“Personal information” means all information about an identified or identifiable individual. In some jurisdictions, the term “personal data” is used in local privacy laws rather than the term “personal information”. Mirai uses the terms “personal information” and “personal data” interchangeably.
Mirai is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.
Legal Basis And Purposes For Collecting Personal Information
Through the Services and the Website, Mirai collects, uses and discloses to certain third parties personal information for the following primary purposes:
to develop, manage, deliver and support our Services to our customers;
to contact our customers, either directly or through one of our resellers, to offer them the option to renew a services;
to contact our customers directly about services that may be of interest;
to ensure high standards of service to customers;
to contact customers with service updates, upgrades and enhancements, as well as administrative or account-related information;
to respond to inquiries and fulfill requests, such as sending requested materials or documents regarding Mirai’s services;
to provide marketing and promotional communications (where this is in accordance with applicable law), and to determine the effectiveness of marketing and promotional campaigns;
for our legitimate business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving or modifying our Services, and identifying usage trends;
to verify a customer’s identity; and
to comply with applicable laws, comply with legal and regulatory processes, enforce our terms and conditions, and protect our operations, rights, safety or property.
The paragraphs below provide further information about what types of personal information we collect and how we use and disclose it for the Website.
The form of consent can vary, depending on the sensitivity of the information and the circumstances. Consent may be express or implied depending on the nature of the personal information or the use, and depending on applicable local privacy laws. At times, consent for one use can fairly be implied to include consent for other included or related uses. When determining the appropriate form of consent, Mirai will be guided by what a reasonable person would consider fair and appropriate in the circumstances.
Your consent may be provided to Mirai orally, in writing or electronically, either personally or through an authorized individual. Consent can be implied (where not prohibited by applicable local privacy laws) when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.
Mirai may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:
When the collection, use or disclosure of personal information is permitted or required by law (including subpoenas, search warrants, court orders and government orders);
In an emergency that threatens an individual’s life, health or personal security;
When the personal information is available from a public source (e.g. a telephone directory or website);
When we require legal advice from a lawyer;
For the purposes of collecting a debt;
In connection with criminal justice, taxation or regulatory activities;
To protect ourselves from fraud or to protect the rights and property of Mirai;
To investigate an anticipated breach of an agreement or a contravention of law; or
In the event of a reorganization, merger or sale of Mirai.
Subject to certain exceptions (e.g. where the personal information is necessary to provide Services, or the withdrawal of consent would frustrate the performance of a legal obligation), you may withdraw or refuse to provide your consent to Mirai, or request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to email@example.com.
Mirai will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Mirai will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.
Mirai will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.
Limited Use, Disclosure And Retention
Mirai may share personal information with our employees, contractors, consultants, affiliates, service providers, business partners and other parties who require such information to assist us with providing you with the Services.
The use, collection and disclosure of personal information may involve Mirai transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws.
Mirai will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for Mirai’s legitimate business purposes, or to comply with applicable legal, tax or regulatory requirements. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous.
Mirai may use and disclose aggregated and anonymous or de-identified information to third parties, including the general public. For example, we may analyze and publish reports on usage trends or statistics from across our global customer base for information or marketing purposes, but only after we have removed any personal information that would identify or be associated with any particular individual or customer. This type of aggregated and anonymous or de-identified data can help Mirai to improve our products, services and advertising, and it can be used by customers and the public to better understand trends in the industry. We will never sell this aggregated data.
Mirai will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Mirai does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Mirai therefore relies on you to keep your personal information accurate and current.
You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Mirai and must provide sufficient detail to identify the personal information and the correction being sought.
If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.
Safeguarding Personal Information
Mirai will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Mirai as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Mirai’s security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.
Mirai will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.
Mirai will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Mirai will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Mirai and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a Privacy Commissioner or similar regulatory body in any relevant jurisdiction.
Mirai will also continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Use By Children
The Website and the Services are not intended for use by minors. Mirai does not knowingly collect information about minors and believes that minors should obtain their parents’ or legal guardians’ consent before providing any personal information. If you believe that we have mistakenly or unintentionally collected a minor’s personal information, please contact firstname.lastname@example.org. By using the Website, you represent that you are over the age of majority.
Mirai Security Inc.
757 West Hastings Street
Vancouver B.C., V6C1A1
Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws.
Policy last updated on: 2019-09-01