PRIVACY POLICY
Akashic Communications Corp. (“the Company”, “we”, “our”, or “us”) is a corporation incorporated under the laws of British Columbia, Canada. We are committed to respecting your privacy and protecting personal information in accordance with:
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British Columbia’s Personal Information Protection Act (PIPA)
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Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
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and where applicable
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The EU General Data Protection Regulation (GDPR)
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The UK Data Protection Act (2018)
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This Privacy Policy explains what information we collect, use, disclose, store, and how we protect personal information through the GEMS Unearthed website (www.gemsunearthed.com) (the “Website”).
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Please read the Privacy Policy carefully before you start to use the Website. By using the Website or by clicking to accept or agree to the Terms of use then this option is made available to you, you accept and agree to be bound and abide by the Privacy Policy. If you do not agree to the Privacy Policy, you must not access or use the Website.
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By using the GEMS Unearthed website and in places where you submit information, you confirm that you understand how that information will be used in accordance with this policy and that you consent to our use of that information as set out in this Policy.
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1. Scope and Application
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This Privacy Policy applies to:
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Visitors to the Website
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Individuals who voluntarily provide personal information through the Website
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Individuals participating in the project described on the Website
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Individuals who use the ‘Nominate’ feature on the Website
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This Policy applies to all personal information collected, used, or disclosed in the course of commercial activities as defined under applicable Canadian and provincial (and where Applicable EU and UK) privacy legislation.
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2. Personal Information Defined
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For the purposes of this Policy, “personal information” means information about an identifiable individual, as defined under BC PIPA, which includes personal details but does not include business contact information used in the regular course of business communications.
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3. Information We Collect
We use information you provide for the sole purpose of delivering the requested product and/or service, to improve our overall performance, and to provide you with information directly related to your participation in the project or requested services. It is possible to browse the Website without providing any personal information.
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The Company does NOT intentionally collect sensitive personal information (such as health, financial, or demographic data). If such information is provided, it will only be used where necessary and will be handled with additional safeguards or deleted where not required.
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a) Information Collected Automatically (Passive Collection)
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When you access the Website, we may automatically collect:
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IP address
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Browser type and version
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Device type and operating system
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Referring and exit pages
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Pages viewed and time spent
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Date and time of access
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This information is used for statistical data only to improve the website and service offerings and may be collected using cookies, analytics tools, server logs, and similar technologies.
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b) Information You Voluntarily Provide
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You may voluntarily provide personal information, including:
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Name
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Email address
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Organization or affiliation
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Contact information
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Information submitted through forms, surveys, or participation requests
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Any other information you choose to provide in connection with participation in the project
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c) Information Submitted by Third Parties (Nominations)
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The Website may include a nomination feature that allows third parties to submit information about another individual (“Nominee”). Information submitted through nominations may include a nominee’s name, affiliation, role, or other limited identifying information.
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The Company relies on the submitting party to confirm that they have lawful authority to provide the information submitted, including that the nominee has been informed of the nomination or that the information is publicly available.
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Nominators are instructed not to submit sensitive personal information or detailed contact information unless necessary and lawfully disclosed.
4. Purposes for Collection, Use, and Disclosure
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a) Personal information is collected, used, and disclosed only for purposes that a reasonable person would consider appropriate, including:
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Enabling direct or nominating participation in the project described on the Website
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Communicating with participants or project Nominees
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Responding to inquiries and requests for information
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Administering, evaluating, and improving the Website and project
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Meeting legal, regulatory, or contractual obligations
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The Company does not sell, trade, rent, or commercially disclose personal information to any third parties. Personal information is not used for advertising or unrelated secondary purposes.
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Personal information submitted through a nomination is collected solely for the purpose of assessing eligibility for participation in the project. The Company does not use nomination information for marketing, promotional, or unrelated purposes.
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We are committed to keeping email addresses confidential. If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received through the Website or telephone.
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In compliance with applicable electronic communications laws including Canada’s Anti-Spam legislation (CASL), all emails sent from us will clearly state who the email is from, and provide clear contact information as to how to contact the sender. In addition, the email messages will contain concise OPT-OUT information as to how to remove yourself from email communications so that you receive no further email communication from us.
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5. Consent
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a) Consent for Information Collection
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We obtain consent for the collection, use, and disclosure of personal information as required under BC PIPA, either:
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Explicitly (e.g., form submission), or
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Implicitly, where appropriate and permitted by law (e.g., basic website analytics)
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You may withdraw consent at any time, subject to legal or operational limitations. Withdrawal of consent may limit your ability to participate in the project.
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b) Indirect Collection Through Nominations
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Where personal information is submitted by a third party through a nomination, the Company relies on the nominator’s confirmation that appropriate consent has been obtained or that the information is otherwise lawfully disclosed.
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Where required by applicable law, the Company will seek consent directly from the nominee before collecting additional personal information or confirming participation.
6. Third-Party Applications and Services
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The Website may use third-party service providers, including:
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Website hosting services
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Analytics providers
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Form submission and communication tools
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Database hosts for digital archive of stories
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Digital or printed book collating and printing services
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These third parties may collect, store, or process information on our behalf or independently under their own privacy policies. The Company requires third-party service providers to implement appropriate safeguards; however, their independent privacy practices are governed by their own policies.
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Where required under BC PIPA and GDPR, we take reasonable steps to ensure service providers implement appropriate safeguards.
7. Cookies and Similar Technologies
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Cookies and similar technologies may be used to:
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Support core Website functionality
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Analyze Website traffic and performance
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Improve user experience
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You may control cookie settings through your browser. Disabling cookies may affect Website functionality. Continued use of the Website constitutes consent to the use of cookies as described in this Policy.
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8. Data Retention
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a) Personal information provided is retained only as long as reasonably necessary to:
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Fulfill the purposes and/or product and service offerings identified in this Policy
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Support project participation
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Meet legal or regulatory requirements
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Information is securely destroyed, deleted, or anonymized when no longer required.
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b) Nomination Information
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Personal information submitted through nominations is retained only for as long as necessary to:
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Review the nomination, and
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Obtain consent directly from the nominee where applicable.
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If a nominee does not consent to participate or does not respond within a reasonable period (not exceeding 60 days), the nomination information will be securely deleted.
9. Safeguards
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We use commercially reasonable administrative, technical, and physical safeguard methods to protect personal information you provide to us or we collect against unauthorized access, disclosure, use, loss, or alteration, consistent with BC PIPA’s safeguard requirements. This includes working only with reputable third-party vendors.
While we take reasonable steps to protect information transmitted electronically, email is not a fully secure medium. We encourage users to avoid sending sensitive information via email.
10. Access and Correction Rights
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a) Individuals have the right to:
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Request access to their personal information
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Request correction of inaccurate or incomplete information
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Request removal of their personal information
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Requests must be made in writing and may be subject to identity verification and legal limitations.
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You have the right to correct any personal data that we may hold about your and have a right of access to the personal data that we hold about you under the Data Protection Act 2018. Please email Privacy Officer should you wish to do this identifying in detail the personal data you would like to correct or have access to.
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If you would like to have all personal data that we hold about you completely removed from our records and/or from the GEMS Unearthed Global Digital Archive. You may also email the Privacy Officer to delete any Website registration or memberships and/or to delete any personal information we hold about you from our records.
Please note however, we require certain key information from you in order to provide you with certain services, and if you ask us to removed all or part of such information, you may no longer be able to access the Website or parts of it.
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b) Nominated Individuals
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Individuals who have been nominated by a third party may request access to, correction of, or deletion of their personal information by contacting the Company using the information provided below.
11. International Data Transfers
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Personal information may be stored or processed outside of British Columbia or Canada, including in jurisdictions that may have different privacy laws (see Third-Party vendors). Where applicable, such transfers are subject to reasonable contractual or organizational safeguards.
12. EU Residents (GDPR)
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a) Information Collected Directly
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Where GDPR applies, individuals have additional rights including:
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Access, rectification, and erasure
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Restriction or objection to processing
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Data portability
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The right to lodge a complaint with a supervisory authority
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Individuals may withdraw consent at any time
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Processing of personal data is based on consent, legal obligations, and the Company’s legitimate interests, depending on the nature of the activity. For example, participation-related information is processed based on consent, while basic website analytics are processed based on the Company’s legitimate interest in improving the Website.
The Company does not use automated decision-making or profiling that produces legal or similarly significant effects.
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Individuals also have the right to lodge a complaint with a supervisory authority in their country of residence or where the alleged infringement occurred.
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b) Information Collected Indirectly
Where personal data is collected indirectly through a nomination, the Company will provide the nominee with the information required under Article 14 of the GDPR within the applicable time frame, unless an exemption applies.
13. The Privacy of Minors
The Website is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors/children.
14. Changes to This Policy
This Privacy Policy may be updated periodically. Changes will be posted on the Website with the updated effective date. You should check the Policy from time to time to ensure that you understand and consent to the use of your personal data in accordance with the current version of the Privacy Policy. Your continued use of the Website will signify your agreement to changes.
15. Contact Information
Our Privacy Officer is responsible for ensuring compliance with this Privacy Policy and applicable privacy legislation. Questions, access requests, or complaints may be directed to:
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Privacy Officer
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Michelle Hohn
Akashic Communications Corp.
mhohn@akashiccommunicationscorp.com
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Effective Date: April 2026
