INOVAIT WEBSITE PRIVACY POLICY

At INOVAIT (“us”, “we”, or “our”), we respect your privacy and are committed to protecting it through compliance with this privacy policy (“Policy”). This Policy, provided on this page and last modified on the date below, describes the types of information we may collect from you or that you may provide (“Personal Information”) on the https://inovait.ca/ website (“Website”), and our practices regarding the collection, use and disclosure of such Personal Information.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and INOVAIT. If you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website. By accessing and using the Website, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.

1. Automatic Collection of Information
   1. Upon opening the Website, our servers will automatically record information sent by your browser, which may include, but is not limited to:
      1. Your device’s IP address
      2. Your browser type and version

• Your operating system type and version

1. Your language preferences
2. The last webpage you visited before using our Website
3. The pages of the Website you visit and time spent on them

• The information you search for on the Website

1. Such information which may be automatically collected will only be used to establish statistics regarding the Website’s use and traffic as well as identify potential cases of abuse.
2. Neither such automatically collected information nor the derived statistics will be used to identify any particular User

2. Collection of Personal Information
   1. You can access and use the Website without providing us Personal Information; however if you wish to use some features on the Website, you may be asked to provide Personal Information such as your name and email address
      1. When required, this information may include, but is not limited to:
         1. Contact information
         2. Personal information such as your name and country of residence
         3. The geolocation data of your device
      2. Such Personal Information which you provide via forms on the Website will be stored as follows:
         1. For information submitted via the “Contact Us” form, storage will be on Sunnybrook Health Sciences Centre (SHSC) email servers located in Canada.
         2. For information submitted via the “Subscribe Now” form, storage will be on third-party servers located in the United States and operated by MailChimp. For further information about MailChimp’s data storage and security, please visit: https://mailchimp.com/about/security/
      3. You may choose not to provide us with any Personal Information
      4. We do not knowingly collect any Personal Information from children under the age of 18
         1. Users under the age of 18 should not submit any Personal Information through the Website
         2. If you for any reason believe a person under the age of 18 has provided us their Personal Information, please contact us directly so we may remove their Personal Information from our servers
      5. Use and Processing of Collected Information
         1. In order to make certain features available to you on the Website, or to meet legal obligations, we may collect and use certain Personal Information
         2. Any information, whether collected automatically, or Personal Information that you have provided us, may be used for the following purposes:
            1. To inform subscribers on the latest happenings in the network (for example, new members, new networking, training, or funding opportunities)
            2. To inform subscribers about upcoming events that are being put on by the network

• To inform subscribers on how to create and manage membership accounts with INOVAIT

1. To inform subscribers on latest advances being made in IGT technology by other members and partners of INOVAIT

1. How we process your Personal Information will depend on how you use our Website , your location, and if any of the following apply:
   1. You have provided your consent for one or more specific purposes
      1. This purpose does not apply where the processing of Personal Information is subject to European data protection law
   2. The provision of the information is necessary for the performance of an agreement with you;

• The processing if necessary for compliance with a legal obligation to which you are subject;

1. The processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; and

1. The processing is necessary for the purposes of the legitimate interests pursued by us or a third party
2. In circumstances where we may be permitted to process information until you have objected to such processing by opting out, without having to first rely on consent or any other legal basis

4. Disclosure of Information
   1. To provide requested services, your information may be shared with our affiliates contracted companies, and service providers (collectively hereinafter referred to as “Service Providers”)
      1. Service Providers will only be provided the information they need to perform their designated functions, and will not be using such information for their own marketing or other purposes
      2. Service Providers cannot use or disclose your information except as necessary to perform services on our behalf or to comply with legal obligations
   2. Your Personal Information will not be shared with any unaffiliated third parties
   3. Personal Information that is collected, used or received may be disclosed, if required or permitted by law, such as to comply with a subpoena or similar legal process and where we believe in good faith that such disclosure is necessary to protect our rights, your or other’s safety, investigate fraud, or to respond to a government request
5. Retention of Information
   1. Your Personal Information will be retained for the period necessary to comply with our legal obligations, enforce our agreements, and resolve disputes.
   2. We may use aggregated data derived from or incorporating your Personal Information, but not in a manner that would make you personally identifiable
   3. Once the retention period has expired, all Personal Information shall be deleted
      1. The Right to Access, the Right to Erasure, the Right to Rectification, and the Right to Data Portability cannot be enforced after the expiration of the retention period
   4. Transfer of Information
      1. Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including Canada
         1. For those residing in the European Union or the United Kingdom, the transfer of your Personal Information to countries outside the European Union or United Kingdom (respectively) will be made only if you have explicitly consented to it or in the cases provided for by the GDPR or UK GDPR and will be processed in your interest. Should any data transfer occur, INOVAIT will ensure relevant safeguards are taken for the protection of your data.
      2. Exercising your Rights under this Policy
         1. Right to Access. You have the right to request from us copies of your personal data. We may charge you a small fee for this service.
         2. Right to Erasure. You have the right to request we erase your personal data, under certain conditions and dependent on feasibility.
         3. Right to Rectification. You have the right to request that we correct any information you believe is inaccurate and to complete information you believe is incomplete.
         4. Right to Data Portability. You have the right to request that we transfer your personal data we have collected directly to you, under certain conditions and dependent on feasibility.
         5. Any requests to exercise your rights can be directed to us through the contact details provided in this Policy
            1. Please note that we may ask you to verify your identity before responding to such requests, so please ensure that your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person
            2. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you

• If you reside in the European Union or United Kingdom and wish to report a complaint about our conduct in handling your request, please contact your country’s Information Commissioner’s Office.

8. Cookies
   1. Our Website uses “cookies” to personalize your experience
      1. You can accept or decline the use of cookies
   2. We may use cookies to collect, store, and track information for security and personalization, and for statistical and marketing purposes
   3. You can read more about our cookie use policy here
9. Data Analytics
   1. Our Website may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information
   2. Information gathered by third-party analytics tools will be used to compile statistical reports on User activity such as, but not limited to:
      1. Page visits
      2. Time on page

• Traffic through site

1. We do not use third-party analytics tools to track or to collect any personally identifiable information of Users and will not associated any information gathered from statistical reports with any User

10. Do Not Track Signals
    1. This Website is set up to interpret or respond to Do Not Track signals communicated by your browser
11. Social Media Features
    1. Our Website may include social media features such as a YouTube and Twitter share buttons (collectively hereinafter referred to as “Social Media Features”)
    2. Social Media Features may collect your IP address, what page you are visiting on our Website, and may set a cookie to enable Social Media Features to function properly
    3. Social Media Features are hosted either by their respective providers or directly on our Website
    4. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers and not by this Policy
12. Email Marketing
    1. Our Website offers electronic newsletter to which you may voluntarily subscribe to
    2. We are committed to keeping your email address confidential, and will not disclose your email address to any third parties except as permitted under Section 3 and 4 of this Policy or for the purposes of using a third-party provider to send such emails
    3. We will maintain the information sent via email in accordance with applicable laws and regulations
    4. In compliance with the Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and the Telecommunications Act (S.C. 2010, c. 23) (“CASL”), all emails sent from us will clearly state who the email is from and provide clear information on how to contact the sender
       1. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us
    5. Links to Other Resources
       1. The Website contains links to other resources that are not owned nor controlled by us
       2. Please be aware that we are not responsible for the privacy practices of such other resources or third parties
    6. Information Security
       1. We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure
       2. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody
       3. However, because no data transmission over the Internet or wireless network can be guaranteed, you acknowledge that:
          1. There are security and privacy limitations of the Internet which are beyond our control;
          2. The security, integrity, and privacy of any and all information and data exchanged between you and the Website cannot be guaranteed; and

• Any such information and data may be viewed or tampered with in transit by a third party, despite best efforts

15. Data Breach
    1. In the event we become aware that the security of the Website has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities
    2. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law
16. Changes and Amendments
    1. We reserve the right to modify this Policy or its terms related to the Website at any time at our discretion
    2. Upon amendment, we will revise the updated date at the bottom of this page
    3. An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified
    4. Your continued use of the Website after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes
       1. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected
    5. Acceptance of this Policy
       1. You acknowledge that you have read this Policy and agree to all its terms and conditions
       2. By accessing and using the Website and submitting your information you agree to be bound by this Policy
       3. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website
    6. Contacting Us
       1. If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us at: [email protected]
       2. We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws

This document was last updated on October 8th, 2021.