Privacy Policy

Privacy policy ​​for​ NANOOKA INNOVATION INC. operating as (o/a) SHINING COMPASS

Last Updated on March 11th, 2025

NANOOKA INNOVATION INC. o/a SHINING COMPASS, and its subsidiaries and affiliates (“Shining Compass”, “we”, “us”)  respect your privacy. This Privacy Policy is designed to explain how we collect, use, disclose, and protect the personal information of our customers and website users (“You”).By access or using our website: https://www.shiningcompass.com (the “Website”), subscribing for our content, accessing our content, purchasing or using the products and/or services we provide, or otherwise engaging with us on social media (collectively, the "Services"), you signify and indicate that you understand, accept and consent to the practices and terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use the Website and/or Services or submit any personal information to us. You affirm that if you are accessing or using the Website and/or Services on behalf of an organization or company, reference to you shall also refer to any such organization or company and that same shall be governed by this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding personal information. Shining Compass reserves the right to modify this Privacy Policy at any time in our sole discretion. We will alert you to any changes to this Policy by changing the “last updated” date at the top of this Privacy Policy and posting such modifications on our Website. Any changes become effective immediately upon publication on the Website, and you waive specific notice of any changes to the Privacy Policy by continuing to use and access the Website and/or Services. We encourage you to review this Privacy Policy periodically, when you use our Website for any purpose, purchase or use our Services, or engage with Shining Compass on social media or for vendor enquiries. Your continued use of our Website and/or Services will be regarded as acceptance of our practices around privacy and personal information including but not limited to this Privacy Policy, as revised.

INFORMATION THAT WE COLLECT

 We collect a variety of information from you when you visit the Website, make purchases, use or access our Services, or interact with Shining Compass on social media. By accepting this Privacy Policy, you are consenting to our collection, use, processing and disclosure of the information (including but not limited to Personal Information, as defined herein) described below. We will only use your Personal Information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes and to achieve Shining Compass’ legitimate business interests.

 The information we collect may include:

Personal Information: Personal information is 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”). We collect Personal Information when you voluntarily provide it through our Website or when you provide it to us through other means, including but not limited to: email, telephone, mail; or other correspondence; or registering for, purchasing or otherwise accessing our Services; and/or entering into any agreements for our Services.:

The Personal Information that we may collect will depend on the particular Service you request and how you access our Website, and may include (but is not limited to) your full name, contact information, shipping address, email address, telephone number, demographic information, such as your age, gender, or location, and any other Personal Information that you choose to submit to us. You consent to providing Shining Compass with such Personal Information when you submit same to us voluntarily on the Website, when you register for, purchase or otherwise access our Services, or as otherwise provided in this Privacy Policy.

You may also provide Personal Information by participating in various activities associated with the Website, including, but not limited to responding to blogs, contacting us with questions, or participating in group training. Your decision to disclose this Personal Information is entirely voluntary. You are under no obligation to provide your Personal Information, but your refusal may prevent you from accessing certain benefits from the Website or from making purchases, accessing or using our Services.

Non-Personal And Derivative Data: In addition to Personal Information, we may collect non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. 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 accessing a specific Website feature.

We may also collect technical information or derivative data, which is information that our servers automatically collect about a user when they access the Website. This type of information includes, but is not limited to:  your log-in information, your IP address, browser type, the dates and times that you access the Website, and the specific pages you view.. Technical Information and derivative data may also include data collected by third-party service providers, such as advertising and analytics providers, and may include cookies, log data, or web beacons. Cookies are discussed more fully below. Technical information and derivative data collected by third-party service providers generally does not identify a specific individual.

 Financial Data: Financial information is information that is related to your payment method, such as credit card or bank transfer details. We collect financial information in order to allow you to purchase, order, return, or exchange products or otherwise us our Services from the Website. We store limited financial information that you provide to us. To facilitate the operation of our business, financial information is transferred to our payment processor, which may include Stripe, PayPal or another third-party provider (each a “Payment Processor”). All such payments will be governed by the Payment Processor’s terms and conditions and you should review the privacy policies and terms of conditions of use for such Payment Processors to determine how they use, disclose, and protect your financial information. As a courtesy, please read Stripe and PayPal’s global policy here: https://stripe.com/en-ca/privacy and https://www.paypal.com/ca/webapps/mpp/givingfund/policies/privacy-policy

 

Social Networking Data: We may also access and collect Personal Information from social media/networking sites and applications, such as Facebook, Instagram, Linkedin, Twitter, Youtube, or other social media/networking sites or applications not named specifically here. Such Personal Information may include your name, your social network username, location, email address, age, gender, profile picture, and any other public information. If you do not want us to access or collect this Personal Information, please go to the specific social media/networking site and change your privacy settings. This Privacy Policy does not cover your privacy, use of and/or retention of information on social media/networking accounts which are governed by the privacy policies of the third parties that operate these social networks and therefore Shining Compass does not assume responsibility or liability for the manner in which these operators collect, use, disclose, secure or otherwise deal your Personal Information.   

 

Mobile Device Data: If you use the Website or access our Services via a mobile device or mobile application, we may collect information about your mobile device, including device ID, model and manufacturer. We may also request geolocation information, which includes permission to track your mobile device, in order to provide you with location-based Services. We may also request access to certain features on your mobile device, including but not limited to the device’s calendar, camera, contacts, social media accounts, Bluetooth, and storage, etc. We may also send you “push notifications” regarding your account or Shining Compass’ mobile application. If you wish to change our access to any of this information, you may do so by changing your device settings.

 

Other Data: On occasion, you may give Shining Compass additional information, such as to enter into a contest or promotion or to participate in a survey. You will be prompted for this information and it will be clear that you are providing such information in exchange for an entry into such a promotion or survey.

HOW WE COLLECT AND USE YOUR INFORMATION

As described herein, when you visit our Website and/or use our Services, we may collect information that is automatically sent to us by your web browser. This information may include your domain name and your IP address. We may also collect other information, such as the type of browser you use, which pages you view, and the files you request. We also collect information that is submitted by you. This includes information that you provide by filling in Shining Compass agreements, forms and/or other documents (whether on our Website or otherwise), such as information provided at the time of registering to use our Website or Services, or requesting further services. We may also collect information when you report a problem with our Website, search queries on our Website, or otherwise provide information to us. We further collect information from records and copies of your correspondence (including email addresses), if you contact us, and details of transactions you may carry out through our Website and/or Services.

 

We use  information described in this Privacy Policy to better understand how our Website and Services are used, to improve our Website and Services, to offer you certain products and the Services, to fulfill our obligations to you, to customize your interaction with Shining Compass. We generally store your information and transmit same to a third party for processing. However, to the extent we process your data, we do so to serve our legitimate business interests (such as providing you with the opportunity to purchase our goods or the Services and interact with the Website or mobile application).

Specifically, Shining Compass may use the information and data described in this Privacy Policy to:

  1. Create and administer your account;

  2. Deliver products or the Services to you;

  3. Correspond with you;

  4. Process payments or refunds;

  5. Contact you about new offerings and promotions;

  6. Interact with you via social media; and

  7. Send you newsletters or other updates about Shining Compass or the Website;

  8. Deliver targeted advertising;

  9. Request feedback from you;

  10. Notify you of updates to Service offerings;

  11. Resolve disputes and troubleshoot any problems;

  12. Administer contests or giveaways;

  13. Generate a profile that is personalized to you; and

  14. Compile anonymous statistical data for our own use or for a third party’s use;

  15. Assist law enforcement or regulatory agencies as necessary;

  16. Prevent fraudulent activity on the Website or mobile app; and

  17. Analyze trends to improve the Website and Services.

At all times, such above use shall be in accordance with the terms and conditions of this Privacy Policy.

GROUNDS FOR USING AND PROCESSING YOUR DATA

The information Shining Compass collects, uses processes and discloses is primarily to allow us to provide the Services and operate the Website and our business generally,. In addition, Shining Compass may collect, use, and process and disclose Personal Information based on the following grounds:

1.      legitimate business interests of Shining Compass, including but not limited to: communicating with you, improving our Website and/or Services, and providing information or Services that you have requested;

2.      entering into a contract or agreement with you and fulfilling our obligations thereunder;

3.      track and analyze trends and patterns;

4.      to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Website and/or Services;

5.      to respond to questions, comments, surveys, requests, job applications, or complaints that you submit to Shining Compass;

6.      create aggregate information that does not allow you to be personally identified;

7.      to improve our customer relationships and experiences;

8.      to communicate information, such as promotions, newsletters, surveys, contests, etc. if you have consented to receive such from Shining Compass;

9.      meet and comply with legal and regulatory requirements; and

10.   other purposes that are disclosed to you and for which you have consented (which consent may be withdrawn in accordance with the terms of this Privacy Policy).

We may also use your information to contact you about our own goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form),adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails and/or e-mail us at privacy@shiningcompass.com

WHY WE DISCLOSE YOUR INFORMATION

 Shining Compass may share your information (including Personal Information) with third parties in certain situations, such as, to serve our legitimate business interests, to administer the Website and your account,  entering into contracts with you, communicating with you,  delivering the Services, identifying trends, protecting the security of Shining Compass and the Website, and marketing additional goods and services to you. The legal basis for such disclosure is your consent to this Privacy Policy and our own right to protect and promote our legitimate business interests.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclosure Personal Information to: (i) our subsidiaries and affiliates; (ii) 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 Shining Compass’ assets; (iii) to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website/Services improvement and optimization) 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 Privacy Policy; (iv) to fulfill the purpose for which you provide it; and (iv) with your consent.

We may also disclose your Personal Information: (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law; (ii) to enforce or apply our terms and other agreements; and/or (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shining Compass, our customers, or others.

Where we disclose Personal Information to third parties that perform services on our behalf, we will require those third parties to use such information solely for the purposes of providing services to us and to have appropriate safeguards for the protection of that Personal Information. You may separately agree to provide your Personal Information to third parties that provide content and/or offerings to our Website and/or users. If you agree to provide such information to these third parties, then your Personal Information will be subject to their privacy policies in addition to our own.

We may disclose your Personal Information to a third party or parties where you consent to such disclosure or the disclosure is required by law. Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside of Canada, including the United States. As a result, this information may be subject to access requests and legal requirements from governments, courts, law enforcement or regulatory agencies in those jurisdictions according to laws in those jurisdictions. Your submitting of Personal Information or otherwise engaging with our website and/or Services indicates your consent to such transfer, storage and/or processing.

We reserve the right to transfer Personal Information in the event that we merge with or are acquired by a third party. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.

THIRD-PARTY LINKS AND INTERACTIONS

We may use third-party advertising companies to run and manage our ads on web browsers, search engines, social media networks or any similar platforms and that produce ads that appear when you visit the Website, Services or mobile app. These companies may use information about your visit to the Website, use of the Services and other websites that are contained in cookies (as described below) to offer personalized advertisements about goods and services. We cannot control the activities of such other advertisers or websites. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit and learn how you may opt-out of certain practices..

Please note that, at this time, we do not recognize automated browser signals regarding tracking systems, which may or may not include “do not track” instructions.

If you interact with other persons on the Website, Services or mobile app, such as participating in a group chat or a group online course or engaging with Shining Compass or other persons on social media, third parties may have access to some of your Personal Information, including your name, profile picture, and history of interaction with the Website, such as prior comments or posts. When you post information online, your posts and information may be viewed by third parties and such information may be distributed outside of the applicable website or application.

The Website and Services may provide links or pointers to third-party sites. We make no representations or warranties about any other websites that may be accessed from the Website or Services. If you choose to access any such sites, you do so at your own risk. We have no control over the contents of any such third-party sites and accept no responsibility for such sites or for any loss or damage that may arise from your use of them. You are subject to any terms and conditions of such third-party sites. We encourage you to read the policies and terms and conditions of use of third-party sites before interacting with them or making purchases through them. Third party sites may collect. use, transfer and disclose different information and by different methods than Shining Compass.

​TRACKING TECHNOLOGIES AND COOKIES

As you navigate through and interact with our Website and Services, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to our Website/Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website and Services; and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways, that you provide to us, consent to, or receive from third parties. It helps us to improve our Website/Services and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.

A list of such tracking technologies and cookies are below:

Log Files: Similar to other websites, we make use of log files. These files log visitors to the Website. The information inside the log files can include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and the number of clicks. This information is used to analyze trends, administer the Website, track user’s movement around the Website, and gather demographic information. IP addresses and other such information are not linked to any Personal Information.

Web Beacons. Pages of our Website [may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or and for other related Website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Cookies: “Cookies” are text files placed on your computer, to help the website, software, application or otherwise analyze how users use same. We may also use cookies to store certain information. We may use cookies for other purposes, including: to authenticate your identity, to determine if you are logged onto the Website, for personalization, for security, for targeted advertising, or for analysis of the performance of the Website and Services. We use cookies that are not specific to your account but unique enough to allow us to analyze general trends and use, and to customize your interaction with the Website. This information helps us to understand the use of the Website and to improve the Website and Services.

These cookies may track information which includes, but is not limited to: (i) IP address; (ii) how the Website is navigated; (iii) the type of web browser and operating system used; (iv) the content accessed; and (v) the pages of the Website visited.

Social Media Cookies: These cookies allow Shining Compass to track when you have engaged with a social media tool while visiting the Website/Services. For example, we may record that you have “liked” a certain aspect of the Website/Services. The social media application may also share data with Shining Compass that you have permitted the social media application to share. If you wish to change you social media sharing settings, please visit the privacy settings of the applicable social media network.

Third Party Use of Cookies: Some content or applications on the Website and/or Services, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or Services. The information they collect may be associated with your personal information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and/or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

 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. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 Consent to Cookies: In addition, when you first encounter the Website, you will be asked to “consent to cookies.” If you wish to disable cookies, you may do so through your individual browser options. However, this may affect your ability to use or make purchases from the Website or use and access the Services. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites. By continuing to use the Website and not disabling cookies on your browser, you are consenting to the use of cookies in accordance with the terms of this Privacy Policy. 

Email Confirmations: We may receive email confirmations when you open an email from Shining Compass. This allows us to determine if users are responding favorably to our email communications and assist in the improvement those communications.

Other Technologies: Other data technologies may be used that collect comparable information for security, fraud detection, and similar purposes, to give us information about your use of the Website and Services, and to greater improve same.

WEBSITE ANALYTICS

We may partner with third-party analytic companies, including, but not limited to SQUARESPACE ANALYTICS, GOOGLE ANALYTICS, and other third party analytical software providers, to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization). The analytic companies may also use cookies (described above) or other tracking technologies to analyze visitors’ use of the Website, Services or mobile app to determine the popularity of the content, and better understand online activity. If and when we transfer Personal Information to such third-parties, they 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 Privacy Policy. Additionally, in order to access the Website/Services, you must consent to the collection and use of your Personal Information by these third-party analytic companies. You should review their privacy policies, terms and conditions, and contact them directly if you have questions. If you do not want any information to be collected and used by tracking technologies, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

For your benefit, we have include applicable information to a select amount of the policies of these analytic companies below (such being non-exhaustive and for information purposes only, with Shining Compass making no representation or warranty as to the accuracy of the information):

Google Analytics: You may opt-out of having your activity on the Website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics from retrieving information about your visits to the Website. For more information about Google’s Privacy Policy, please visit: https://policies.google.com/privacy.

Twitter: You can opt-out of Twitter’s internet-based ads by visiting: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.

You can learn more about Twitter’s Privacy Policy at https://twitter.com/en/privacy.

Facebook: You can opt-out of Facebook’s interest-based ads by visiting: https://www.facebook.com/help/568137493302217.

You can learn more about Facebook’s Privacy Policy at: https://www.facebook.com/privacy/policy/

Instagram: Learn more about Instagram’s ad policies by visting:

https://www.facebook.com/help/instagram/2885653514995517?locale=en_US&draft=2885653514995517 

You can learn more about Instagram’s Privacy Policy at:

https://help.instagram.com/519522125107875

LinkedIn: Learn more about LinkedIn advertisement policies by visiting link below :

https://www.linkedin.com/legal/ads-policy

You can learn more about LinkedIn’s Privacy Policy at:

https://www.linkedin.com/legal/privacy-policy

PROCESSING YOUR INFORMATION

We may, from time to time, process your Information (which includes Personal Information). The legal basis for this processing is your consent to the processing,  Shining Compass’ legitimate business interests, and to comply with legal obligations. We may process the following information:

  1. Information associated with your account, such as your name, address, email address, and payment information.

  2. Information about your usage of the Website, such as IP address, geographical information, and length of Website access, and what you viewed on the Website.

  3. Information related to your personal profile, such as your name, address, profile picture, or employment details.

  4. Information that you provide to us in the course of using the Services.

  5. Information that you post on the Website, such as comments or responses to blogs, as applicable.

  6. Information that you submit to when you contact us.

  7. Information related to transactions with Shining Compass, including any purchase of Services (this information may include contact details and payment information).

  8. Information that you provide when you subscribe to our emails or newsletters, including your email address and contact information.

  9. Any other information identified in this Privacy Policy, for the purpose of complying with legal obligations, or to protect the vital interests of you or any other natural person.

INTERNATIONAL DATA

 We may transfer Personal Information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business. Specifically, our Website is hosted on servers located in the United States of America, primarily on Square Space servers (the privacy policy for Square Space can be found here: https://www.squarespace.com/privacy). To the extent possible, we will obligate such businesses to use this information 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.

To facilitate our operations, we may process, store, and transfer your Personal Information in and to a foreign country, different from that where you live (including the United States of America). Laws in these foreign countries have different privacy laws that may or may not be as comprehensive as Canadian law or the applicable law of your country of residence. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that foreign country may be able to obtain access to your Personal Information through the laws of such country.

By using this Website, the Servers and providing Shining Compass with your information (including your Personal Information), you consent to such transfer, processing, and storage of same.

FURTHER INFORMATION FOR RESIDENTS OF THE UNITED KINGDOM (UK) AND EUROPEAN UNION (EU)

Personal Information may be transferred to our Website servers and/or third-party processors or subcontractors that are located in the United States of America and Ireland. We use SquareSpace Inc, USA and Squarespace Ireland Limited for our website hosting service, which actively participate(s) in the EU-U.S. and Swiss-U.S. Privacy Shield framework. Their privacy policy can be found here: https://www.squarespace.com/privacy.

Legal Basis for Processing. As described above, our processing (i.e., collection and use) of your Personal Information is based on one of a number of legal conditions. Generally, these include: (i) your consent; (ii) the performance of a contract with you; (iii) compliance with a legal obligation (for example, where we are required to disclose personal information to a court or a tax authority); and (iv) our legitimate interests, provided these do not override your fundamental rights and freedoms (for example, where we carry out research and analysis to improve our Website and Services).

Rights of UK and EU Residents. Subject to applicable law, as a resident of the UK or the EU, you may have certain rights with respect to your Personal Information. These rights may include some of the following:

·        to obtain a copy of your Personal Information together with information about how and on what basis that Personal Information is processed;

·        to rectify inaccurate Personal Information;

·        to erase your Personal Information (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);

·        to restrict processing of your Personal Information where: (i) the accuracy of the Personal Information is contested; (ii) the processing is unlawful but you object to the erasure of the Personal Information; or (iii) we no longer require the Personal Information, but it is still required for the establishment, exercise or defense of a legal claim;

·        to challenge processing which we have justified based on a legitimate interest;

·        to prevent us from sending you direct marketing;

·        to withdraw your consent to our processing of your Personal Information (where that processing is based on your consent); and

·        to obtain, or see a copy of the appropriate safeguards under which your Personal Information is transferred to a third country or international organization. 

In addition to the above, you have the right to lodge a complaint with your local supervisory authority, depending on where you have your habitual residence or place of work, or where an alleged infringement of applicable data protection law occurs (for example, the Information Commissioner’s Office in the United Kingdom, contactable at www.ico.org.uk). For the European Economic Area (“EEA”), a list of data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Exercising Your Rights. If you would like to exercise any of the rights described above, please submit a request using the contact details listed below. Please note we will request proof of your identity, and verify such identity in order to protect your Personal Information and ensure compliance with all applicable regulations and policies. In some cases, we may limit or deny requests where permitted or required by law. For example, except where disclosure is required by law, we may decide not to grant access or make revisions where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in any given case, or when the rights of others would be violated by granting the access. Additionally, we may deny a request if we are unable to adequately verify your identity. We reserve the right to charge a fee where permitted by law, including for example, if your request is manifestly excessive or unfounded. We will respond to your requests within the applicable timeframes and consistent with applicable regulations.

International Transfers for UK and EU Residents. Shining Compass is based in Ontario, Canada. As part of the operation of our Website and provision of Services, your Personal Information may be transferred to and stored in the United States for processing. Additionally, any Personal Information that you provide to or that is collected by or on behalf of us may be transferred or accessed by entities around the world consistent with the practices described within this Privacy Policy. The privacy laws in these countries may be less stringent than the laws in your country of residence. In relation to service providers or suppliers, for Personal Information that is transferred outside of the UK and the EEA, we rely on adequate measures (such as the EU Commission-approved Standard Contractual Clauses), which give personal data the same protection it has in the UK and the EEA. If we send your Personal Information to Canada it is protected under Canadian law, which the European Commission has found will adequately protect your information. You may have a right to request additional details about the mechanisms under which your data is transferred outside of the UK and the EEA. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

DATA SECURITY

As stated above, the privacy laws in your country may not be as strict as those in foreign jurisdictions. Please be aware that:

●       We may transfer Personal Information that we collect to locations outside of your country for processing or storing, and the Personal Information may be processed by our personnel or by third-party processors. By submitting your Personal Information, or engaging with the Website and/or Services, you agree to this transfer, storing, and processing. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

●       Information that is provided to Shining Compass is stored on secure servers. We endeavor to have payment information and other sensitive data encrypted to ensure its safety.

●       The transmission of information (including Personal Information) via the internet is never completely secure, and Shining Compass cannot guarantee the security of such information that is sent to us electronically. Your transmission of such information to Shining Compass is at your own risk.

●       Where information that you have provided to us is password protected (such as on your Website account), you are responsible for keeping the login credentials and password secure and confidential. You are exclusively responsible for any breaches of your information that results from your own disclosure of or failure to protect your login credentials and/or password.

 

DATA RETENTION

Shining Compass retains your Personal Information as long as it is needed to conduct our legitimate business purposes, to comply with our legal obligations, until it is no longer necessary for the particular use it was collected, or until you request its deletion. We destroy Personal Information when it is no longer needed. 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 without further notice to you or your consent.

We cannot control the retention policies of third parties. If you wish to have any third parties, including those to whom Shining Compass has transmitted your Personal Information, delete that the Personal Information, you will need to contact the applicable third parties directly. You may request from Shining Compass a list of all third parties to whom we have transmitted your Personal Information.

We may retain usage data (that is, data that is gathered by Shining Compass or third-party analytics companies for the purpose of analyzing the use of the Website) as needed for internal analysis purposes. This type of data is usually retained for a shorter period of time than Personal Information, unless the data is necessary to improve the security or functionality of the Website or Services, or if we are legally obligated to retain such information for a longer period of time.

AGE OF MAJORITY

Our Website and Services are not intended for persons under the age of majority (18 or 19 years as applicable by Law). No one under such age may provide any information to or on the Website or use our Services. We do not knowingly collect personal information from children or persons under the age of majority. If you are under the age of majority, do not use or provide any information on this Website or Services, including your name, address, telephone number, email address, date of birth or any other information like screen name or user name you may use.

SENSITIVE DATA

We request that you do not submit any sensitive data (including your social security number, social insurance number or similar government identifications, personal health information, genetic information, or information related to ethnic origin, religious belief or criminal record) to Shining Compass, via public postings, email correspondence, or any other method. If you do provide Shining Compass with such information, then by doing so you are consenting to our use, storage, transfer, processing and disclosure of this information in accordance with this Privacy Policy.

YOUR RIGHTS TO ACCESS AND RECTIFICATION

You have certain rights with respect to our Personal Information, as outlined below. Note that Shining Compass may charge you a reasonable fee, in accordance with applicable laws, for actions/requests that you ask us to take with respect to your Personal Information. In addition, Shining Compass reserves the right to request that you provide us with evidence of your identity before we take any action with respect to the exercise of your rights regarding Personal Information. We will provide you with access to your Personal Information that is in our possession, subject to certain exceptions, including information that is referenced to another individual’s personal information that we cannot sever, or information subject to legal restrictions that may prevent us from fulfilling your request.

Update Account Information: You have the right to update or change any information you have provided to us if you believe it is inaccurate. To update or delete your information, please contact us at: privacy@shiningcompass.com .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. 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.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. You can review and change your Personal Information by logging into the Website and visiting your account profile page.

Confirmation of Personal Data and Use: You have the right to request that we confirm what information (including Personal Information) we retain about you, and for what purposes. You also have the right to know whether we process your information or deliver your information to third-party processors, and for what purposes. Subject to the restrictions provided in this Privacy Policy, we will provide you with a copy of your Personal Information upon your written request.

Withdrawing 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 using the contact information below. Please note that if you withdraw your consent we may not be able to provide you with use or access to our Website or Services.

Transfer Your Data: You have the right to request that we collect and transfer your Personal Information to another controller, in a commonly used and machine readable format, unless doing so would cause an undue burden to Shining Compass.

Destroy All Data: You have the right to request that we destroy all Personal Information in our possession, and, subject to the restrictions provided in this Privacy Policy and applicable laws, we will destroy such information without undue delay. Such restrictions to the aforementioned right to destruction of Personal Information  include when the Personal Information is required to be kept according to applicable laws, is necessary for the exercise of legal rights, is required for compliance with legal obligations or is necessary for the exercise or defence of legal claims. Such a request to destroy your Personal Information may result in a termination of your account with Shining Compass and/or a restriction on your use and access to the Website.

Processing: You may, in some circumstances, restrict the processing of your Personal Information, such as when you contest the accuracy of such information or when you have objected to processing, pending the verification of such objection. When processing has been restricted, we will continue to store your Personal Information but will not transfer or disclose it on to third-party processors without your consent, or as necessary to comply with legal obligations or protect your rights, the rights of others, or the rights of Shining Compass

Unsubscribe: If you no longer wish to receive electronic messages, marketing communications and/or Services from Shining Compass, you may unsubscribe in the “unsubscribe” link in the e-mail you receive (as applicable), follow the instructions in the e-mail you receive, or contact us at the information listed in this Privacy Policy. Please note that, after you unsubscribe, Shining Compass may still send electronic communications to you in certain limited circumstances, such as to provide you with Website and/or Services notifications, or to provide information that Shining Compass is legally obligated to provide you.

Complaints: If you are an EU resident, you have the right to complain to a supervising authority if you believe we are misusing your Personal Information or have violated any of your rights under this Privacy Policy or applicable law. You may do so in the EU member state in which you reside or have your place of business or in which the alleged infringement took place. If you are located outside the EU, you may have rights under privacy laws in the jurisdiction where you reside.

Further, we do not  sell your data to third parties.

NEWSLETTER AND MARKETING

We offer the opportunity for you to volunteer certain information to us that is used for email and marketing purposes. This information includes, but is not limited to, your name and email. You will have an opportunity to unsubscribe from any future communications via email, but we reserve the right to maintain a database of past email subscribers. We reserve the right to use this information as reasonably necessary in our business and as provided by applicable law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting our business, such as through Facebook ads or Google Pay Per Click marketing campaigns.  We do not sell your Personal Information to third parties.

CHANGES TO THIS PRIVACY POLICY

Shining Compass reserves the right to modify our Privacy Policy at any time, so please review it from time to time. If we make significant changes to this policy, we will notify you here, by email, or by a notice on our applicable Website, so you continue to be aware of the information we collect, how we use it, and under what circumstances we disclose it.

LANGUAGE

HOW TO CONTACT US

If you have any questions regarding this Privacy Policy, or to access your information, please contact our Privacy Officer at: privacy@shiningcompass.com . Please submit full details of your privacy concerns with screen shots , website details and any other incidental details through email.

Nanooka Innovation Inc. , o/a Shining Compass Team located at Ontario, Canada. privacy@shiningcompass.com

The email above is only for serious privacy or terms of service policy concerns and not for intermittent website issues beyond our control.