Privacy Policy – My Memory Vault Co

Language Governance: If this Policy is translated into any language other than English, in the event of a conflict, the English language version shall govern to the fullest extent permitted by applicable laws.

Your Privacy Rights

From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. The Act gives you rights concerning the privacy of your personal information.

MV is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this Privacy Policy, and trained our staff about our policies and practices.

What is Personal Information?

Personal information is any information that identifies you, or by which your identity could be deduced.

What Data Does MV Collect?

Users can input, upload, or store in the MV platform any text, images, and other data that they choose—MV refers to that information as "Content".

MV also collects the following general types of personal data:

Basic subscriber information: To open an MV account and process payments, MV collects personal data like email address and, depending on how you purchase a subscription to a paid plan, billing address and other payment information. MV may also link subscriber’s information with data collected from partners and third parties to understand user needs.
Usage data: MV collects and logs Internet or other electronic network information on how users access and use the platform (e.g., the act of creating a memory), including via cookies and similar technologies.
Location information: MV collects IP addresses used to connect to the MV platform.

Categories of Personal Data & Purpose Matrix

Type of Information	Purpose of Collection & Use
Username, email address, and contact preferences	To create and support your MV account. To communicate with user. In accordance with communication preferences, to send information about features, products, and services. To verify email addresses to help prevent spam, fraud, and abuse.
Name, image, and other personal information	To display in user profile.
Geographic interaction area & preferred language	To localize user interaction (displaying interfaces in preferred language, appropriate pricing, local search filtering). To assist MV in complying with jurisdiction-specific legal restrictions. To enhance user content and discovery with location details.
Device information	To show authorized devices connected to user accounts. To inform product development and marketing/cookie analytics. To provide direct account support.
Telephone number	To help prevent spam, fraud, and abuse. To enable 2-Factor Authentication (2FA). To send feature updates and service notices per preferences.
Actions performed on the platform (e.g., creating a memory)	To administer and improve platform usability. To suggest enhancing features and provide account troubleshooting.
Referral & partner tracking	To determine revenue share payments to distribution/referral partners and generate anonymized partner reports.
Payment information	To process paid subscription billing transactions.
Trusted Contacts	To enable and verify designated "Trusted Contacts" authorized to access user vaults.
Billing information (postal address, phone, contact email)	To communicate with the designated account Billing Contact and process support.
Inquiry submissions (name, company, email, phone, notes)	To answer partnership, enterprise, and press inquiries.

How Do We Collect Your Information?

We collect information only by lawful and fair means, and not in an unreasonably intrusive way. We collect your personal information directly from you during the sign-up and onboarding process.

How MV Uses Data Provided by Users

MV maintains specific rules governing personal data usage:

Perform and personalize MV services: Powering search, suggesting actions, and providing personalized memory tools.
Maintain and improve services: Diagnostic debugging, resolving software impairments, and customer support troubleshooting.
Protect against security threats, abuse, and illegal activity: Automated scanning of incoming communications to detect spam, malware, and platform vulnerabilities.
Communicate with users: Sending technical bulletins, administrative receipts, expiration alerts, and critical security breach notifications.
Comply with laws: Fulfilling statutory obligations, legal court demands, and enforceable regulatory mandates.
Promote user engagement: Delivering optional promotional updates in alignment with your configurable contact preferences.
Protect MV’s rights and corporate transactions: Enforcing contractual agreements, defending against legal claims, or facilitating corporate mergers, sales, and reorganizations.

How and When Does MV Disclose User Data?

MV discloses personal data strictly when necessary, adhering to the principle of minimal data disclosure:

1. Service Providers & Vendors

We work with authorized processors (including credit card gateways, cloud back-up vendors, and customer service management systems) bound by rigorous data protection standards aligned with our privacy policies. We do not sell personal data, nor do we disclose personal data to third parties for their independent advertising purposes.

2. Referral Partners & Corporate Affiliates

If you purchase a subscription via a partner or referral member, necessary transactional confirmation data is shared for accounting reconciliation. In addition, data may be transferred during corporate restructurings, mergers, or to current/future MV subsidiaries under strict confidentiality.

3. User-Directed & Integrated Apps

Whenever you choose to connect your MV Vault with third-party applications or participating organizations (such as the Digital Trust Platform ecosystem), your explicit consent is required before any permitted fields are transmitted.

4. Legal Compulsion & Public Information

Data may be disclosed if formally ordered by a competent court or tribunal, where permitted under PIPEDA regulations for publicly available records, or with your affirmative permission.

How Does MV Respond to Legal Requests for User Data?

MV will not disclose personal data to law enforcement or governmental authorities unless we believe in good faith that compliance is legally mandated by valid warrants, court orders, or subpoenas. This includes valid international requests consistent with internationally recognized standards of due process.

MV interprets all requests narrowly, releasing only information explicitly specified in the legal instrument, and will notify the account holder unless legally prohibited from doing so.

Data Storage, Hosting & Retention

Geographic Hosting

Local applications cache data on your device. When synced, information is securely replicated on servers maintained in Canada and the United States. By storing information with MV, you acknowledge that your personal data will be processed and accessed across these jurisdictions.

Retention Schedule

Vault content remains accessible until you delete it or close your account. Residual encrypted backup copies may persist in system disaster-recovery backups for up to 12 months before automated purge.

Non-payment account deletion: As a general operating policy, inactive accounts with lapsed subscriptions are purged after 60 days of non-payment.

Updating Profile Information

You can update, edit, and correct profile details at any time by logging into your active MV Dashboard.

Is My Personal Information Secure?

MV deploys comprehensive administrative, physical, and technical safeguards:

Securing physical office premises against unauthorized entry.
Restricting digital file access strictly to authorized support personnel with role-based access.
Deploying enterprise-grade firewalls, SSL/TLS transmission encryption, and intrusion-prevention systems.
Mandating two-factor authentication (2FA) and complex password rules.

Note on Email Transmissions: Standard unencrypted email is not a 100% secure medium. MV cannot guarantee the confidentiality of sensitive personal data sent via standard email communications.

Access Denial Exceptions

While users maintain rights to access records, access may be restricted when required by law (e.g., solicitor-client privilege), where disclosure would reveal confidential information of others that cannot be severed, where it threatens individual safety, or where information was generated in formal dispute proceedings. If access is refused, a formal explanation will be provided.

Region-Specific: California Residents (CCPA / CPRA)

Under the California Consumer Privacy Act, as amended by the CPRA (Cal. Civ. Code § 1798.100 et seq.), California residents hold specific rights:

Right to Know: Request disclosure of the specific categories and pieces of personal information collected, commercial collection purposes, and recipient categories.
Right to Correct: Request correction of inaccurate personal data held by MV.
Right to Delete: Request permanent erasure of personal information, subject to statutory retention exceptions.
No Sale or Sharing: MV does not sell or share consumer personal data for cross-context behavioral advertising and has not done so in the preceding 12 months.

To submit a request, email info@mymvgateway.com with the subject line "CCPA Rights Request". MV will never discriminate against users exercising these statutory rights.

Region-Specific: European Economic Area (EEA), UK & Switzerland

Users in the EEA, UK, or Switzerland hold statutory protections under the General Data Protection Regulation (GDPR) and UK GDPR:

Right of Access & Portability: Obtain confirmation of processing, copies of records, and export data in a structured, commonly used, machine-readable format.
Right of Rectification & Erasure: Rectify inaccuracies or enforce your "Right to be Forgotten".
Right to Object & Restrict: Object to processing based on legitimate interests, restrict processing, or halt direct promotional outreach.
Right to Withdraw Consent: Revoke consent at any time without affecting previous lawful processing.

To exercise your European rights, contact our Data Protection representative at info@mymvgateway.com.

Identity Verification (IDV) & Proof of Life (PoL) Privacy Addendum

Effective Date: January 01, 2026 • Powered by Plaid Inc.

This section governs personal data processing specifically when you engage in our Identity Verification and Proof of Life services.

1. IDV & Biometric Data Collected

Personal Identification Details: Full legal name, date of birth, residential address, contact details, and government-issued credential metadata (driver's licence, passport, national ID).
Biometric Information: High-resolution selfie captures or video streams, facial geometry vector biometrics comparing your selfie to your ID credential, and gesture/motion validation to confirm live physical presence.
Technical Diagnostics: Geolocation, IP connection signals, device fingerprinting, and tamper-detection telemetry.

Strict Biometric Mandate: Biometric processing is executed strictly on a voluntary, consent-first basis solely to establish identity and live presence. Biometrics are never used for marketing, commercial profiling, or surveillance.

2. Purpose & Result Disclosures

Verification records and validation flags (match confirmed, failure, liveness verified) are transmitted strictly to the Participating Organization that requested the check, accessible solely by authorized review personnel under agreed compliance procedures.

3. Plaid Inc. Partnership & Protective Safeguards

Technical checks are powered in coordination with Plaid Inc. All verification infrastructure incorporates end-to-end encryption in transit (TLS 1.3) and at rest (AES-256), secure isolated biometric processing zones, and automated data purging schedules aligned with requesting client contracts.

Contact & Data Inquiries

For questions, data access demands, or formal inquiries regarding this Privacy Policy or verification operations, contact:

myMemory Vault Co. Inc.
Corporate Inquiries: info@mymvgateway.com
Support & Data Requests: support@mymvgateway.com
Website: mymvgateway.com
Toronto, Ontario, Canada