Mirai Security Inc. Privacy Policy

Mirai Security Incorporated (“Mirai”) and its affiliates (“Mirai”, “we”, “us” or “our”) are committed to respecting and protecting the accuracy, confidentiality, and security of your personal information, and want you to feel secure when visiting our website (the “Website”) and using our services (the “Services”). This Privacy Policy sets out our policies concerning the collection, use, disclosure, and protection of personal information we receive from individuals using the Website.

“Personal information” means all information about an identified or identifiable individual. In some jurisdictions, the term “personal data” is used in local privacy laws rather than the term “personal information”. Mirai uses the terms “personal information” and “personal data” interchangeably.

Scope Of Privacy Policy

This Privacy Policy was drafted with the objective of complying with or exceeding the requirements of Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and British Columbia’s Personal Information Protection Act (“PIPA”), as Mirai’s corporate headquarters are located in Canada. However, Mirai also does business in other countries, and non-Canadians also use our Website. Many of these other countries have their own laws applicable to the protection of personal information, which may or may not conflict with or contain more restrictive legal obligations than PIPEDA and PIPA (including, for example, the European Union’s General Data Protection Regulation, known as “GDPR”). It is Mirai’s policy to comply with the privacy legislation within each of these countries. As such, this Privacy Policy outlines the minimum standards for Mirai’s treatment of personal information. Where applicable laws contain additional requirements, Mirai will ensure compliance with those laws. Should there be, in any specific case, an inconsistency between this Privacy Policy and applicable local privacy laws, this Privacy Policy will be interpreted in that case to give effect to and comply with the local privacy laws.

Mirai may update this Privacy Policy from time to time in response to changing legal, technical and business developments. We will take appropriate measures to notify you about material changes in a manner that is consistent with the significance of the changes we make. As well, a history of material changes will be noted at the end of this Privacy Policy, beginning with the original publish date of September 1, 2019. However, it is your responsibility to review the most current version.

Accountability

Mirai is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.

Please note that if you are a corporate customer or any other type of organization, you are responsible for the legal collection and use of personal information of individuals within your organization, in accordance with the principles set out in your privacy policy and the applicable laws in the countries in which you operate or in which you or your personnel use the Services. Mirai is not responsible for your privacy practices and policies.

Legal Basis And Purposes For Collecting Personal Information

Mirai’s legal basis for collecting and using personal information will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we need the personal data to perform a contract with you, or where the processing is in Mirai’s legitimate interests and not overridden by your privacy and data protection interests or fundamental rights and freedoms, or where Mirai has your consent to do so. In some cases, Mirai may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we collect and use your personal data in reliance on our legitimate interests (or those of any third party) other than as described in this Privacy Policy, we will make clear to you at the relevant time what those legitimate interests are.

Through the Services and the Website, Mirai collects, uses and discloses to certain third parties personal information for the following primary purposes:

• to develop, manage, deliver and support our Services to our customers;

• to contact our customers, either directly or through one of our resellers, to offer them the option to renew a services;

• to contact our customers directly about services that may be of interest;

• to ensure high standards of service to customers;

• to contact customers with service updates, upgrades and enhancements, as well as administrative or account-related information;

• to respond to inquiries and fulfill requests, such as sending requested materials or documents regarding Mirai’s services;

• to provide marketing and promotional communications (where this is in accordance with applicable law), and to determine the effectiveness of marketing and promotional campaigns;

• for our legitimate business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving or modifying our Services, and identifying usage trends;

• to verify a customer’s identity; and

• to comply with applicable laws, comply with legal and regulatory processes, enforce our terms and conditions, and protect our operations, rights, safety or property.

The paragraphs below provide further information about what types of personal information we collect and how we use and disclose it for the Website.

Website

Mirai Security Inc. uses Squarespace to host our website. By visiting our website, you are agreeing to the privacy policy Squarespace has set out and the data that they collect. Mirai Security uses Google Analytics. By visiting our website, you are agreeing to the privacy policy Google Analytics has set out and the data that they collect. Mirai Security uses Hubspot. By visiting our website, you are agreeing to the privacy policy Hubspot has set out and the data that they collect. Data, such as click patterns, time of day visited, network used, etc. are used for analytics and sales purposes to improve the user experience and contact people interested in using Mirai’s services.

Consent

As a general principle, Mirai will obtain your consent before collecting, processing, storing, using or disclosing your personal information for any purpose other than as identified in this Privacy Policy. Mirai will make an exception only where legal, medical or security reasons make it impossible or impractical to obtain consent, as discussed further below. We will make reasonable efforts to ensure you understand how your personal information may be used or disclosed. If Mirai plans to use previously-collected personal information for a new use that is incompatible with the original purpose, you will be informed of the new purpose, and we will obtain consent from you prior to this new use.

The form of consent can vary, depending on the sensitivity of the information and the circumstances. Consent may be express or implied depending on the nature of the personal information or the use, and depending on applicable local privacy laws. At times, consent for one use can fairly be implied to include consent for other included or related uses. When determining the appropriate form of consent, Mirai will be guided by what a reasonable person would consider fair and appropriate in the circumstances.

Your consent may be provided to Mirai orally, in writing or electronically, either personally or through an authorized individual. Consent can be implied (where not prohibited by applicable local privacy laws) when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.

Mirai may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law (including subpoenas, search warrants, court orders and government orders);

• In an emergency that threatens an individual’s life, health or personal security;

• When the personal information is available from a public source (e.g. a telephone directory or website);

• When we require legal advice from a lawyer;

• For the purposes of collecting a debt;

• In connection with criminal justice, taxation or regulatory activities;

• To protect ourselves from fraud or to protect the rights and property of Mirai;

• To investigate an anticipated breach of an agreement or a contravention of law; or

• In the event of a reorganization, merger or sale of Mirai.

Subject to certain exceptions (e.g. where the personal information is necessary to provide Services, or the withdrawal of consent would frustrate the performance of a legal obligation), you may withdraw or refuse to provide your consent to Mirai, or request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to info@miraisecurity.com.

Limited Collection

Mirai will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Mirai will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.

Mirai will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.

Limited Use, Disclosure And Retention

Mirai will use and disclose personal information only as described in this Privacy Policy, or for the purposes for which it was collected, or as agreed by you, or without your consent for the limited circumstances listed above in the section titled “Consent”. We will not use or disclose personal information for any additional purpose that is incompatible with the original purpose unless we obtain consent to do so. We will not sell your personal information to other parties.

Mirai may share personal information with our employees, contractors, consultants, affiliates, service providers, business partners and other parties who require such information to assist us with providing you with the Services.

The use, collection and disclosure of personal information may involve Mirai transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws.

Mirai will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for Mirai’s legitimate business purposes, or to comply with applicable legal, tax or regulatory requirements. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous.

Mirai may use and disclose aggregated and anonymous or de-identified information to third parties, including the general public. For example, we may analyze and publish reports on usage trends or statistics from across our global customer base for information or marketing purposes, but only after we have removed any personal information that would identify or be associated with any particular individual or customer. This type of aggregated and anonymous or de-identified data can help Mirai to improve our products, services and advertising, and it can be used by customers and the public to better understand trends in the industry. We will never sell this aggregated data.

Accuracy

Mirai will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Mirai does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Mirai therefore relies on you to keep your personal information accurate and current.

You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Mirai and must provide sufficient detail to identify the personal information and the correction being sought.

If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.

Safeguarding Personal Information

Mirai will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Mirai as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Mirai’s security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.

Mirai will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.

Mirai trains all staff who handle personal information on the importance of and procedure for maintaining confidentiality. All employees, contractors, consultants and service providers of Mirai who are provided access to personal information on behalf of Mirai are required to be familiar with and comply with the provisions of this Privacy Policy and applicable laws.

Mirai will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Mirai will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Mirai and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a Privacy Commissioner or similar regulatory body in any relevant jurisdiction.

Mirai will also continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Openness

This Privacy Policy is available to the public on our Website, so that information about our policies and practices relating to the management of information is readily available to everyone.

Use By Children

The Website and the Services are not intended for use by minors. Mirai does not knowingly collect information about minors and believes that minors should obtain their parents’ or legal guardians’ consent before providing any personal information. If you believe that we have mistakenly or unintentionally collected a minor’s personal information, please contact info@miraisecurity.com. By using the Website, you represent that you are over the age of majority.

Complaint Procedure

Mirai Security’s Data Privacy Officer is Sandy Buchanan.

Complaints, concerns or inquiries about Mirai’s privacy policies and practices, including compliance with this Privacy Policy, should be made in writing to:

Sandy Buchanan
C/O Mirai Security Inc.
757 West Hastings Street
Suite 142
Vancouver B.C., V6C1A1
Canada

E-mail: privacy@miraisecurity.com

Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws.

Mirai’s Privacy Policy was initially published effective September 1, 2019.

Policy last updated on: 2022-09-15