We comply with all of the requirements of Canada’s federal Personal Information Protection and Electronic Documents Act, other applicable substantially similar provincial legislation and, where applicable, the European Union General Data Protection Regulation (“GDPR”) 2018 (collectively “Data Protection Legislation”).
By submitting to us your Personal Information, or using Miravo’s website (the “Site”), you (“Data Subject”) accept this Policy and are deemed to explicitly consent to its terms and terms otherwise described to you at the time of collection of your Personal Information. You may withdraw this consent at any time, unless legal requirements prevent your withdrawal. If we are asking you to provide sensitive Personal Information, in addition to this Policy we will always tell you why and how this information will be used. If you do not agree with the terms of this Policy, please do not use the Site or otherwise provide your Personal Information to us.
This Policy may be amended at Miravo’s discretion, without notice to you. Please check back from time to time for such amendments. By continuing to access and use the Site, you agree to the terms of the then-current Policy, as amended.
What is Personal Information?
“Personal Information” is information about you, although most business contact information or information from a public directory listing of your name, address, or telephone number is not Personal Information. De-identified information, including demographic information and statistics, is not considered Personal Information.
Collection of Personal Information
Personal Information is collected by Miravo when you provide it to us, for example via the Site or when you call us. We may also collect your IP address when you use the Site and we keep track of your dealings with us, including details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, and other communication data.
We collect your Personal Information for the purposes of improving our business and its communications and answering the questions you pose to us and responding to comments you make to us, with respect to our products, investing in Miravo, employment opportunities and otherwise. We may also de-identify your Personal Information and use the resulting data for market research, business optimization and other purposes.
Use and Disclosure of Personal Information
We collect and use your Personal Information only for the purposes described above and other purposes disclosed to you at the time of collection or as permitted by law. We do not disclose your Personal Information, except as disclosed to you in this Policy, at the time of collection or as permitted by law.
If you indicate that you are interested in receiving offers or information from Miravo, your Personal Information will also be used to contact you or to send you materials about products, services and investment opportunities that might be of interest to you.
Processing of Personal Information
Your Personal Information may be processed and stored outside of the location in which it was collected by us or a third party service provider (“Location”), subject to local law. If your Personal Information is transferred outside of Canada, your Personal Information will be subject to the laws of the country in which it is stored. In certain circumstances, foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal Information without notice to you. Miravo will complete continual reviews of the countries with sufficient adequacy decisions, and provisions for binding corporate rules, standard data protection clauses or approved codes of conduct. Miravo will further perform due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information.
Miravo undertakes that it shall not transfer Personal Information outside of the Location unless the following conditions are fulfilled:
- The Data Subject has enforceable rights and effective legal remedies;
- Miravo shall comply with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Information that is transferred;
- Miravo complies with any reasonable instructions notified to it in advance with respect to the processing of the Personal Information; and
- Upon written direction shall delete or return, where applicable, Personal Information (and any copies of it) unless Miravo is required by law to retain the Personal Information.
Our legal basis for processing your processing your Personal Information, is based upon your consent to do so, performance of a contract where you are a party, legal obligations we are required to meet, and the Data Protection Legislation provisions.
We implement reasonable security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We use physical, organizational, and technological measures to protect Personal Information.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected or as required by the Data Protection Legislation.
Information transmitted on the internet, especially by electronic mail, is never 100% secure. As a result, you should take special care in deciding what information you send to Miravo by electronic mail.
The Site may also use Web beacon, gif, or other technologies. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
Your Rights as a Data Subject
At any point while we are in possession of or processing your personal data, you, the Data Subject, have the following rights, where applicable:
- Right of access – you have the right to request a copy of the information that we hold about you. In order to access your Personal Information, you must put your request in writing to our Privacy Officer, referred to below. Please allow up to thirty (30) days for a response;
- Right of rectification – you may have a right to correct data that we hold about you that is inaccurate or incomplete;
- Right to be forgotten – in certain circumstances you may ask for the data we hold about you to be erased from our records;
- Right to restriction of processing – where certain conditions apply you may have a right to restrict the processing;
- Right of portability – you may have the right to have the data we hold about you transferred to another organisation;
- Right to object – you may have the right to object to certain types of processing such as direct marketing;
- Right to object to automated processing, including profiling – you may also have the right to object to the legal effects of automated processing or profiling; and
- Right to review, in the event that Miravo refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
Third Party Websites
Please be aware that the Site may, from time to time, contain links to other third party websites and Miravo does not represent and cannot guarantee that those websites have privacy policies similar to this Policy. Miravo disclaims all liability in relation to such third parties.
6733 Mississauga Road, Unit 800
Canada L5N 6J5
DOC Dublin Airport
Swords, Co Dublin, Ireland
Date: December 15, 2020