Effective Date: September 5, 2019
MVC Technologies Inc. ("MVC", "we", "us" or "our"), the owner and operator of MVC, the website www.tokein.com (the "Website"), and all of MVC's websites, mobile applications (including the Mobile Rewards app), channels, software and social media pages (collectively, the "Sites"), committed to maintaining and protecting the confidentiality and security of your personal information.
Further information with respect to our privacy practices is set out below.
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
We collect and maintain different types of personal information in respect of the individuals with whom we interact.
When you first access the Sites or register for the Sites, you will be asked to confirm that you are of the age of majority in your province, territory, state or location by providing your date of birth.
Also, when you register to use the Sites, we collect the following information from you:
We may also collect market-related information, which may include market trends and activities impacting our business. We may also collect information related to our media, public relations activities, and information related to our interactions with financial and other advisors.
We may collect information related to your usage of our Mobile Rewards app, including the device type, location access from, and action captured within the application We may collect and process information about your actual location using various technologies including IP address, GPS and other sensors. We use this information to monitor our Sites’ performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our Sites.
Finally, our Sites may contain links to other sites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these sites. MVC is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
Typically, MVC collects personal information from you. In other circumstances, MVC collects information from MVC in the matter described below. In addition, where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
We limit the collection, use, retention and disclosure of Information to that which is reasonably necessary for the purposes outlined herein. When personal information collected by MVC is to be used for a purpose not previously identified, the new purpose will be identified prior to use.
We may use your personal information:
We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
MVC may also use, store and disclose your Information in de-identified, aggregated form for its Clinical Decision Support tool ("CDS") and future data driven cannabis usage and efficacy tools. CDS is a program developed by MVC that uses de-identified, aggregated information about users to identify trends, preferences and tendencies of cannabis use for business and research purposes. The information used, stored and disclosed to CDS users is completely de-identified and aggregated, and MVC will not use the information in CDS to re-identify an individual for any purpose, unless required to do so by applicable law. To learn more about our de-identification process, you can contact us here: firstname.lastname@example.org
We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.
We use Merrco for all of our payment processing needs, and may share personal information about you with them to facilitate online payment for your monthly fees.
For example, we may share your personal information from time to time with our third party information technology, payment and data processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in Canada or the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.
Also, we may provide it to third parties associated with the Mobile Rewards app & Sites including dispensaries so that they may contact you directly, but only where you have provided consent for us to do so.
Finally, your personal information may be disclosed: as permitted or required by applicable law or regulatory requirements; to comply with valid legal processes such as search warrants, subpoenas or court orders; as part of MVC's regular reporting activities; to protect the rights and property of MVC; during emergency situations or where necessary to protect the safety of a person or group of persons; and with your consent.
The personal information collected about you is retained in confidence and MVC have adopted reasonable physical, electronic and managerial procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide. Notwithstanding these measures, no collection or transmission of information over the Internet or otherwise can be guaranteed to be 100% secure, and therefore the security of any such information cannot be warranted or guaranteed.
The personal information we collect will be retained in compliance with MVC's legal obligations, and only as long as necessary for the purposes for which it was collected.
The personal information we collect will be stored on the servers of our third party service provider, [name of service provider] which are located in multiple locations in North America. Within MVC, only staff members who require access to offer our services will have access to your Information. We require anyone who collects, uses or Information on our behalf to be aware of the importance of maintaining its confidentiality. This is done through the signing of confidentiality agreements, privacy training, and contractual means.
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, it is your responsibility to keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information held by MVC. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
Privacy Officer: Kash Qureshi, MVC Technologies Inc.
5045 Orbitor Dr, Building 11, Unit 300
Mississauga, Ontario, L4W 4Y4
MVC will receive and respond to complaints or inquiries about our policies and practices relating to the handling of Information, and will investigate all complaints. If a complaint is found to be justified, MVC will take appropriate measures to respond. We will inform individuals who make inquiries or lodge complaints of other available complaint procedures, including to the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario, as applicable.