Privacy Policy

MIJEM INC. PRIVACY POLICY

Mijem Inc. (“Mijem”, “Our”, “We” or “Us”) Mijem respects and values your privacy. We are committed to maintaining and protecting your Personal Information (as defined below) obtained by reason of your relationship with Mijem in accordance with Canada’s federal privacy law Personal Information Protection and Electronic Documents Act (PIPEDA), and provincial private sector legislation which has been declared “substantially similar” to PIPEDA, to the extent they apply to Mijem.

Mijem collects only such Personal Information as is required for the purposes of providing services to its users and collects, uses and discloses Personal Information only for those purposes as would be considered reasonable in the circumstances (including to protect from fraud and to comply with legal and governmental requirements). This Privacy Policy (the “Policy”) is designed to explain the types of Personal Information We collect, how it is used, and the steps We take to ensure your Personal Information is handled appropriately.

This Policy applies to Personal Information collected by Mijem in connection with Our operations and services, which includes Personal Information collected through Our website mijem.com and Our smartphone mobile application software Mijem (collectively, the “Site”), as well as the services offered by Mijem (the “Services”). This Policy is incorporated into and forms part of the Terms of Service for the Services.

By using the Site, the Services or otherwise providing Us with your Personal Information, you are accepting the practices described in this Policy, as they may be amended by Us from time to time, and agreeing to Our collection and use of your Personal Information in accordance with this Policy. If you do not agree to the collection, use and disclosure of your Personal Information in this way, please do not use the Site, Our Services or otherwise provide Mijem with your Personal Information.

The highlights below summarize what information We may collect from you, how We may use it, who We may share it with, what choices you have with regard to the collection, use or disclosure of your Personal Information, what We will do in case of a privacy or security breach involving Personal Information, and how to contact Us. A copy of the full Policy follows these highlights.

We may collect the following personal information from you:

When you create a user account: first and last name; username; email address; password; gender; and your location. (Users will be able to search for other users using first name, last name, email address, or username.)
When you complete in-app financial transactions: credit card number and expiration date, delivery date, currency type, billing address, shipping address, return address, and bank account information. We use two in-app third party payment processors, Stripe, Inc. https://stripe.com/privacy and Toshi Holdings Pte. Ltd. https://commerce.coinbase.com/legal/privacy-policy/, to enable you to complete financial transactions via the app. We will not collect, receive, store or otherwise have access to the banking or other financial information that you provide when using the payment processor.
When we process cryptocurrency refunds: email address, which we may share with our third party processors, CB Payments, Ltd and Coinbase UK, Ltd https://www.coinbase.com/legal/privacy.
When you redeem reward points: email address, which we may share with our third party processors, HandCash Labs S.L. https://handcash.io/legal/privacy or Fabriik Exchange, LLC and Fermatted Drives Limited https://www.moneybutton.com/privacypolicy.
When we send you marketing communications: email address, if you opt-in to receive marketing communications from us, We will keep you up to date on our products, services and promotions. (You may withdraw your consent to receiving marketing communications from Us at any time by following the unsubscribe instructions in each communication, or by contacting us at privacy@mijem.com.)
When you buy items: billing address, shipping address for the item, and/or meeting location for the item.
When you post items for selling or trading: picture, category, title, and delivery method of the item.
When you post items (or bulletins) you are looking for: title of the item, category, and the relevant community.
When you post events: title of the event, date of the event, and event location.
When you sell items: return address for the item.
When you use our ride share services: When you post a ride as a driver, the following information will be visible to potential passengers, including members of the public:

Departure and destination city/location
Pick up and drop off location
Departure date and time
Price
The average of any ratings you received from users of Mijem
Your username
Your profile picture (optional)
Vehicle type (optional)
Number of seats available (optional)

When you post about looking for a ride as a passenger, the following information will be visible to potential drivers and other passengers:

The fact that you are looking for a driver
Departure and destination city/location
Pick up and drop off location
Departure date and time
Price
The average of any ratings you received from users of Mijem
Your username
Your profile picture (optional)
Vehicle type (optional)
Number of seats needed (optional)
Other information about you or the ride that you may choose to provide

Information collected automatically when you use our website:
- Usage information, including the browser you are using, the URL that referred you to the Site, all of the areas within the Site that you visit, and the time of the visits; search terms you use on the Site; the links you select from within the Site to other areas of the Web or elsewhere online; Internet Protocol (“IP”) address or other unique identifier for your computer, cell phone, or other device used to access the Site.
- General IP information, including information that your browser automatically sends whenever visiting or using any of the Services, including your web request, the browser configuration of your Device (as defined below), the date and time of your request and the uniform resource locator of the referring and/or exiting websites.
- Information provided by or social media platforms or tools: if you interact with us through social media platforms or tools, we may have access to certain information about you, depending on your settings and preferences. (For example, when you link your Facebook account to the Site as a means for registering for the Site, some of your Facebook information will be shared unless you disable that sharing.)
- Cookies and other tracking technologies: The Site may include cookies and other tracking technologies, which may be set and controlled by Us or by Our third party service, advertising or content providers (including advertising services such as Google).
Optional information you may provide:
A picture in order to personalize your Mijem profile;
Your phone number in order to verify your Mijem profile;
A picture, category, price, and description for an event listing;
Location, price, and description for an item (or bulletin) you are looking for;
A description, price, condition, size, and gender of the item, in order to help Us analyze Our user base and improve Our services;
Your phone, email and social network contacts, and your social network login credentials, in order to help connect you with other Mijem users in your contacts and social networks. (However, this information will not be retained.)
Communications sent by you to Us, in order to process your inquiries, respond to your requests and improve the Services.

We may use the personal information we collect for the following purposes:

Providing Our Services;
Providing and maintaining the Site;
Setting up and maintaining a user account which allows you to access and use our Services;
Personalizing and verifying your User account;
Allowing you to complete in-app financial transactions;
Processing cryptocurrency refunds;
Providing you with marketing and promotional communications (if you opt-in to receive such communications);
Posting items for buying, selling, and trading;
Posting things you are looking for;
Posting events for users of Mijem to join;
Providing Our ride share services;
Analyzing Our user base and improving Our Services;
Connecting you with other users in your contacts and social networks;
Usage information is used for the purpose of research based on aggregated data, as well as for collecting payment from advertisers who place their advertising links on our app.

We may share your personal information with the following parties:

Authorized employees and agents of Mijem who require access to fulfill their job requirements, or on a “need to know” basis;
Our service providers and payment processors who perform business support and information system management;
Our consultants who provide business, financial and legal services;
Other Mijem users with respect to certain information, such as, for example, members using Our ride share services;
Third party advertising providers (You can opt out of Interest-based advertisement.)
Google Adsense, Analytics, Firebase (https://policies.google.com/privacy).
Other third parties with your consent, or as permitted or required by law.

You have the following choices:

Access to and correction of your personal information: You can access your personal information and ask us to update, correct or delete any information we have about you, subject to legal and contractual restrictions.
Marketing communications: If you agreed to receive marketing communications from us, you can unsubscribe from continuing to receive such communications by using the unsubscribe link at the bottom of an email you receive, or by sending an email to: privacy@mijem.com.
Disabling cookies and tracking technologies: You may disable cookies and other tracking technologies through the settings in your browser. However, doing so may affect your use of our website and the ability to access certain features of the website and/or receive our Services. However, disabling cookies and other tracking technologies will not prevent you from transacting with us.
Opt-outs: You may contact us to opt-out of being contacted by us, as well as to opt-out of certain uses of your personal information, as explained in our Privacy Policy.

In case of a breach of security safeguards involving personal information, we will:

Determine whether the breach creates a real risk of significant harm to the individual, including physical, financial or reputational harm;
Notify the affected individual, the Office of the Privacy Commissioner of Canada and any provincial Information and Privacy Commissioners, as appropriate, and any other organization or government institution that can reduce the risk or mitigate the harm from the breach; and
Keep a record of the breach in accordance with our legal obligations.

How to contact us

If you would like further information about your privacy rights, opting-out of the collection or use of your information, accessing or correcting your information, or to register a complaint, please contact Our Privacy Officer at privacy@mijem.com.

This Privacy Policy outlines in detail:

What personal information we may collect
How we may use personal information
How we may share personal information
How we protect your personal information
Your rights in relation to your personal information, including opt-out choices
How we use Cookies, Tracking Technologies and Analytics

What is Personal Information?

“Personal Information” is information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information. “Personal Information” may or may not include business contact information, depending on the jurisdiction. The types of Personal Information that Mijem collects are described below.

This Policy does not cover aggregated data from which the identity of an individual cannot be determined. Mijem reserves the right to use aggregated data in any way it determines appropriate.

COLLECTION AND USE OF PERSONAL INFORMATION

Mijem collects your Personal Information for the purpose of setting up and maintaining a user account which allows you to access and use Mijem’s Services. Our use of Personal Information is limited to the purposes described in this Policy. Mijem does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.

Creating a User Account: You will be required to provide the following Personal Information to create a user account on the Site:

first and last name;
username;
email address;
password;
gender; and
your location.

Users will be able to search for other users using first name, last name, email address, or username.

Financial Transactions: When you complete financial transactions to pay for our Services, we may collect the following payment and transaction information: credit card number and expiration date, delivery date, currency type, billing address, shipping address, return address, and bank account information. We will use two in-app third party payment processors, Stripe, Inc. and Toshi Holdings Pte. Ltd., to enable you to complete financial transactions via the app. We will not collect, receive, store or otherwise have access to the banking or other financial information that you provide when using the payment processor. Stripe, Inc. and Toshi Holdings Pte. Ltd. are wholly independent from Mijem. For more information on Stripe, Inc.’s privacy practices, please consult Stripe, Inc.’s privacy policy available here: https://stripe.com/privacy. For more information on Toshi Holdings Pte. Ltd.’s privacy practices, please consult Toshi Holdings Pte. Ltd.’s privacy policy available here: https://commerce.coinbase.com/legal/privacy-policy/.

Cryptocurrency Refunds: If applicable, to process cryptocurrency refunds, we may share your email address with our third party processors, CB Payments, Ltd, and Coinbase UK, Ltd. For more information on CB Payments, Ltd, and Coinbase UK, Ltd.’s privacy practices, please consult CB Payments, Ltd, and Coinbase UK, Ltd.’s privacy policy available here: https://www.coinbase.com/legal/privacy.

Reward Points Redemptions: If applicable, to connect to Mijem an external wallet you may have with Fabriik Exchange, LLC and Fermatted Drives Limited, we may share your email address with our third party processors, HandCash Labs S.L. or Fabriik Exchange, LLC and Fermatted Drives Limited.

For more information on HandCash Labs S.L. or Fabriik Exchange, LLC and Fermatted Drives Limited’s privacy practices, please consult HandCash Labs S.L.’s privacy policy: https://handcash.io/legal/privacy or Fabriik Exchange, LLC and Fermatted Drives Limited’s privacy policy: https://www.moneybutton.com/privacypolicy.

Transactional Notifications: We provide notifications for certain activities relating to your use of our Services despite your indicated e-mail preferences, for example we may send you notices of any updates to our Terms of Service or Privacy Policy and notices with regards to confirmed or potential financial transactions, even if you have opted not to receive general communications from us.

Marketing Communications: If you opt-in to receive marketing communications from us, we will keep you up to date on our products, services and promotions. You may withdraw your consent to receiving marketing communications from us at any time by following the unsubscribe instructions in each communication, or by contacting us at support@mijem.com.

Buying Items: You will be required to provide Us with the following additional information for the items you wish to purchase on the Site:

Billing address;
Shipping address for the item; and/or
Meeting location for the item;

Posting Items for Selling and Trading: You will be required to provide Us with the following information about the items you wish to post for the purpose of selling or trading on the Site:

Picture of the item;
Category of the item;
Title of the item; and
Delivery method of the item.

Posting Items You Are Looking for: You will be required to provide Us with the following information about the items you are looking for on the Site:

Title of the item;
Category of the item; and
Relevant community.

Posting Events: You will be required to provide Us with the following information about the events you wish to post on the Site:

Title of the event;
Date of the event; and
Event location.

Selling Items: You might be required to provide Us with the following additional information for the items you wish to sell on the Site:

Return address for the item

Ride Shares: When you post a ride as a driver, the following information will be visible to potential passengers, including members of the public:

Departure and destination city/location
Pick up and drop off location
Departure date and time
Price
The average of any ratings you received from users of Mijem
Your username
Your profile picture (optional)
Vehicle type (optional)
Number of seats available (optional)
Other information about you or the ride that you may choose to provide

When you post about looking for a ride as a passenger, the following information will be visible to potential drivers and other passengers:

The fact that you are looking for a driver
Departure and destination city/location
Pick up and drop off location
Departure date and time
Price
The average of any ratings you received from users of Mijem
Your username
Your profile picture (optional)
Vehicle type (optional)
Number of seats needed (optional)
Other information about you or the ride that you may choose to provide

Information Collected Automatically

We also collect certain types of information whenever you interact with Us through the Site, including, but not limited to, the following:

Information We Collect Automatically When You Access and Use the Site: In addition to any Personal Information or other information that you choose to submit or disclose to Us via the Site or the Services, We and Our third party service providers (including analytics providers) may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with the Site or one of Our advertisements or other content elsewhere online (“Usage Information“). Usage Information may include, among other information, the browser you are using, the URL that referred you to the Site, all of the areas within the Site that you visit, and the time of day. Our systems may also automatically gather information about the search terms you use on the Site and the links you select from within the Site to other areas of the Web or elsewhere online. In addition, We may collect your IP address or other unique identifier for your computer, cell phone, or other device used to access the Site (collectively referred to as a “Device Identifier“). A Device Identifier is a number that is automatically assigned to your computer, your cell phone, or other device used to access the Site, and Our computers identify your device by its Device Identifier. Usage Information may be non-identifying or may be associated with you. Whenever We associate Usage Information or a Device Identifier with you, as an individual and identifiable person, We will treat it as Personal Information.

IP Information: In general, We collect and use information and data regarding your access and use of the Site and the Services. When you use a web browser to visit the Site or use the Services, We record the information that your browser automatically sends whenever visiting or using any of the Services, including your web request, the Internet Protocol (“IP”) address and browser configuration of your Device (as defined below), the date and time of your request and the uniform resource locator of the referring and/or exiting websites. In this Privacy Policy, “Device” means a computer, mobile phone, handset, tablet or other device enabled for internet access and/or communication.

Social Media/Integration With Third party Platforms: The Site may permit you to interact with a third party website or service, such as enabling you to “like” Us on another website or “share” content from the Site with other websites (a “Social Networking Service“). If you choose to “like” or “share” content or to otherwise post information from or via the Site to a Social Networking Service, that information may be publicly displayed, and the third party may have access to certain information about you and your use of the Site. Similarly, if you interact with Us through a Social Networking Service, We may have access to information about you (for example, if you “like” or “follow” Our page on a third party website). Please note that if you mention or comment upon Mijem or the Site in your post to a third party platform, the third party platform may allow Us to publish your post on the Site.

You may also choose to use a social media tool offered by a third party, but available on the Site (such as posting a review or logging into the Site with your username and password for another website, such as Facebook or Google+). Use of such a feature may allow Us to collect (or the third party to share) information about you, including Personal Information. Information about you, including your name and profile photo, may be shown to other users of the Site if you are logged in through the Site or through a third party website or service or if you have previously posted content to the Site while logged in. When you choose to use a social media tool available through the Site, you may be opting to link your activity on the Site with that third party website or service, which may then collect information about your visits to the Site and may publish that activity as you request to your profile or similar feature with that third party. For example, when you link your Facebook account to the Site as a means for registering for the Site, some of your Facebook information will be shared unless you disable that sharing.

In addition, We may receive information about you if other users of a third party website give Us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third party website or interactive service.

Cookies and Similar Technologies: The Site may include the following tracking technologies, and similar technologies, and which may be set and controlled by Us or by our third party advertising provider Google:

Cookies: Mijem uses cookies, which are small data files that are saved to your Device when you visit the Site and use the Services. Mijem may use both “session” cookies and “persistent” cookies. A session cookie is only active while you are on the Site and is deleted once you close your browser. Unlike a session cookie, a persistent cookie is not deleted when you close your browser and will stay on your Device indefinitely. Mijem uses cookies to identify when you return to the Site, save login information (but never passwords), track usage statistics and store your preferences.

Disabling cookies: By default, most browsers will automatically accept cookies, but by altering your browser’s settings, you can either disable cookies completely or be prompted prior to a cookie being loaded. Consult each individual browser’s “help” feature for more information. While disabling cookies may lead to loss of functionality of the Site, it will not prevent Us from transacting with you.

Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links on which you click. The code is temporarily downloaded onto your computer, mobile device or other device from Our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

In addition, We may use a variety of other technologies on the Site that collect information for security purposes. Please note that it is not possible to opt-out of these technologies, which prevent hacking and malicious activity.

Analytics: Portions of the Site and Services may also use analytical tools (collectively, “Analytical Tools”) that are operated by Us and third party providers, which may use cookies, web beacons, scripts and similar means for the purpose of collecting information and analyzing how you use the Site and Our Services. Currently, we use Google Analytics & Firebase (https://policies.google.com/privacy). Information collected using Analytical Tools will be transmitted and stored on servers located outside of Ontario, specifically in the United States or any other country with which Mijem, its Affiliates or service providers maintain facilities, and may be accessible to law enforcement or other authorities in those foreign jurisdictions. The third party providers of Analytical Tools may also transfer this information to other third parties (such as governmental authorities) where they are required to do so by law, or where such third parties process the information on their behalf. Opt-out: As some Analytical Tools rely on cookies to perform their functions, you can avoid having your usage data collected by those Analytical Tools by disabling cookies in your browser.

Optional Information

You may wish to voluntarily provide Us with the following information:

A picture in order to personalize your Mijem profile;
A picture, category, price, and description for an event listing;
Location, price, and description for an item (or bulletin) you are looking for; and/or
Your phone number in order to verify your Mijem profile.

To help Us analyze Our user base and improve Our services, you may choose to provide Us with additional information, such as:

Description of the item;
Price of the item;
Condition of the item;
Size of the item; and/or
Gender of the item;

Your telephone, email and social network contacts: You may also choose to provide Us with the following information, which We will use to help you connect with other Mijem users in your contacts and social networks. However, this information will not be retained:

Your phone contacts;
Your email contacts;
Your social network contacts; and
Your social network login credentials.

Communications: When you send email or other communications to Us, We may retain those communications in order to process your inquiries, respond to your requests and improve the Services.

CONSENT

Consent to Collection, Use and Disclosure of Personal Information

Consent to collect, use and disclose personal Information may be “express”, or may be “implied”, for example, when you provide information necessary to use one of Our services. By accessing or using the Site you agree and consent that We may collect, use and disclose your Personal Information in accordance with this Policy. In addition, where appropriate, specific, express authorizations or consents may be obtained from time to time.

YOUR CHOICES

Withdrawing Consent to the Collection, Use and Disclosure of Personal Information

You are free to withdraw your consent to Our collection, use and disclosure of your Personal Information at any time, subject to contractual and legal restrictions and reasonable, advance notice. If you have given Us contact information and no longer wish to be contacted, contact Us by email and We will remove it from Our system. However, it should be noted that if you withdraw your consent to certain uses of your Personal Information, We may no longer be able to provide you with certain Services or you may not be able to take advantage of all of the features and functionality of the Services.

Managing Your Information Preferences

You can review, correct, update, change, and delete your Personal Information by changing the relevant settings in your user account.

Access your Personal Information

If you would like to access or correct Mijem’s file of your Personal Information, you may contact Customer Service at customerservice@mijem.com. Your right to access or correct your Personal Information is subject to applicable legal restrictions.

Disabling cookies

By default, most browsers will automatically accept cookies, but by altering your browser’s settings, you can either disable cookies completely or be prompted prior to a cookie being loaded. Consult each individual browser’s “help” feature for more information. While disabling cookies can lead to loss of functionality, it will not prevent Us from transacting with you.

Opt-out of the use of Analytical Tools

As some Analytical Tools rely on cookies to perform their functions, you can avoid having your usage data collected by those Analytical Tools by disabling cookies in your browser.

Opt-out of Interest-based Advertisement

Visit the Network Advertising Initiative’s online resources, and/or the resources of Digital Advertisement Alliance (DAA) to learn about how you may opt-out of certain interest-based advertising. Some of these opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete cookies, you may need to perform the opt-out task again.

DISCLOSURE OF PERSONAL INFORMATION

Who May Have Access to Your Personal Information?

Users will be able to search for other users using first name, last name, username, or email address.

Mijem does not disclose any of your Personal Information without your informed consent, unless We are required or permitted to by law (including in order to comply with a court order, federal or provincial regulations, or a legally permitted inquiry by a government agency) or as described in this Policy. Where obligated or permitted to disclose information without consent, Mijem will not disclose more information than required.

We maintain strict controls over access to the Personal Information you share with Mijem. Within Mijem, access to your Personal Information is granted only to authorized employees and agents of Mijem who require access to fulfill their job requirements, or on a “need to know” basis.

Your Personal Information may be shared in the following ways:

We may share Personal Information internally to improve Our services;
We may share your username,your item data, your shipping address for the item, and your return address for the item when you are interacting with users on our Site;
We may de-identify your Personal Information and share anonymized data with third parties;
We may combine your information with other information in a way that it no longer identifies you and share that aggregated information internally or externally with third parties for the purpose of enhancing the services We offer and your user experience;
We may access, preserve and share your information internally or with law enforcement officials in response to a legal request if We have a good reason to believe that the law requires Us to do so.

Except as set out in this Privacy Policy, Mijem does not sell, trade, or otherwise transfer to outside parties your Personal Information. We may transfer your Personal Information to trusted third party service providers who assist Us in administering and providing the Site or the Services. If your Personal Information is shared with third parties, those third parties will be bound by appropriate agreements with Mijem to secure and protect the confidentiality of your Personal Information.

Information, including Personal Information, which We collect from users of the Services and others, is considered to be a business asset. As a result, in the unlikely event that We go out of business, enter bankruptcy or if We are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third party acquirer in connection with the transaction.

You are deemed to consent to disclosure of your Personal Information for those purposes. If your Personal Information is shared with third parties, those third parties are bound by appropriate agreements with Mijem to secure and protect the confidentiality of your Personal Information.

We may disclose your Personal Information when We believe such disclosure is appropriate to comply with the law, enforce Our policies, or protect Our or others’ rights, property or for safety.

Permitted Disclosure Without Consent

We may disclose personal information to other third parties without your consent where required or permitted by law, where: (i) the information is public as permitted by law; (ii) it is necessary to proceed with or complete a “business transaction”, such as purchase and sale of an organization or assets, a merger or amalgamation, making of a loan, charge, lease or licensing, or other prescribed business activity; (iii) it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; (iv) it is necessary to comply with a law, regulation or order of a court, administrative agency, or government tribunal; or (v) it is necessary to identify an individual who is injured, ill or deceased, or due to an emergency that threatens the life, health or security of an individual.

PROTECTION OF PERSONAL INFORMATION

Physical, Electronic and Procedural Safeguards

Mijem recognizes the sensitivity of your Personal Information and protects it using appropriate physical, electronic or procedural security measures with respect to its offices and information storage facilities. This may include safeguards to protect against loss or theft, unauthorized access, disclosure, copying, use or modification. This also applies to Our disposal or destruction of Personal Information.

Only authorized employees, contractors and agents of Mijem, who require access to your Personal Information to fulfill their job requirements, will have access to your Personal Information. All Personal Information files and data are the sole property of Mijem.

In Case of a Privacy or Security Breach

A “breach of security safeguards” is defined as the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards. In case of a breach of security safeguards involving personal information under Our control, we will notify the affected individual and the Office of the Privacy Commissioner of Canada, as well as any provincial Information and Privacy Commissioner, as appropriate, if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to the individual, including physical, financial or reputational harm. We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach. We will keep a record of any breach of security safeguards in accordance with our obligations under the applicable privacy legislation.

Transfer or Storage Outside Canada

Information may be securely transferred or stored outside of Alberta, outside of Quebec, and outside of Canada, to the United States or to any other country in which Mijem, its Affiliates or service providers maintain facilities. Where information is transferred or stored outside Canada, it may be accessible to foreign law enforcement and other foreign authorities.

Accuracy and Retention of Personal Information

Mijem endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which We use that information. If We become aware that Personal Information is inaccurate, incomplete or out of date, We will revise the Personal Information.

We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time We retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with Us, but it will be only for so long as it is necessary for Us to have sufficient information to respond to any issues that may arise at a later date.

When your Personal Information is no longer required for Mijem’s purposes, We have procedures to destroy, delete, erase or convert it into an anonymous form.

PRINCIPLES

Mijem’s employees, agents and subcontractors with access to your Personal Information are expected to have basic knowledge and understanding of the general principles underlying PIPEDA and substantially similar provincial legislation:

Accountability

An organization is responsible for Personal Information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.

Identifying Purposes

The purposes for which Personal Information is collected shall be identified by the organization at or before the time the information is collected.

Consent

The knowledge and consent of an individual are required for the collection, use, or disclosure of Personal Information, except where appropriate.

Limiting Collection

The collection of Personal Information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Limiting Use, Disclosure and Retention

Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information shall be retained only as long as necessary for the fulfilment of those purposes.

Accuracy

Personal Information shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is used.

Safeguards

Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.

Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of Personal Information.

Individual Access

Upon request, an individual shall be informed of the existence, use, and disclose of his or her Personal Information, and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designate individuals accountable for the organization’s compliance.

INTERACTIONS WITH THIRD PARTIES AND OTHER WEBSITES

This Policy only addresses the use and disclosure of information collected from the use of the Site and Services. We make no representations or warranties about the privacy practices of any third party individual, website or service that you may encounter through the use of the Site and Services. As third party individuals, websites and services are wholly independent from Mijem, We are not responsible for the privacy practices of third parties or the content of any third party websites that may be linked by Mijem or other Mijem users. Therefore, user transactions with any third parties and access to any third party websites or services is entirely at your own risk. It is also your responsibility to take all protective measures to guard against viruses or other destructive devices and programs. You should refer to the privacy policies of third parties if you have any questions.

RESOLVING YOUR PRIVACY CONCERNS

In the event of questions about: (i) access to your Personal Information; (ii) Our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact Mijem by sending an e-mail to privacy@mijem.com.

Mijem will investigate all complaints and if a complaint is justified, We will take all reasonable steps to resolve the issue.

If We are unable to resolve your concerns to your satisfaction you may contact the Privacy Commissioner of Canada by writing to:

Office of the Privacy Commissioner of Canada

30, Victoria Street

Gatineau, Quebec

K1A 1H3

https://www.priv.gc.ca/en/contact-the-opc/

Privacy Policy Changes

This Policy may be revised from time to time. If We intend to use or disclose Personal Information for purposes not described in this Policy, We will make reasonable efforts to notify affected individuals in advance, if necessary. If you are concerned about how your Personal Information is used, you should contact Us as described above or check back at Our Site periodically to obtain a current copy of this Policy.

This version of this Privacy Policy is effective as of August 04, 2022.