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.

myMEMORY VAULT Co. (“MV”) recognizes the importance of privacy and the sensitivity of personal information. As a corporation, we are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.

Your Privacy Rights

From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act, 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?

User can input, upload, or store in the MV platform any text, images, and other data that you choose—MV refers to that information as “Content”. MV also collects the following 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, user’s billing address and other payment information. MV may also link subscriber’s information with data MV collects from its partners and other third parties to help understand user needs and provide user with a better experience.

Usage data. MV collects and logs Internet or other electronic network information on how user and others access and use MV platform, for example, the act of creating a memory. Usage data may be collected through cookies and similar technologies.

Location information. MV collects the IP address to connect to the MV platform.

In addition, MV collects the following types of personal data when user uses the MV platform:

TYPE OF INFORMATION

Username, email address, and contact preferences

• To create and support MV account.
• To communicate with user.
• In accordance with user’s communication preferences, to send information about MV features, products, and services that can enhance use of the MV platform.
• To verify email address to help prevent spam, fraud, and abuse.

Name, image, and other personal information

• To display in user profile

The geographic area from which user computing devices interact with the MV platform and preferred language

• To localize user interaction with the MV platform by, for example, displaying web pages or user interfaces in user’s preferred language, showing user website content or pricing information appropriate to user’s location, and improving features like search by allowing user to filter results by location.
• To assist MV in complying with legal restrictions that may limit the permissible use of the MV platform.
• To enhance user content with location information.
• To help user discover relevant content.

Device information

• To show user which devices have been authorized to access user’s account
• To inform our product development and marketing efforts, including our advertising efforts as described on our Cookie Information page.
• To provide account support.

Telephone number

• To help prevent spam, fraud, and abuse.
• To enable 2-Factor Authentication.
• In accordance with your communication preferences, to send you information about MV features, products, and services that can enhance your use of the MV platform.

Actions user performs when using the MV platform (e.g., creating a memory)

• To administer the MV platform and to improve the features and usability of the platform.
• To suggest MV features, products, and services that can enhance your use of the platform.
• To provide account support.

Whether user account was created or referred through a Referral Member or other partners who helps distribute or promote MV accounts

• To determine the amount of revenue share payments to make to partners with whom MV might have such arrangements and to provide aggregated and/or anonymized revenue share reports. These partners could include Referral Members or distribution partners.

Payment information (e.g. paid subscription account holders)

• To process payment.

Trusted Contacts

• To enable and verify “Trusted Contacts” who may access user’s vault.

Email address of Users

• To create and support the user’s MV account.
• To communicate with Users in accordance with communication preferences.
• To verify Users’ email addresses to help prevent spam, fraud, and abuse.

Billing information (e.g., postal address, email address, and telephone number)

• To communicate with the Billing Contact on the account and provide account support.

Name, company, email address, phone number, and other information user chooses to share

• To communicate with user, including to answer press or partnership inquiries.

How do we collect your personal 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 process.

How MV uses data provided by Users?

MV has specific rules for how and when MV uses the personal data it collects. MV uses the personal data it collects to:

Perform and personalize the MV services including to process transactions. MV platform analyzes data to power MV features and to continually improve its service. This may include, for example:

• Making sure users find what they’re looking for when searching
• Suggesting actions to be taken based on information
• Suggesting MV features or products that MV thinks will help to get the most out of the MV

Maintain and improve the MV services. To provide troubleshooting and customer support. MV Customer Support may need to access personal data, such as your account email address and information about the MV application. MV may also use personal data to improve MV services such as debugging to identify and repair errors that impair existing intended functionality, conducting research for technological development and demonstration, and analyzing information to maintain or enhance the quality or safety of the services.

Protect against security threats, abuse, and illegal activity. As part of MV’s efforts to protect user accounts and the functionality of the MV platform, MV’s systems may analyze the emails user sends to MV to detect spam, malware, or other potential security concerns.

Communicate with user. MV uses personal data to communicate with user in order to send important service messages such as administrative messages, technical notices, or security alerts. If MV learns of a security system breach, MV may attempt to notify user and provide information on protective steps, if available, through the email address, phone number, or other contact information that have been provided or by posting a notice on the MV website.

Comply with laws. MV uses information to satisfy applicable laws or regulations, and disclose information in response to legal process or enforceable government requests, including to law enforcement.

Market, promote, and maximize user engagement with the MV platform. In accordance with user communication preferences, MV may use personal data to send promotional communications that may be of specific interest to users, such as information about new products and features, tips for using the MV platform, special offers, and information about how MV works with products and services from our business partners. User may also log in to their account settings to change contact preferences. User will continue to receive essential MV Service-related and account-related information (such as notification that your paid subscription is about to expire).

Protect MV’s interests and rights. MV uses information where required by law or where MV believes it is necessary to establish, exercise, or defend its rights and those of its employees, or to carry out corporate transactions or operations. For example, in the event of a merger, sale, or reorganization of all or part of our business, personal data covered by this policy may be transferred in connection with that deal.

How and when does MV disclose user data?

Here are instances when MV may disclose user personal data — and then only the minimum information necessary:

• MV may disclose personal data with its service providers who process data on MV’s behalf, such as credit card processors and customer management systems. MV requires these providers to agree to strict data protection requirements in keeping with MV privacy policy standards and MV obligations under “applicable privacy MV does not share personal data, but may provide anonymized and aggregated data with any third parties for their own advertising purposes. For example, MV service providers help MV:

Operate, develop, and improve the features and functionality of the MV platform. Complete user payment transactions.

Fulfill sales and support requests.

Communicate with user as described elsewhere in this Privacy Policy.

• If you purchase a Paid MV plan from a Referral Member or MV Partner, MV may need to disclose limited personal data with the Referral Member to ensure accuracy in payment, account management, and delivery of services to

• In the event of a merger, sale, or reorganization of all or part of MV business, personal data covered by this policy may be transferred in connection with that

• MV may disclose personal data covered by this policy with any current or future MV subsidiaries and affiliated

• MV also may disclose personal data about user to third parties whenever user consents to or direct such This includes, for example, if user connects their MV account with a third-party app. In some cases, MV may partner with other companies to provide an integration. If you connect your MV account to these third-party services, user may be giving the partner access to some or all of user data, including, in some cases, your content. Providing such access is entirely voluntary, and you’ll receive notice and must agree to such access before it is granted. Please consider your selection of such applications and services, and your permissions, carefully. MV encourages you to review each party’s contract terms and privacy policy.

• When MV is required or authorized by law to do so, for example if we are ordered to do so by a competent court or tribunal

• When user has consented to the disclosure

• If MV engages a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by MV’s Privacy Policy

• If the information is Publicly Available Personal Information, as it is defined under the Personal Information Protection and Electronic Documents Act

How does MV respond to legal requests for user data?

MV diligently protects the privacy of user accounts. MV will not disclose personal data to law enforcement or other governmental authorities unless MV believes it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of Canada where MV has a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process.

MV narrowly interprets all information requests, and only discloses content in user’s MV account that is specifically responsive to a government warrant or where user has provided explicit consent.MV will notify user if MV believes it is compelled to comply with a third party’s legal demand for user information

In addition, in rare cases, MV may share personal data as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which MV operates the MV platform, or as otherwise necessary to comply with MV’s legal obligations.

Where does MV store user data?

When user uses MV platform software on their computing device, such as using one of MV’s downloadable applications, some of user data will be stored locally on that device.

When user sync their computing device with the MV platform, that data will be replicated on servers maintained in Canada and the United States. This means that if user stores information in the MV platform, user acknowledges that their personal data will be transmitted to, hosted, and accessed in Canada and the United States.

Data privacy laws or regulations in user’s home country may differ from, or be more protective than, those in Canada or the United States. MV will collect, store, and use personal data in accordance with this Privacy Policy and applicable privacy laws, wherever it is processed.

How long does MV store user data?

MV makes the content you store within your vault readily accessible to you, until you make the decision to delete it or cancel your MV account. If you delete your content, it will no longer be accessible to you or other “Trusted Contact(s)” you have assigned to your account. The MV back-up systems may retain residual copies of your deleted content for up to 12 months due to the nature of those systems’ operations. This retention is based on MV’s back up retention strategy consistent with industry standards.

As a general rule, MV deletes all accounts after 60 days for non-payment.

Consent

During the sign-up process, we shall ask you to specifically consent, if we collect, use, or disclose your personal information.

Updating Your Information

If any of your information changes during your lifetime of being a member of MV, please update your profile and information via your MV Dashboard.

Is My Personal Information Secure?

MV takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• securing our office space and physical premises against unauthorized entry and theft;
• restricting file access to personal information;
• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
• internal password and security

Can I be denied access to my Personal Information?

Your rights to access your personal information are not absolute. MV may deny access when:

• it is required or authorized by law (for example, when a record containing personal information about you is protected by solicitor-client privilege);
• to do so would reveal confidential information about others, and the personal information cannot be severed from the record;
• to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record; or
• the information was generated in the course of a formal dispute resolution process;

If we deny your request for access to, or refuse a request to correct information, we shall explain why.

Communicating with Us

You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information. MV does not guarantee the confidentiality of any email transmission.

Changes to this Privacy Policy

Since MV regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Website

Our website, mymvgateway.com, may contain links to other sites, which are not governed by this Privacy Policy.

Certain links on our website lead to documents or websites maintained by other persons and organizations. Inclusion of these links on this website does not signify MV’s endorsement of the form or content of any of those documents or websites, and MV makes no representation as to the security of those documents or websites, or the accuracy of the information contained in them.

On our website, like most other websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

REGION-SPECIFIC INFORMATION

 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.

The information on this page supplements the information found in MV Privacy Policy and may apply to user if user is a resident of one of the regions below.

California

Your California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act, as amended from time to time, including the California Privacy Rights Act and its implementation regulations (“CCPA”) (California Civil Code Section 1798.100 et seq.).

MV collects user information for the purposes described in this Privacy Policy, which include “business purposes” under the CCPA. MV provides the following additional disclosures related to the collection, use, and disclosure of personal information under the CCPA:

Categories of Personal Information Collected. In the preceding 12 months, MV has collected the categories of personal information listed below.

Identifiers. Identifiers such as user first name, last name, email address, IP address, unique device identifiers or other online identifier.

Personal information categories listed in the California Customer Records statute. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as user name or the commercial, professional, or education information described below.

Commercial information. Commercial information such as user payment method and related information if user purchases a subscription.

Network activity. Internet or other electronic network activity information, including connection information and information regarding user interaction with the platform such as the name of mobile operator or ISP, browser type and version, usage data, type and version of operating system, hardware version, device settings, software types, battery and signal strength, screen resolution, device manufacturer and model, language and time zone, mobile phone number and IP address.

Geolocation data. Geolocation data, including the IP address you use to connect to the platform and — if user chooses to share it — user location information from a mobile device.

Sensory information. Audio, electronic, visual, or similar information, such as photos that user uploads to their account or otherwise provide to MV, or when user consents to the recording of calls.

We do not sell or share (as defined under the CCPA) any of the categories of personal information we collect about user, and have not sold or shared such information in the preceding 12 months. We generally do not collect information that is considered sensitive personal information (as defined under the CCPA). In the limited circumstances that we do, such as the collection of your username and password, we do not collect this information for the purpose of inferring characteristics about user.

Business or Commercial Purpose for Collecting Information. MV collects personal information for the business and commercial purposes described in the section “How MV uses data?” of this Privacy Policy.

Categories of Sources of Personal Information. MV collects personal information directly from user when user interacts with the platform, automatically when user accesses or uses the platform or transact business with MV, and from other sources as in the section “What data does MV collect?” of this Privacy Policy.

Categories of Recipients with Whom We Disclose Information. MV may disclose personal information as described in the section “How does MV disclose user data?” of this Privacy Policy. In the preceding 12 months, MV has disclosed the categories of personal information for a business purpose or at user direction to MV’s parents, affiliates, subsidiaries, and service providers.

User Rights. Below is an explanation of rights for California consumers:

• Right to know. User can request to know the specific pieces of personal information MV collects about user.
• Right to correct. User can request that MV corrects certain inaccurate information.
• Right to delete. User can request that MV deletes personal information that MV collects from user (subject to certain exceptions).

California consumers may make rights requests by emailing user request to info@mymvgateway.com. In the subject line of email, please write “CCPA Rights Request.”

MV will not discriminate against you if user choose to exercise their rights under the CCPA.

Europe

Users residing in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland are afforded certain additional rights with respect to their personal data under applicable data protection laws.

User Rights. Subject to applicable data protection laws, the following rights may be available:

• Right to access. User can request MV to provide user with information on how MV collects, use, and store personal data, including providing user with a copy of personal data that MV stores.
• Right of rectification. User can request that MV corrects certain inaccurate personal data.
• Right of erasure. User can request that MV deletes user’s personal data.
• Right to data portability. User can export personal data from MV to a competing service. See MV’s Third Law of Data Protection for more information.
• Right to object. User can object to the processing of personal data in certain cases, as well as request that MV not use personal data for direct marketing purposes. Direct marketing includes emails which help MV keep user informed about the latest improvements to MV service.
• Right to restrict. User can restrict the processing of personal data in certain cases.
• Right to consent withdrawal. Where MV relies on user consent to process personal data, user has the right to withdraw user consent. If user does so, the processing carried out before withdrawal will remain valid, but thereafter MV no longer processes user’s data for that purpose.