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1. Collection and Use of Personal Information

a) Direct Collection of and Our Use of the Personal Information

We collect the following Personal Information directly from you and use it the ways described below:

How & What We Collect	How We Use It
Registering an Account: When you register for an account on our website, https://www.mccqbank.com, or any related website controlled by us (“Site”) or on any mobile application controlled by us (“App”), we will collect your: email address, year of graduation, university you attended, and the password you create Please note that in the event you use your Google or Apple account to sign into our Site or App, Google and Apple’s privacy practices are outside the scope of this Policy. Please review Google’s and Apple’s respective privacy policy for more details. Mentorship: When you book mentorship appointments, we will collect your: email address You may also provide us other Personal Information when talking with our mentors.	We use your: email address and password to allow you to log-into our Site or App, which provides you access to certain features, such as booking mentorship appointments. We use your university and year of graduation to create an aggregated demographic profile of our users for our own internal, non-commercial purposes. If you provide us with other Personal Information through our Mentorship services, we will use it to respond to you and provide mentorship advice tailored to that Personal Information.
Social Media: If you engage with our online communities, including interacting with our social media pages, submitting content, leaving reviews, or otherwise entering information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with us, we may collect certain Personal Information about you, including your social media public identification and any other personal information you provide us.	We use this information to validate your identity and respond to your inquiry.
Support and Customer Service: If you contact us through our Site, through our App, by email, or through any other method, we will collect your: contact details; and may collect additional Personal Information that you provide us.	We use this information to validate your identity and respond to your inquiry.
Newsletters and Marketing: If you subscribe to our newsletters or marketing communications, we will collect your: email address; or other contact information.	We will use this information for the purpose of sending you our newsletter or marketing content. You may unsubscribe from receiving these communications at any time. This will not affect our use of your Personal Information in relation to our other Services.
Payment Information: We have engaged a third-party payment processor to process payments made by your or on our behalf. Our third-party payment service provider will collect your: payment information. The third-party payment service provider will only use such information for the purpose of processing the payment to us.	Handled entirely by our third-party provider. We do not store this information ourselves.

How & What We Collect	How We Use It
Site or App Usage Data: We use Google Analytics to collect your device’s IP address, browser type, browser version, the parts of our Site or App that you visit, the date and time of your visit, the time spent on those parts, unique device identifiers, and other diagnostic data when you visit and use our Site and App.	We use this Personal Information to track and monitor your use of our Site or App. You may opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

b) Automatic Collection of and Our Use of the Personal Information

We collect the following Personal Information directly from you and use it the ways described below:

Cookie Type	Cookie	Cookie Purpose	Duration	Potential Impact if Disabled
Functional These cookies allow the website to remember choices you make and provide enhanced, more personal features.	G_Enabled_IDPS	Allows you to use Google Single Sign On to sign onto the Site.	Two years	You will not be able to sign into the Site with Google Single Sign On.

c) Third Parties’ Collection and Use of your Personal Information

The following third parties may collect and use your Personal Information when you use our Site or App:

Google Analytics: As noted above, our Site and App use Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic.

Google shares its collected information with other Google services, and Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Social Media Plugins: Our Site and App also use social media plugins (“Plugins”) from the following social networks: Facebook, Twitter, Instagram, and LinkedIn. These Plugins are offered by the companies of Meta Platforms, Inc., Twitter, Inc., and LinkedIn Corporation. If you are logged into a social network, these companies may record your use of our Site or App. In addition, if you interact with the Plugins, your Personal Information may be directly transmitted to the respective social media company.

However, the Plugins’ processing of your Personal Information is not covered by this Privacy Policy. For more information, please consult the respective social media company’s Terms of Service and Privacy Policy.

d) Anonymized Information

We may create de-identified or anonymized data from your Personal Information by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you. Anonymized data is no longer considered Personal Information and is not subject to this Privacy Policy.

2. Sharing Your Personal Information

We do not sell Personal Information, and we will not share your Personal Information, except:

a) To third party service providers performing clearly defined sub-processing functions on behalf of us, including the following types of third parties:

(i) Mentors, for providing our mentorship services to you
(ii) Payment processors, for processing your payments to us
(iii) Email hosting providers, for communication with you
(iv) Scheduling software for recording the date and time of your mentorship appointment, for our mentorship services
(v) Videotelephony applications for communication purposes between you and the mentor

b) where we are required by law to disclose Personal Information; in connection with any legal proceedings or prospective legal proceedings

c) in order to establish, exercise, or defend our legal rights

d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling. We will require any person or entity to whom we provide your Personal Information to agree to comply with our then current Privacy Policy. We will take reasonable commercial efforts to ensure that they comply with our Privacy Policy.

In addition, since we do not collect information from visitors who are under 14 years old, no such information is disclosed to third-parties.

3. Safeguarding Your Personal Information

To protect your Personal Information against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we and our sub-processors use appropriate physical, technical, and organizational security measures.

4. Retention of Your Personal Information

We do not hold onto your Personal Information indefinitely. Instead, our default is to retain your Personal Information until it is no longer necessary for the purposes for which it was collected. Such default is typically three years after our last communication. We may also hold onto certain types of information for longer periods to comply with legal obligations.

5. Children’s Personal Information Policy

Our Site and App are meant for adults and those who have reached the age of majority as defined by the laws of Ontario. The Services are not meant for individuals under the age of 16. We do not knowingly collect or retain any Personal Information about visitors under the age of 16. If we learn that we have collected or received Personal Information from a child under 16, we will promptly delete that information from our database and all other media.

6. Links to other Websites

Our Site and App may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

7. Do Not Track

We do not track our Site’s visitors over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

However, third parties that have content embedded on our Site such as social media plugins may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific part of our Site from a certain IP address.

8. Your Privacy Rights

You have the following rights with respect to the Personal Information that we process:

Right to be Informed: right to be informed about the collection and use of your personal information.
Right to Access: The right to be provided with a copy of your Personal Information held by us.
Right to Correct: The right to ask us to correct your Personal Information if it is inaccurate or incomplete.
Right to Withdraw Consent: The right to withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
Right to File a Complaint: The right to complain about the breach of your rights.

To exercise your rights or to determine what rights you may have, you or your authorized agent may reach out to us by email at marketing@mccqbank.com.

If you’re not satisfied with our response, you may complain to the Privacy Commissioner of Canada. If for whatever reason you’re unsure of how to contact the Privacy Commissioner, let us know, and we’ll endeavor to help you.

9. Data Retention and Your Rights to Access and Correction

Depending on your request and the method of contact, we may ask you for Personal Information that we consider necessary to verify your identity to prevent fraud. This information may include name, contact information, and information related to your relationship with us, but the specific information requested may differ depending on the circumstances of your request.

We will respond to your request as soon as possible, ideally within 30 days.

a) Your Right to Access

The disclosure of information will be provided at a no cost to you. However, we reserve the right to decline your request where the information requested:

would disclose Personal Information of another individual or of a deceased individual, and your information is not severable from the other’s information
is subject to legal privilege
does not exist, is not held, or cannot be found by us, could reasonably result in serious emotional harm to the individual or another individual, or serious bodily harm to another individual
may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions

In addition, we reserve the right to decline your request if the request is manifestly unfounded or excessive, and we quote you a reasonable fee for responding to your request, but you refuse to pay that fee.

Lastly, we also will not disclose the Personal Information where applicable law would bar such disclosure.

b) Your Right to Update or Correct Your Information

You may in most cases correct or update your Personal Information by instructing us to do so on your behalf.

10. Region-Specific Privacy Rights

a) Québec Act

In order to comply with Québec law for our Quebec visitors, in addition to the common rights granted to all visitors of the Website who provide us with Personal Information, the Québec Act provides the following additional rights to individuals in Québec:

Right to De-Indexation: You have the right to ask us to de-index your Personal Information, as permitted by law.
Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances.
Right to data portability: Where technically feasible, you have the right to receive the Personal Information that you have provided to us, in a structured, commonly used technological format, and you have the right to transmit that information to another person or body authorized by law to collect that information.
Right to be informed of a decision based solely on automated processing: If applicable, you may also ask for the opportunity to submit observations to a member of our staff who is in a position to review the decision.
Right to lodge a complaint: You have the right to lodge a complaint with your commissioner.

b) General Data Protection Regulation (GDPR)

We rely on the following legal bases to process your Personal Information:

you have provided your consent to the processing of your Personal Information
processing is necessary for the performance of our contract with you
processing is necessary for compliance with our legal obligations
processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms

The GDPR provides the following additional rights:

Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Information, as permitted by law.
Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances.
Right to data portability (Art. 20 GDPR): You have the right to receive and transmit your Personal Information in a structured format.
Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Information.
Right not to be subject to automated decisions (Art. 22 GDPR): You have the right to object to decisions made solely through automated processing.
Right to lodge a complaint (Art. 77 GDPR): You have the right to file a complaint with a supervisory authority.

11. Withdrawing or Varying your Consent

Where you have provided your consent to the processing of your Personal Information, you may have the legal right to withdraw or vary your consent under certain circumstances and without retroactive effect. To withdraw or vary your consent, if applicable, contact us at marketing@mccqbank.com.

Please note that despite your withdrawal or variation, we may continue to process your Personal Information:

to the extent that we are contractually obligated to do so
to the extent necessary to enforce any contractual obligations you may have with us
for any other legitimate purpose (including fraud prevention) permitted by applicable law

12. We May Change this Privacy Policy

In order to maintain or enhance our Services it might be necessary to change this Privacy Policy from time to time. We reserve the right to modify this Privacy Policy at any time, subject to applicable data protection laws. Please visit the Site from time to time for information on updates to this Privacy Policy.

13. Data Privacy Contact

If you have any questions regarding this Privacy Policy or our privacy practices or our sub-processors, or if you require assistance to withdraw your consent to our sub-processing of your Personal Information or wish to access or correct your Personal Information, please contact us by sending an email to marketing@mccqbank.com or in writing to:

Siskinds LLP, 275 Dundas Street, Unit 1, London, Ontario N6B 3L1.