Last Updated: April 11, 2022
Please read the following policy carefully before using our Platform or providing us with information about an identifiable individual (“Personal Information”).
The purpose of this privacy policy (the “Policy”) is to provide you with information about how Mitchellwood Mining Hub Inc. (“Mitchellwood”, “we”, “our” or “us”) collects, uses and discloses your Personal Information in connection with your access to and use of the Mitchellwood website juniormininghub.com and any and all applicable subdomains (the “Website”), our mobile application (the “App”), and all related webpages, forums and chatrooms (together with the Website and App, the “Platform”), together with all of the Platform’s content and related features (“Content”) and all products and services made available through the Platform, including, without limitation, the services that enable you to receive information about the junior mining and mining companies, and individuals, in various regions, using our interactive mapping platform (collectively, the “Services”).
We are committed to protecting your privacy and will manage your Personal Information in accordance with applicable provincial and federal privacy laws including the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Information Protection Act (British Columbia).
The purpose of this privacy policy (the “Policy”) is to provide you with information about how Mitchellwood Mining Hub Inc. (“Mitchellwood”, “we”, “our” or “us”) collects, uses and discloses your Personal Information in connection with your access to and use of the Mitchellwood website juniormininghub.com and any and all applicable subdomains (the “Website”), our mobile application (the “App”), and all related webpages, forums and chatrooms (together with the Website and App, the “Platform”), together with all of the Platform’s content and related features (“Content”) and all products and services made available through the Platform, including, without limitation, the services that enable you to receive information about the junior mining and mining companies, and individuals, in various regions, using our interactive mapping platform (collectively, the “Services”).
We are committed to protecting your privacy and will manage your Personal Information in accordance with applicable provincial and federal privacy laws including the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Information Protection Act (British Columbia).
Mitchellwood collects your Personal Information when you interact with us or use the Platform, Services or Content. We also collect some Personal Information from you automatically, which is addressed in more detail below. We will not use or disclose your Personal Information for any new purpose without first identifying the new purpose and providing notice to or obtaining your consent (as applicable), unless permitted by law.
You can always choose not to provide us with certain of the Personal Information we request, however you may not be able to access or utilize all or part of the Platform, Services or Content.
Personal Information You Provide
Contact information: we collect your Personal Information when you contact us directly to inquire about the Platform, Services or Content. This may include your first and last name, e-mail address, phone number, and other information that you choose to provide to us.
Account and profile information: we collect your Personal Information when you register for an account (“Account”) with us, and when you create or modify your Account or user profile. This includes information such as your first and last name, title, company, business address, your e-mail address, phone number, password.
Chat and Forum Information: if you choose to communicate with other users using the online chat or forum feature on the Platform, we may collect any information that you disclose to us through such means.
Interactive Mapping Platform: we may collect any company information that you provide when you register your mineral project on our interactive mapping platform. For example, when you add a project outline which may include information such as project name, operator, commodity(s), location, stage, mineral district, availability for Option/JV/Sale, additional owners, project option details, and any underlying Net Smelter Royalties (NSR), and any additional information voluntarily provided under your project profile dashboard.
Other information: we may collect any of the information or content that you provide through our Platform voluntarily. For example, when you e-mail us for information about Platform and its Services. We collect the Personal Information to provide you with the information or service that you have requested. We also collect any Personal Information that may be embedded in Content that you choose to upload to the Platform.
Personal Information Automatically Collected
Location Information
If you permit the Platform or Services to access location services through the privacy settings on your mobile device or browser, we may also collect the location of your device when the App is running in the foreground or background of your device.
If you have enabled location services in the App through your browser or mobile device, we may track your geolocation on a real time basis when you are using the Platform or logged into the App. You can choose whether to enable the location tracking feature through the settings on your browser or mobile device. If you choose to disable access to location services through your browser or mobile device, this means that the the App will not receive location information from your device, which may affect the functionality available to you.
Technical Information
We may also automatically collect the following technical information about your Platform and Services usage:
the Internet Protocol (IP) address, web browser, device and operating system that you are using;
the sections of the Platform that you visit;
the date and time of your use of the Platform and Services and your in-media time; and
if you were on another website before visiting the Platform and if that website referred you to our Platform, the URL of that previous website.
We may choose to link any of the above information with information that is personally identifiable to you. We collect this data for a number of reasons, including to understand the traffic on our Platform, how it is used, and how we can improve it. We also collect this data to ensure that the Platform is compatible with your device. We do not share this aggregate data with third parties except for the possible use of web analytics companies as described below.
Cookies
We use “cookies” to track user activity on the Platform and to modify the Platform and an Account holder’s or visitor’s experience to reflect their preferences. Cookies enable our Platform to save and retrieve information that you enter (for example, to recognize a returning user). Cookies may remain on your device after you leave the Platform (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser; however, disabling cookies may affect the functionality of the Platform and your ability to access some pages on the Platform.
Pixel Tags
A pixel tag (also known as a web beacon) is a piece of code embedded in the Platform that collects information about visitors’ engagement on that web page. The use of a pixel allows us to record, for example, that you have visited a particular web page on the Site.
Web Analytics
We may use third party analytics tools, such as Google Analytics, to track certain Platform usage information in a way that does not personally identify you. Such information may include the device or network being used to access the page and your geolocation. This data is used for aggregate reporting purposes. None of this data is used by Mitchellwood or our service providers to identify you. These third party analytics companies may use cookies and other tracking technologies to perform their services. To learn more about Google’s privacy practices, including how you can view and edit your preferences, please see the Google Privacy Policy. Information about how to opt-out of certain types of interest-based ads is available here.
Mitchellwood will only use your Personal Information to fulfill the purpose for which it was originally collected, or for a use consistent with that purpose, unless you expressly consent otherwise or it is permitted or required by law. We may contact you to inform you about our services in different ways including by mail, email, telephone, or other means to which you have agreed.
We may use the Personal Information that we collect for the following purposes:
To provide services to you: we use your Personal Information to provide you with access to, and optimize your use of, the Platform, Services and Content, including to set up your Account and to administer your use of the Platform, Services and Content. For example, you may create custom stock exchange and commodity watchlists, subscribe to specific mining companies of your choice.
To communicate with you: we use your Personal Information to contact and correspond with you directly about our relationship and your use of the Platform, Services and Content. For example, we may use your Personal Information to respond to specific requests and inquiries from you, including to provide you with information and services that you request.
To personalize the Platform, Services and Content: we use your Personal Information to identify what may be of interest to you, and what services, information and/or offers may be more relevant to you. For example, where we have your consent to do so, we may use your contact information to send you email newsletters and news releases about specific mining companies from your watchlist.
To generate aggregated statistics: we may use your information to conduct data analysis, testing, research and monitor and analyze Platform usage and activity trends. We may also use and share anonymous information about you with junior mining and mining companies, business partners, and other third parties for business or other purposes, such as to improve the Platform, Services and Content, to the extent permitted by applicable law.
To improve our Platform and Services: we may use your Personal Information to improve the Platform and/or Services. For example, we may use the comments and suggestions that you provide to improve our Platform.
For security purposes: we may use your Personal Information to monitor suspicious or fraudulent activity, protect the security of the Platform, Services and Content, and identify violations of the Terms of Use. For example, we may use the information provided by users using the “report” function to suspend or deactivate the Accounts of users.
Troubleshooting and user support: we may use your Personal Information to respond to customer service requests regarding your Account, the Platform, Services or Content, and to administer and resolve technical issues on our Platform and Services.
Legal: we may use your Personal Information to meet legal and regulatory requirements.
Other: we may use your Personal Information to facilitate such other services and activities, as we may identify to you at the time.
If you provide us with your e-mail address and “opt-in” to receiving messages from us via the e-mail address provided, you may receive electronic communications from us from time to time. These electronic communications will provide you with our contact information and a method to opt-out and unsubscribe from receiving any further communications from us. You can also opt-out of receiving further communications from us by contacting our Privacy Officer via the email address below. We may use your e-mail address to communicate with you regarding important matters, such as information about your account. You may not opt-out of receiving communications required by law, or necessary to provide you with requested services.
Except as described in this Policy or in other situations where we have provided you with prior notice, have obtained your consent, or are obligated or permitted by law, we will not share your Personal Information with third parties.
Third Party Service Providers
Mitchellwood may disclose certain Personal Information to third party service providers, to carry out work on our behalf. Currently, we use third party service providers set out below:
Platform and Services design and operation: we use a third party company, Volta Design, to design and maintain the Platform and Services.
Electronic communications: we use third party email service providers, such as MailChimp, to send electronic communications to users. These third party email service providers may save a history of whether you open emails, whether you access the link(s) provided in emails, and if you do, when you opened emails or accessed the link(s) provided.
Hosting and content delivery network services: we use third party hosting companies to host our Platform and Services. Such third party hosting companies’ servers are resident in Canada.
We may also partner with additional third-party advertisers, ad server companies, and ad networks (“Third-party Advertising Companies”), to promote our Platform, Services or Content. If you respond to one of our advertisements and visit or register to use our Platform, Services or Content, we or our third party service providers may provide these Third-party Advertising Companies with identifiers from your device or computer, such as an IP address or device ID, to help us analyze our user acquisition efforts.
The third party service providers will have access to Personal Information needed to perform their services, but are only provided the limited amount of information required to perform their services. When we use third party service providers, we require the providers to protect your Personal Information in accordance with the law and with no less than the same or more stringent security and privacy standards than we apply. Any such disclosure of your Personal Information by us to a third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed. These third party service providers, such as Google Ads, may collect and use certain Personal Information to perform their services. To learn more about Google Ads’ privacy practices please see the Google Ads Privacy Policy.
The third party service providers identified in this Policy are located across multiple jurisdictions, and your Personal Information may be stored, accessed or used in the United States, Canada, or other jurisdictions and may be subject to the laws and access by government or regulatory organizations in those jurisdictions. If you have any questions about our policies and practices with respect to such service providers, including the collection, use, disclosure, and storage of Personal Information, you can contact our Privacy Officer at the contact information listed in this Policy.
Business Changes
In the event we go through a business transaction such as a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be among the assets transferred and any such acquirer of us or our assets may continue to collect, use and disclose your Personal Information as set forth in this Policy.
Where Required or Authorized by Law
We may also disclose your Personal Information where authorized or required by law. For example, we may disclose your Personal Information to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel.
Except as described in this Policy or in other situations where we have otherwise provided you with prior notice and, to the extent required by applicable law, obtained your consent, Mitchellwood will not share your personal information with third parties.
Mitchellwood takes reasonable steps to protect your Personal Information. We have implemented reasonable physical, technical and organizational measures to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information. As well, we will use care when destroying or disposing of Personal Information to prevent unauthorized access, use or disclosure of any Personal Information. Our employees and independent contractors with access to Personal Information are required to respect the confidentiality of such information.
The Platform includes links to external websites. Once you leave the Platform, this Policy does not apply. We are not responsible for the privacy practices, collection of Personal Information, or content of external websites. We are not responsible for any lost, stolen, or compromised user IDs, passwords or for any activity on your Account via unauthorized password activity. You should take steps to protect against authorized access to your account by, for example, choosing a robust password and keeping your password private. We are not responsible for any failure by you to secure your own devices and their access to the Internet or your use of public, unsecured networks.
Personal information collected by us is maintained in accordance with applicable privacy legislation and our retention policies and practices. However, once you deactivate and remove your Account or stop using your Account for a period of twenty-four (24) months, we will delete any Personal Information on such Account immediately or after such period as may be required for retention by applicable laws.
All Personal Information in your Account is accessible by you. You can make changes to certain Personal Information that we hold about you, such as your contact information, by editing the information in your Account. You are responsible for keeping the Personal Information in your Account up to date and accurate. Certain minimum Personal Information must be input in your Account in order to use the Platform’s services. For example, you must share your first and last name and your email address with us.
You can obtain access to, verify or correct the accuracy and completeness of your Personal Information in our possession and control. In appropriate circumstances, we will amend the information. It is your responsibility to provide any updates to your Personal Information to us in writing.
You may request access to your Personal Information and/or correction of that information by contacting us in writing at the contact information noted below, with sufficient detail to enable us to identify the Personal Information being sought. When you contact us, we may ask for further information to confirm your identity and the nature of the information being sought.
After we receive your request for access to Personal Information, we will provide you with an estimate of when you can expect a response. In some cases, we may need additional time to respond to a request, in which case we will provide you with written notice of the extension. Please note that in some cases, we may not provide access to Personal Information that we hold about you, such as where the denial of access is authorized by law. There are also cases where we may be legally required to refuse access to Personal Information. If we deny your request for access to Personal Information, we will advise you of the reason for the refusal, and will provide the name, title, and contact information of the designated person who can address the refusal.
We may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.
Those who choose to use or access the Platform, Services or Content from outside Canada do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Notwithstanding the foregoing, and recognizing the global nature of the Internet, each user shall comply with all local rules regarding online conduct and submission of acceptable materials. This Policy shall be governed and and construed in accordance with the laws of the Province of British Columbia and the federal laws of Canada applicable therein, without regard to its conflict of laws principles. You and Mitchellwood agree to submit to the exclusive jurisdiction of the courts of British Columbia situated in the city of Kelowna with respect to any claim, proceeding or action involving the violation of this Policy, provided that Mitchellwood may seek and obtain injunctive relief in any jurisdiction in any court of competent jurisdiction.
Mitchellwood may update this Policy from time to time by posting a new version of the Policy on the Platform, including on the App. Our collection, use, disclosure, and retention of your Personal Information will be governed by the version of the Policy in effect at that time. We suggest that you review this Policy periodically.
Questions or concerns regarding this Policy, including the collection of your Personal Information, can be directed to the Mitchellwood Privacy Officer, who is responsible for ensuring our compliance with this Policy. You can contact the Privacy Officer at info@juniormininghub.com.
We take any complaint about our privacy practices seriously. We will investigate all complaints. If we find a complaint justified, we will take the necessary steps to resolve it. The complainant will be informed of the outcome of the investigation regarding any complaint.
If you are not satisfied with our response to a complaint, you may have options to exercise various complaint procedures, including with the relevant Privacy Commissioner (if you are based in Canada) or regulatory authority (if you are based outside of Canada).