system configuration information. 

We do not use cookies or similar tracking technologies for analytics, advertising, or behavioral tracking. 

Google API 

Our use of information received from Google APIs will adhere to the latest and most updated Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements. 

2. HOW DO WE PROCESS YOUR INFORMATION? 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent. 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including: 

1. To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. 

2. To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. 

3. To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. 

4. To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. 

5. To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. 

6. To enable user-to-user communications. We may process your information if you use any of our offerings that allow for communication with another user. 

7. To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. 

8. To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below. 

9. To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. 

10. To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience. 

11. To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. 

12. To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights. 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. 

If you are located in Canada, the below section applies to you. 

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. 

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: 

1. If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.  

2. For investigations and fraud detection and prevention. 

3. For business transactions provided certain conditions are met. 

4. For identifying injured, ill, or deceased persons and communicating with next of kin. 

5. If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse. 

6. If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province. 

7. If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced. 

8. If the collection is solely for journalistic, artistic, or literary purposes. 

9. If the information is publicly available and is specified by the regulations. 

10. We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments. 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties. 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. 

The categories of third parties we may share personal information with are as follows: 

• Cloud Computing Services 

• Data Storage Service Providers 

• Data Analytics Services 

• Communication & Collaboration Tools 

• Product Engineering & Design Tools 

• Performance Monitoring Tools 

• Payment Processors 

• Order Fulfillment Service Providers 

• Government Entities 

• Finance & Accounting Tools 

• Sales & Marketing Tools 

• Testing Tools 

• User Account Registration & Authentication Services 

• Website Hosting Service Providers 

• Subscription Management Platform Service Providers 

We also may need to share your personal information in the following situations: 

1. Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

2. When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: Address; City; Country; Latitude; Longitude; User Selected Location Information; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled "HOW DO WE PROCESS YOUR INFORMATION?" Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise.  

3. Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile. 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 

In Short: We do not use cookies or similar tracking technologies for analytics, advertising, or behavioral tracking. 

The mobile application does not use cookies, web beacons, pixels, advertising identifiers, or similar tracking technologies to track users for analytics or marketing purposes. 

We only process limited technical and functional information necessary to operate the Services, such as enabling core app features and maintaining security. 

The application may use third-party services (such as Google Places API) solely to support location-based functionality. These services do not involve the use of cookies within the app and are not used for advertising or user tracking purposes. 

If our use of tracking technologies changes in the future, we will update this Privacy Policy accordingly. 

6. HOW LONG DO WE KEEP YOUR INFORMATION? 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required or permitted by law. 

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy other than as permitted or required by law will require us keeping your personal information for longer than one (1) months past the termination of the user's account. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

7. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organizational and technical security measures. 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. 

8. DO WE COLLECT INFORMATION FROM 

MINORS? 

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction. 

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at support@themindshiftproject.ca. 

9. WHAT ARE YOUR PRIVACY RIGHTS? 

In Short: Depending on your state of residence in the US or in some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence. 

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. 

We will consider and act upon any request in accordance with applicable data protection laws. 

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows or permit for processing, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, Emailing "STOP" or "UNSUBSCRIBE", or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. You will then be removed from the marketing lists. 

However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. 

Account Information 

If you would at any time like to review or change the information in your account or terminate your account, you can: 

• Log in to your account settings and update your user account. 

• Contact us using the contact information provided. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements as permitted or required by applicable law.  

If you have questions or comments about your privacy rights, you may email us at support@themindshiftproject.ca. 

10. CONTROLS FOR DO-NOT-TRACK FEATURES 

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. At this time, there is no consistent industry standard for recognizing or responding to DNT signals, and we do not currently respond to them. 

We do not use cookies or similar tracking technologies for advertising or behavioral tracking purposes. 

Some jurisdictions (such as California) recognize browser-based signals like Global Privacy Control (“GPC”). Where required by applicable law, we will honor such signals. However, because we do not sell or share personal information for advertising purposes, such signals do not materially change how we process your information. 

11. DO UNITED STATES RESIDENTS HAVE 

SPECIFIC PRIVACY RIGHTS? 

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below. 

Categories of Personal Information We Collect 

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?" 

Category 

Examples 

Collected 

1. 
   Identifiers 

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name 

Yes 

2. 
   Personal information as defined in the California Customer Records statute 

Name, contact information, education, employment, employment history, and financial information 

Yes 

3. 
   Protected Classification characteristics under state or federal law 

Gender, age, date of birth, national origin, marital 

status, and other demographic data 

Yes 

4. 
   Commercial Information 

Transaction information, purchase history, financial details, and payment information 

Yes 

5. 
   Biometric Information 

Fingerprints and voiceprints  

No 

6. 
   Internet or other similar network activity 

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements 

Yes 

7. 
   Geolocation Data  

Device location 

Yes 

8. 
   Audio, electronic, sensory, or similar Information 

Images and audio, video or call recordings created in connection with our business activities 

No 

9. 
   Professional or Employment-related Information 

Professional affiliation details in order to provide you our Services, work history, and professional qualifications  

Yes 

10. 
    Education Information 

Regulatory college and licensing details 

Yes 

11. 
    Inferences drawn from collected Personal Information 

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics 

No 

12. 
    Sensitive Personal Information 

While we do not intentionally collect sensitive personal information, user generated content  may include sensitive personal information (such as health, racial origin, sexual orientation, or other protected categories) 

No 

(Sensitive Personal Information is not collected intentionally. We prohibit users from providing us with sensitive personal information.) 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: 

• Receiving help through our customer support channels; 

• Participation in customer surveys or contests; and 

• Facilitation in the delivery of our Services and to respond to your inquiries. 

We will use and retain the collected personal information as needed to provide the Services or for: 

• Category A - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category B - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category C - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category D - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category F - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category G - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category I - One month after the user's account is terminated unless permitted or required by applicable law. 

• Category J - One month after the user's account is terminated unless permitted or required by applicable law. 

Sources of Personal Information 

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?" 

How We Use and Share Personal Information 

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?" 

Will your information be shared with anyone else? 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. 

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: 

• Category A. Identifiers 

• Category B. Personal information as defined in the California 

• Customer Records law 

• Category C. Characteristics of protected classifications under state or federal law 

• Category D. Commercial information 

• Category F. Internet or other electronic network activity information 

• Category G. Geolocation data 

• Category I. Professional or employment-related information 

• Category J. Education information 

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" 

Your Rights 

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as required or permitted by applicable law. These rights include: 

1. Right to know whether or not we are processing your personal data 

2. Right to access your personal data 

3. Right to correct inaccuracies in your personal data 

4. Right to request the deletion of your personal data 

5. Right to obtain a copy of the personal data you previously shared with us 

6. Right to non-discrimination for exercising your rights 

7. Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling") 

Depending upon the state where you live, you may also have the following rights: 

1. Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota) 

2. Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland) 

3. Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon) 

4. Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut) 

5. Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota) 

6. Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California) 

7. Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida) 

How to Exercise Your Rights 

To exercise these rights, you can contact us by emailing us at support@themindshiftproject.ca, or by referring to the contact details at the bottom of this document. 

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. 

Request Verification 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. 

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf. 

Appeals 

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@themindshiftproject.ca. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general. 

12. DO WE MAKE UPDATES TO THIS POLICY? 

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws. 

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. 

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY? 

If you have questions or comments about this Privacy Policy, you may email us at support@themindshiftproject.ca or contact us by post at 163 MacFarlane Road, Ottawa, Ontario K2E 6V4, Canada. 

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://themindshiftproject.ca/contact-us.