Last modified: June 23, 2023

INTRODUCTION

MMDF Corporation Privacy Policy

MMDF Corporation (“MMDF”, “us” or “we”) respects your privacy and is committed to protecting it by complying with this Privacy Policy (the “Policy”).

MMDF provides financial support for mining and economic development initiatives that create new opportunities and capitalize on existing assets in the north and across Manitoba. Projects funded by MMDF (each, a “Project”) are intended to benefit Manitoba’s economy and local communities alike, with a partnership-based approach to help grow and diversify the provincial economy together with Indigenous communities. Our key objectives include:

  • Increasing economic partnerships between Indigenous communities and the mineral development industry.
  • Building capacity in local communities and businesses to increase engagement in economic development opportunities.
  • Creating and maintaining short-term and long-term local employment opportunities.
  • Improving local training and education opportunities to build a skilled local workforce.
  • Diversifying regional economies, particularly in areas of Manitoba that are impacted by fluctuations in the mineral development industry.
  • Stimulating investment in the mineral development industry.

These, and such other activities and other products and services as may be provided by MMDF from time to time,

including the MMDF website, (our “Site”), are collectively referred to as the “MMDF Services”.

This Policy describes how we collect, use, disclose and protect the personal information we receive from users of the MMDF Services (collectively referred to as “you”). In some cases, specific products and services we offer are subject to additional terms and conditions (including our Website Privacy Statement, Application Portal Privacy Statement and any contribution agreement you may enter into with us regarding your Project). We will make those terms and conditions available to you through the specific products and services to which they relate.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or contact information, as used in your professional capacity.

We will collect, use and disclose personal information in accordance with this Policy, unless otherwise required by applicable law. We take reasonable steps to ensure that any personal information we collect about you is adequate, relevant, not excessive, and used for limited purposes.

This Policy does not apply to personal information collected outside the MMDF Services or by any third party, including information collected through an application or content that may link to or be accessible from or on our Site.

The application of this Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and any other applicable legislation or regulation. If you reside in British Columbia, Alberta or Québec, then the substantially similar provincial privacy law of your province will apply to our handling of your personal information, rather than PIPEDA. In that case, reference in this Policy to PIPEDA shall be deemed to include your province’s substantially similar privacy law.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing personal information. By accessing or using the MMDF Services, you indicate that you understand, accept, and consent to the practices described in this Policy.

ACCOUNTABILITY

MMDF is responsible for all personal information under its control and has designated the MMDF Privacy Officer to oversee privacy compliance. Other individuals within MMDF may be delegated to act on behalf of our Privacy Officer or to take responsibility for the day to day management of personal information. MMDF trains and communicates with employees about our privacy practices, including this Policy.

As appropriate, MMDF implements privacy policies and procedures to properly enforce this Policy, and we use contractual or other means to provide a comparable level of privacy protection while personal information is being processed or used by a third party.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

  • Personal information, that we can reasonably use to directly or indirectly identify you, which may include your: name; contact information; and information collected from MMDF’s employees and independent contractors for the purposes of administering our relationship with them (“personal information”).
  • Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic data, statistical or aggregated data or data about a Project which cannot be used to identify you. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users participating in a certain program or accessing a specific feature on our Site.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

  • INFORMATION YOU PROVIDE TO US, for example, by:
    • Filling in forms, online polls, or questionnaires, including Project applications.
    • Registering for an account, program, or services.
    • Corresponding with us by phone, email, or otherwise. Records of correspondence, including copies of emails, may be kept by MMDF to assist us in delivering our programs and services to you.
    • Providing information for us to publish or display on public Site areas (referred to as “posted” or “posting”) or to transmit to other Site users or third parties (collectively, “User Contributions”), as and when such features are made available from time to time. Any User Contributions are posted and transmitted to others at your own risk. MMDF cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
    • If you engage with our social media accounts, we will collect whatever information you provide to us through the applicable platform. This may include the user ID associated with any social media account (e.g., Google) that you use. If you sign in with or otherwise connect your social media account to the MMDF Services, you authorize us to collect, store, and use in accordance with this Policy any and all information available to us through the social media interface, including without limitation any information that you have made public in connection with your social media account, information that the social media service shares with us, or information that is disclosed as being shared during the sign-in process. Please see your social media provider’s privacy policy and help centre for more information about how they share information when you choose to connect your account.
  • THIRD PARTIES, including service providers who are engaged for specific projects or services as part of MMDF’s programs (for example, the third party which helps us operate our application portal (the “Portal”)). Where MMDF engages a service provider to collect or manage personal information on our behalf (either directly or indirectly) for a specific project, we will explain to you (in this Policy or otherwise) what personal information we are collecting, for what purposes it is being collected, and with whom that information will be shared (if anyone). Service providers who collect or manage personal information on MMDF’s behalf are contractually obligated to keep personal information confidential, collect it only for the purposes for which we have engaged them, and to process the personal information with the same standards set out in this Policy. MMDF remains responsible for any personal information collected for us by service providers, as set out in this Policy.

A NOTE ABOUT THIRD PARTY TRACKING TECHNOLOGIES

At times we may provide links or content through the MMDF Services that is hosted or served by third parties. These may include, for instance, our social media channels, which we use to communicate information about our organization and activities. These third-party websites may include advertisements or other content produced or distributed by third parties. These third parties may use cookies or other tracking technologies to collect information about you when you use their services. They may collect information, including personal information, about your online activities over time and across different websites and other online services and may use this information to provide you with interest-based (behavioural) advertising or other targeted content, on other platforms.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

To learn more about online behavioural advertising and how to stop websites from placing cookies on your device, you can access materials and information provided by the Digital Advertising Alliance of Canada or the Network Advertising Initiative.

USE OF YOUR INFORMATION

We may use information that we collect about you or that you provide to us, including any personal information:

  • To provide the MMDF Services, including providing you with information or services that you request from us.
  • To evaluate your Project application.
  • To provide funding for your Project, if your application is accepted, and to monitor your performance of the Project.
  • To present our Site and its contents to you.
  • To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts with you.
  • To notify you about changes to the MMDF Services, including changes to our Site.
  • To improve the MMDF Services, including our Site, communications, client relationships and experiences.
  • To allow you to participate in interactive or similar features on our Site, as such features may be made available from time to time.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

The information you provide to us – such as your name, address, etc. – allows us to inform you about potential funding and other programming opportunities, and to notify you of issues, events or special offers which may be of interest to you.

By signing up for an account, you provide us permission to contact you by way of the information you provide. If you do not wish to be contacted by us for these purposes, please email us at: [Insert email address].

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or which you provide as described in this Policy:

To provide the MMDF Services, including maintaining accountability and oversight of funded Projects.

To the Government of Manitoba (“Manitoba”), in order for Manitoba to:

  • Measure the results of the Manitoba Mineral Development Fund (the “Fund”);
  • Evaluate the success of the Fund in achieving its objectives; and
  • Ensuring MMDF meets its obligation of accountability by reporting on the results of the program and its success in achieving its objectives.Information, when provided to Manitoba, is administered in accordance with The Freedom of Information and Protection of Privacy Act. The information disclosed to Manitoba includes information regarding the total number of applications received and accepted, the amount of funding which has been disbursed, a listing of all successful Project applicants, their application status, a description of the Project and the total amount to be disbursed. Generally speaking, this information is non-identifying, though in the case of small organizations, it may be capable of identifying particular individuals.
  • To the Manitoba Chambers of Commerce (“MCC”), for the same purposes as set out above with respect to Manitoba. Information disclosed to MCC is similar to what we disclose to Manitoba, but also includes status updates for Project applications which are currently under consideration and not yet awarded.
  • In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MMDF’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MMDF about our Sub-Agreement Holders, clients, individual program participants, and users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
  • To enforce or apply the MMDF Terms of Use and other agreements. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MMDF, our clients, or others.

We share aggregated information – not personal information – about the MMDF Services (including the names of successful Project applicants, a description of the funds to be made available and a brief description of the Project), on our Site and otherwise to the public, generally. We do this to help promote the Fund and to showcase success stories. If you do not want this information to be made available to the public, please do not submit an application for a Project.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer limited personal information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support the MMDF Services (such as the third party that provides the cloud platform we use for the Portal and an external investment manager for the Fund) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation.

You are welcome to contact us to obtain further information about MMDF policies regarding service providers outside of Canada. See the Contact Information section below.

By submitting your personal information to us or engaging with the MMDF Services, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Programming Information from MMDF. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by MMDF to provide information about educational, employment, or other programming opportunities we think may be of interest to you, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a general informational email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided by MMDF as part of its requirements under an agreement with you.
  • Information Used and Disclosed as part of the MMDF Services, generally. When it comes to the MMDF Services, generally, MMDF may have certain contractual obligations relating to the use and disclosure of personal information you have provided to us, as described in this Policy. If you wish to have more information about MMDF’s privacy practices and your choices related to how we use and disclose your information as part of the MMDF Services, please contact us at the information provided below in the Contact Information section.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us in compliance with policies, procedures and guidelines described in this Policy and our other contractual obligations.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, as such functionality is offered from time to time, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk, except to the extent that we have caused that risk by breaching this Policy. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This includes personal information collected under a contribution agreement, which will be maintained in accordance with the terms of that agreement.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose under MMDF’s mandate without further notice to you or your consent.

CHILDREN UNDER THE AGE OF 13

We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any personal information through the MMDF Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under 13, please contact us at [email protected].

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [Insert email address] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected].

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [Insert email address]. Please note that if you withdraw your consent we may not be able to provide you with particular services and your right to withdraw consent may be limited by agreements you have entered into with us. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

This Policy may change from time to time. Changes we make to this Policy will be posted on this page. If we make material changes to how we treat our users’ personal information, we may notify you by email or through a notice on the Site home page. We include the date the Policy was last revised at the top of this Policy. You are responsible for periodically visiting our Site and this Policy to check for any changes. Your continued use of the MMDF Services after such notice constitutes your acceptance of such changes.

LANGUAGE

You and MMDF have requested and agree that this Policy and all documents related to this Policy be drawn up in English. Les parties ont demandé que cette convention ainsi que tous les documents que s’y rattachent soient rédigés en anglais.

CONTACT INFORMATION

If you have any questions about this Policy and MMDF’s privacy practices, please contact us at:

MMDF
Attn: Privacy Officer
[email protected]

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy please contact our Privacy Officer using the contact information listed above.