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Scintillant Ventures Ltd. (“Scintillant”) is committed to protecting the privacy and security of all Personal Information inputted via its website and mobile application (collectively, the “App”) or stored on servers under its control. This policy explains the steps we take to ensure Personal Information is handled appropriately. Our policies and practices have been designed to comply with the Personal Information Protection Act of British Columbia (“PIPA”).

This privacy policy applies to all users of the Scintillant App.

  1. Definitions

    1. “Personal Information” means information about an identifiable individual including name, age, address, etc.

  2. Collecting Personal Information

    1. Unless the purposes for collecting Personal Information are obvious and the user provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected before or at the time of collection.

    2. We will only collect Personal Information necessary to fulfill the purposes set out in Section 4.1 below.

    3. Examples of the Personal Information we collect include:

      • name;

      • email address;

      • age;

      • school name;

      • phone number; 

      • photos uploaded by a user; 

      • agenda data (including schedules, tasks, and goals);

      • connections with other App users; and

      • App usage data (including IP address, browser type, unique device identifiers, and other diagnostic data).

  3.  Consent

    1. We will obtain user consent to collect, use, or disclose Personal Information (except where, as noted below, we are authorized to do so without consent).

    2. Consent can be provided orally or in writing, or it can be implied where the purpose for collecting, using, or disclosing the Personal Information would be considered obvious and the user voluntarily provides Personal Information for that purpose.

    3. Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), users can withhold or withdraw their consent for Scintillant to use their Personal Information in certain ways. A user’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or product.

  4. Using Personal Information

    1. We will use Personal Information for the following purposes:

      • to communicate with users generally;

      • to customize the App to provide functionality and services that are most relevant to a particular user; 

      • to provide workflow analysis and recommendations;

      • to provide users with offers for Scintillant’s products and services; and

      • to fulfill any other purpose that would be obvious to a reasonable person.

  5. Retaining Personal Information

    1. If we use a user’s Personal Information to make a decision that directly affects that user, we will retain that Personal Information for at least one year so the user has a reasonable opportunity to request access to it. 

    2. Subject to Section 5.1, we will retain Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose. 

  6. Ensuring Accuracy of Personal Information

    1. We will make reasonable efforts to ensure that a user’s Personal Information is accurate and complete where it may be used to make a decision about the user or disclosed to another organization. 

    2. Users may request correction to their Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought. 

    3.  If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note the user’s correction request in the file.

  7. Securing Personal Information

    1. We are committed to ensuring the security of Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks.

    2. The following security measures will be followed to ensure that Personal Information is appropriately protected:

      • physical security measures such as restricted access facilities;

      • electronic security measures for computerized data such as password protection and database encryption;

      • organizational processes such as limiting access to Personal Information to a selected group of individuals; and

      • contractual obligations with third parties requiring them to protect and secure your Personal Information.

    3. We will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.

  8. Storing and Sharing Personal Information

    1. Personal Information may be stored with third-party cloud storage providers including, for example, Amazon Web Services, Microsoft Azure, and Google.

    2. Personal Information may be shared with users’ parents, teachers, school administrators, and school board.

  9. Providing Access to Personal Information

    1. Users have a right to access their Personal Information, subject to limited exceptions. 

    2. A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. 

    3. Upon request, we will tell users how we use their Personal Information and to whom it has been disclosed if applicable. 

    4. We will make the requested Personal Information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. 

    5. If a request is refused in full or in part, we will notify the user in writing, providing the reasons for refusal and the recourse available to the user. 

  10. Privacy Officer

    1. Scintillant’s Privacy Officer is responsible for ensuring Scintillant’s compliance with this policy and PIPA.

    2. Users should direct any complaints, concerns or questions regarding Scintillant’s compliance in writing to the Privacy Officer at: 

                Unit 251 2912 W Broadway
                Vancouver, BC V6K 2G8

        3. If the Privacy Officer is unable to resolve the concern, the user may also write to the Information and Privacy Commissioner of British Columbia.

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