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Privacy Policy

Overview

As a company offering a digital service online that collects personal information from people, we are obligated to post and maintain a privacy policy that outlines:

  • The information we collect
  • What we do with the information
  • How we store the information
  • How someone can get their information removed from our services
  • Who we share the information with and why
  • Who they can contact for more information
  • Most importantly, how we handle information from minors under the age of 13

Our Commitment to Privacy

Personal information is any information you provide to us that personally identifies you, like your name or email address, or other information which could be reasonably linked to such identifying information by us. We will only collect, use, and share your personal information in accordance with this Privacy Policy. This policy applies whether you use Minga through http://minga.io/ or via our Minga mobile applications (collectively, the “Service”).

This policy does not apply to websites or services or practices of companies that Minga doesn’t own or control, such as third party services you might access through links or other features on the Service. These other services have their own privacy policies, and we encourage you to review them before providing them with personal information.

We want you to feel comfortable using our products and services and encourage you to take the time to get to know our privacy practices. We’ve made every effort to ensure they’re clear and straight forward but if you have any questions, you can send us an email at support@minga.io. By using the Service, you acknowledge that you accept and agree to this Privacy Policy.

Protection of privacy is especially important to us. Minga respects and follows the rules and expectations set forth in the Children’s Online Privacy Protection Act (COPPA) that went into effect in the United States on April 21, 2000. COPPA aims to protect the online privacy of children under the age of 13 (“child” or “children”) by restricting how much Personally Identifiable Information (PII) is collected and by requiring parental consent for activities that make use of PII. Additionally, Minga respects the Personal Information Protection and Electronic Documents Act (PIDEDA) of Canada and the Personal Information Protection Act (PIPA) of British Columbia, Canada. Both PIDEDA and PIPA more generally outline how organizations collect, use and disclose personal information in the course of commercial business. For more information about COPPA and generally protecting children’s online privacy, please visit OnGuard Online. For more information about PIDEDA, please visit the Government of Canada. For more information on PIPA, please visit the Government of British Columbia.

What information does Minga collect and how is it used?

Accounts are created on the Service by an account administrator. New members are invited to join the Service only after an account has been created.

We collect the following account information:

  • First and last name: Used during account creation and when automatically creating a users display name.
  • Email: Used to uniquely identify each member in the Service, to invite users to Minga and to help reset lost account credentials.
  • Birthdate (optional): Used in automated birthday announcements.
  • Profile Picture (optional): Uploaded by a user and used as their avatar within the Service.

Through the Service members are able to post text and share photos, also known as User Generated Content (UGC). All UGC may be reviewed and moderated by Minga to ensure it upholds the spirit of our Service and does not include any personally identifying information (PII). Approved UGC is made available to all members of the Service and never privately between two or more members. We believe private, or group sharing promotes negative online behaviour. We encourage you to review the rules for posting content set forth in the “User Conduct” section of our Terms of Service.

Through the course of using the Service we will automatically collect generic usage information as set forth in the “Information collected automatically” section below. We use this information to provide the Service to the member, for security and safety purposes, or as required by law or to enforce our Terms.

If we discover that we have collected information from a child in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information, or immediately seek consent for that collection. We do not disclose any personal information about members to third parties, except to service providers necessary to provide the Service, as required by law, or to protect the security of the Service or other members.

How Long Does Minga Hold On to Information?

We do not keep member data any longer than we have to and follow a strict data retention and protection policy. We automatically delete member data subject to the following requirements:

  • We automatically delete member data after a 12 month period of inactivity; unless
  • As required by law
  • As required by our Terms of Service
  • To ensure the security of our Service

Information Collected Automatically

Like most internet-based services, we (or our service providers) may automatically receive and log generic information about you when you use the Service. For example, this could include the frequency and duration of your visits to the Service, the browser you use, and the platform of the device you use.

If you use the Service on different devices, we may link the information we collect from those different devices to help us provide you with a consistent experience across your different devices. If we do combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy.

The technologies and information we automatically collect may include:

  • Cookies and other similar technologies: We (or our service providers) may use various technologies to collect and store information when you visit our Service including, clear GIFs (also known as “web beacons”), “tags”, “scripts”, and “cookies”. We use both session and persistent cookies: a session cookie disappears after you close your browser; a persistent cookie remains after you close your browser (although it can be removed) and may be used by your browser to identify you on subsequent visits to the Service. We may also use, collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5). Like many services, Minga uses these technologies to tailor the Service for you, and to help the Service work better for you – for example, by remembering recent search choices.
  • Device information: We may collect device-specific information such as your operating system type, hardware version, screen resolution, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how the Service is performing and improve Minga for you on your particular device.
  • Log information: Like most online services, when you use our Service, we automatically collect and store certain information in our server logs. Examples include things like:
    • Details of how you used our service, such as your activity on the Service, and the frequency and duration of your visits to the Service.
    • IP Address
    • Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL

This information helps us make decisions about what we should work on next – for example, by showing which features are most (or least!) popular.

  • Location information: When you use our Service we may collect and process information about your geographic location based on your IP address. We do this to derive amalgamated anonymized information about how well (or not!) our Services is used in certain geographic areas. We do not associate precise geolocation data with a child’s personal information and will not track the specific location of a child at a given moment in time.

How does Minga use the automatic information it collects?

First and foremost, you should know that Minga does not sell or rent any of your personal information to any third party for any purpose – including for advertising or marketing purposes. We use the information we collect to provide the best experience. More specifically, this information is used to:

  • Provide and improve the Service, for example by developing new products and features, or by reporting errors within the service.
  • Respond to your requests for information or customer support.
  • Customize the Service for you, and improve your experience with it.
  • Most crucially, to protect our community by making sure the Service remains safe and secure.

Will Minga share any information it collects?

First and foremost, you should know that Minga does not sell or rent your personal information to any third party for any purpose – including for advertising or marketing purposes. Third-party advertising is not permitted on Minga. Furthermore, we do not share personal information with any third parties except in the limited circumstances described in this Privacy Policy:

  • Service Providers: We do work with vendors, service providers, and other partners to help us provide the Service by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. Please see the list of the third parties below. Generally, these service providers do not have the right to use your personal information we share with them beyond what is necessary to assist us. Additionally, these service providers must adhere to confidentiality and security obligations in a way that is consistent with this Privacy Policy.
  • Analytics Services: We use analytics services, including mobile analytics software, to help us understand and improve how the Service is being used. These services may collect, store and use information in order to help us understand things like how often you use the Service, the events that occur within the application, usage, performance data, and from where the application was downloaded. A list of all of our third party services is included below.
  • Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information publicly, including with users, partners or the press in order to, for example, demonstrate how the Service is used, spot industry trends, or to provide marketing materials for Minga. Any aggregated information shared this way will not contain any personal information.
  • Legal Requirements: We may disclose personal information if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of Minga, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests.
  • Sharing with Minga Companies: Over time, Minga may grow and reorganize. We may share your personal information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your personal information in a way that is consistent with this Privacy Policy.
  • Change of control: In the event that all or a portion of Minga or its assets are acquired by or merged with a third party, personal information that we have collected from users would be one of the assets transferred to or acquired by that third party. This Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, or by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, you may request its deletion from the company.In the unlikely event that Minga goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third party.
  • With your consent: Other than the cases above, we won’t disclose your personal information for any purpose unless you consent to it. Additionally, as discussed above, we will never sell or rent your personal information to advertisers or other third parties.

How does Minga protect and secure my information?

Your Minga account is protected by a password. You can help us protect against unauthorized access to your account by keeping your password secret at all times.

The security of your personal information is important to us. We work hard to protect the Service, and we maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information. In particular:

  • Our engineering team is dedicated to keeping your personal information secure
  • We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems
  • We continually develop and implement features to keep your personal information safe – for example, when you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL) by default
  • We ensure passwords are stored and transferred securely using encryption and salted hashing
  • We automatically delete inactive accounts after a specific period of time, as per our retention policy, described in the “How Long Does Minga Hold On to Information?” section

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (minga.io) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

What communications will I receive from Minga?

If you registered on Minga we may send you messages and updates regarding your account, including privacy and security notices, updates regarding the Service, and information regarding products, features or services from Minga. If you have an account with us, we’ll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business.

If you download and install the app on an Apple or Android device, you will optionally receive push notifications for activity related to your account that occurs while you are not using the Service.

How will Minga notify me of changes to this policy?

We may occasionally update this Privacy Policy – you can see when the last update was by looking at the “Last Updated” date at the bottom of this page. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Service and/or notifying you by email (using the email address you provided), so you can review and make sure you know about them.

If we make changes that have a material effect on our Privacy Policy we will provide our schools and registered users with at least 30 days notice so that you have time to review our changes.

We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use, and disclosure of personal information through the Service. If you don’t agree with any changes to the Privacy Policy, you may terminate your account (although we’ll be sad to see you go!). By continuing to use the Service after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.

Third Party Service Providers

It’s important to us that we keep your information safe and secure. To best provide our Services, and keep your information safe, we work with a few other companies. These companies will only have access to the information they need to provide the Service.

Here is a list of the essential service providers we work with, and their respective privacy policies to provide a great Minga experience.

  • Google Analytics for analytics on our website
  • MailChimp for sending email from our app
  • Two Hat Security for moderating and validating usernames
  • Watson from IBM for moderating and validating user generated content
  • Perspective from Google for moderating and validating user generated content
  • Sight Engine for moderating and validating user generated content

How can I contact Minga with questions?

If you have any questions or concerns about this Privacy Policy or how we protect our community, please contact us at support@minga.io – we’d love to help. If you’d like, you may also write to us at:

Minga

Unit 300, 1353 Ellis Street
Kelowna, BC
V1Y 1Z9

Attention: Chief Privacy Officer

Effective Date

This Privacy Policy is effective as of April 1, 2019.

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