Privacy Statement
Biomedical Commercialization Canada Inc. Privacy Policy
Last Revised: August, 2025
In this Privacy Policy, “Manitoba Innovates”, “we”, “us”, “our” and “ours” means Biomedical Commercialization Canada Inc., and "you" means (and “your” refers to) anyone who provides personal information to us, and their successors, heirs, administrators, executors and assigns (as the case may be).
Manitoba Innovates provides investment, mentorship, and infrastructure support to help business of all sizes start, stabilize, and grow (collectively, the “Services”). We have adopted this Biomedical Commercialization Canada Inc. Privacy Policy (the “Privacy Policy”) to explain how we will meet our responsibilities with respect to the information you provide to us for the Services. This Privacy Policy applies to both individuals and organizations, from whom we collect personal information through the provision of the Services.
The Services are not intended to be used by minors, and we do not knowingly collect, use, or disclose any personal information from or about minors. By using the Services, you are representing that you are over the age of majority, in your jurisdiction.
The principles that form the basis of this Privacy Policy are interrelated and Manitoba Innovates adheres to all of the principles as a whole. Each principle should be read in conjunction with the accompanying commentary. As permitted by Personal Information Protection and Electronic Documents Act (“PIPEDA”), the commentary in this Privacy Policy has been drafted to reflect privacy issues specific to Manitoba Innovates. We will continue to review this Privacy Policy to make sure that it remains current with exceptions, changing technologies, industry standards and applicable laws.
Scope and application
This Privacy Policy applies to personal information, in any form, collected, used or disclosed by Manitoba Innovates in the provision of the Services.
This Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Manitoba Innovates:
information about an individual that is publicly available and is specified by regulation pursuant to PIPEDA;
personal information that is not collected, used or disclosed, for commercial purposes;
non-personally identifiable information; and
the name, title, business address or telephone number of any person, where collection, use or disclosure of such information is solely for the purpose of communicating with the person about their employment, business or profession (collectively, “Business Contact Information”).
The application of this Privacy Policy is subject to the requirements and provisions of PIPEDA, and any other applicable legislation or regulation. If you reside in the outside of Canada, or in certain Canadian provinces, such as British Columbia, Alberta or Québec, then the substantially similar provincial privacy law of your jurisdiction will apply to our handling of your personal information, rather than PIPEDA. In that case, reference in this Privacy Policy to PIPEDA shall be deemed to include your jurisdiction’s substantially similar privacy law.
Definitions
collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. The form of consent we seek may vary, depending upon the circumstances and the type of personal information. In determining the form of consent, we take into account the sensitivity of the personal information and your reasonable expectations. Consent may be provided directly by you, or by your authorized representative, in accordance with applicable law.
disclosure: Making personal information available to a third party.
employee: An employee of, or an independent contractor to, Manitoba Innovates. The inclusion of independent contractors within the definition of "employee" is for convenience of reference only, and should in no manner imply that such independent contractors are our employees within the meaning of employment legislation or are in an employee-employer relationship with us.
personal information: Information about an identifiable individual, but does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address. Information about corporations is not considered personal information.
Privacy Officer: The person responsible for our privacy monitoring and compliance. For greater certainty, the role and responsibilities of a "Privacy Officer" are analogous to a "Data Protection Officer", as described in the General Data Protection Regulation.
third party: An individual or organization outside of Manitoba Innovates.
use: The treatment, handling, and management of personal information by and within Manitoba Innovates or by a third party with the knowledge and approval of Manitoba Innovates.
Website: The website associated with Manitoba Innovates, manitobainnovates.ca .
Reasons why we collect, use and disclose personal information
Except as set out in this Privacy Policy, we only collect personal information about you with your knowledge and consent. Generally, this means we collect personal information directly from you when you use the Services. Occasionally, we may collect personal information from third party sources, but only when the third party collects the personal information with your knowledge and consent, or where otherwise authorized by the law.
Manitoba Innovates may collect personal information from you for the following purposes:
to provide you and your business with investment, mentorship, and infrastructure support;
to provide you with information that you request from us;
to enroll you and your business in our Start-Up Visa program;
to invite you to networking events that may be of interest to you;
to connect you with individuals, organizations, or programs that might assist you or your business;
to contact you about our other service offerings that may be of interest to you;
to evaluate the success of our service offerings;
in any other way we may describe when you provide the information; and
for any other purpose with your consent, or as required or permitted by law.
Further reference to “identified purposes” means the purposes identified in this section of this Privacy Policy.
Manitoba Innovates may collect the following personal information, depending on what is required to fulfil the identified purposes:
your name and address;
your business’ name and address;
your contact information, including your email address and phone number;
your job title; and
any other personal information you choose to provide to us.
Manitoba Innovates may also occasionally provide you with a survey about your business. Manitoba Innovates anonymizes the results of these surveys and provides them to other survey participants, allowing each participant to anonymously compare their business to other similar businesses who have completed these surveys. Manitoba Innovates does not use the personal information collected from our surveys for any other purpose, except with your consent. If you choose to complete a survey, Manitoba Innovates may collect the following information from you (some of which is personal information):
your salary;
the average salary of employees in your business;
the number of employees in your business;
the country in which your business operates;
the year in which your company was founded;
the industry in which your business operates; and
any other information that may be asked for in the survey, from time to time.
Whenever we collect your personal information, we will indicate the identified purposes to you, orally, electronically or in writing, at or before the time your personal information is collected. People who collect personal information may explain the identified purposes or refer you to a designated person within Manitoba Innovates who can explain these identified purposes, upon request.
Manitoba Innovates will only collect personal information that is necessary for the purposes identified in this Privacy Policy or as otherwise agreed to by you.
We collect no personal information about you unless you choose to provide that information to us. As a limited exception to this principle (and in circumstances separate from reviews and complaints), we may collect personal information without your consent where permitted by PIPEDA and other applicable laws.
You may withdraw your consent to the collection and use of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. You may contact our Privacy Officer about withdrawing your consent (their contact information is below).
Disclosure of personal information
Manitoba Innovates will not disclose personal information for purposes other than those purposes for which it was collected, except with your consent or as required or permitted by law. Manitoba Innovates may disclose your personal information:
to fulfill the identified purposes;
when we have your consent, whether express or implied;
if and when we are involved in a corporate reorganization, merger, or acquisition, or if we otherwise sell or lease all or part of our business;
to meet legal and regulatory requirements; and
where required or permitted by law.
In such circumstances, we will not disclose more information than is required for the purpose for which the information is being disclosed. We will also, whenever it is reasonable and practicable to do so, enter into privacy agreements with third parties with whom we share personal information.
Manitoba Innovates Website
Website Technologies and Data Collection
Our Website may use various technologies, from time to time, to:
help us customize your experience on our Website;
track your use of our Website for advertising, marketing, or promotional purposes;
help us determine whether you opened an email message from us; or
gather information to deliver information about products and services we think may be of interest to you.
Cookies
Our Website uses "cookies", which are small text files placed on your computer or other device when you visit a website. Cookies may store user preferences and other information. Our Website only uses session cookies which are specific to a particular visit and limited to sending session identifiers, so you do not have to re-enter information when you navigate to a new page on our Website. Session cookies are not permanently stored on your device and are deleted when you close the browser. Session cookies are essential to enable you to move around our Website and use its features. You cannot withdraw your consent from the use of these types of cookies.
Information Collected by Automated Means
The type of information we may collect by automated means includes:
your visiting domain name or IP address;
the device, browser, operating system type and screen resolution you use;
information on actions taken at our Website, such as navigation patterns (i.e., pages viewed and downloaded; job postings viewed, etc.) and the date, time, duration and number of times you visited our Website;
the previous site you visited; and
the geographical location (such as the country and city of origin) from where you accessed our Website.
This information enables us to:
customize the services we offer you, to improve our Website;
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; and
show our advertisements on external sites.
Third-Party Analytics and Tracking Tools
When you visit our Website, we may collect certain information by automated means such as through the use of cookies, other automated devices and website tracking tools such as Google Analytics and Google Tag Manager. We use these tools to collect information about how our Website is used. Google Analytics generates statistical and other information about websites by means of cookies stored on users' computers. Google may collect, transfer, store, and process this information on its servers located in the United States.
We also use social media pixels from Facebook, LinkedIn, Twitter, and Instagram for advertising and analytics purposes. These pixels may collect information about your visit to our Website and your interactions with our content for advertising and measurement purposes.
Data Collection Through Website Forms
In addition to automated data collection, we collect personal information directly from you through various forms on our Website. The information we collect depends on which form you complete:
Contact Us Form
We collect: full name, email address, organization name, website or LinkedIn profile, reason for inquiry, message content, and how you heard about us. We also offer an optional mailing list opt-in.
Careers Form
We collect: full name, email address, phone number, LinkedIn profile, information about role interests, preferred industries/sectors, resume upload, and how you heard about us.
Office Space Form
We collect: full name, email address, organization name, partnership status, space preferences, team size, move-in timeline, tour interest, and additional comments.
Event Submission Form
We collect: event details (title, description, date, time, format), organizer information (name, organization, email), target audience, public/private status, registration links, and event images or flyers.
Event Sponsorship Form
We collect: full name, organization name, email address, phone number, sponsorship interests, support type, estimated budget, additional comments, and how you heard about us.
Partnership Form
We collect: organization details (name, contact information, address, website, LinkedIn), industry type, organization type, company description, logo, partnership tier selection, billing preferences, and how you heard about us.
Manitoba Invests Application Form
We collect: full name, email address, company name, partnership status, technology readiness level (TRL), company location, pitch deck upload, and how you heard about us.
Newsletter Signup Form
We collect: email address, first name, organization/company name, interest preferences, and consent confirmations.
Data Storage and Processing
All personal information collected through our Website forms is processed and stored by HubSpot, our customer relationship management (CRM) platform. HubSpot hosts our data in Canada. We may also download and store copies of certain information, including uploaded documents, on our internal SharePoint server for backup and operational purposes.
Email Marketing and Communication Tracking
We use HubSpot and Mailchimp for email marketing and communications. When we send you emails, we may track metrics such as open rates, click-through rates, forwards, and other engagement statistics to help us improve our communications and understand what information is most valuable to our audience.
Third-Party Service Providers
We work with several third-party service providers to operate our Website and provide our services, including:
HubSpot: Customer relationship management, form processing, and email marketing
Mailchimp: Email marketing and communications
Google Analytics and Google Tag Manager: Website analytics and tracking
Social Media Platforms (Facebook, LinkedIn, Twitter, Instagram): Analytics pixels for advertising and measurement
QuickBooks: Invoice processing and financial management
SharePoint: Document storage and backup
All of these service providers maintain their own privacy policies and handle personal information in accordance with applicable privacy laws.
Data Sharing
In addition to sharing with the third-party service providers mentioned above, we may share your personal information with our partners and sponsors to help them provide better services and opportunities to our community members and for event-related purposes, always in accordance with the purposes outlined in section 3 of this Privacy Policy.
Data Retention
We retain personal information collected through our Website indefinitely unless you request deletion. You may contact our Privacy Officer at any time to request deletion of your personal information, subject to any legal or business requirements that may require us to retain certain information.
Your Rights and Choices
You have the right to:
Access the personal information we have collected about you
Request correction of inaccurate information
Request deletion of your personal information
Withdraw consent for email communications at any time by clicking "unsubscribe" in any email or contacting our Privacy Officer
Opt out of certain tracking technologies where technically feasible
To exercise any of these rights, please contact our Privacy Officer using the contact information provided in section 10 of this Privacy Policy.
Security of personal information
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to help prevent any unauthorized access, disclosure, copying, use, or modification of personal information. We store all information which is under our control on secure servers which are behind firewalls.
Manitoba Innovates employees are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained, and employees receive training about our privacy practices. Safeguards are in place to help ensure that the information is not accessed, disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered.
We maintain reasonable controls, schedules and practices for personal information management retention and destruction. Personal information that is no longer necessary or relevant for the identified purposes is destroyed, deleted, or erased, unless required to be retained by law.
We protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the personal information and the purposes for which it is to be used. We only select service providers that protect personal information in a manner that is comparable to the protection we provide under our own privacy policies.
Access to your personal information
You may access an account of your personal information which is under our control, and which has been collected, used or disclosed for a commercial purpose, by sending a written request to our Privacy Officer. Manitoba Innovates may advise you in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days, or advise that the request for access is subject to an extension as authorized by PIPEDA.
To protect your privacy, you may be required to provide sufficient identification, in order to permit us to account for the existence, use and disclosure of certain personal information and to authorize access to such information. Any such information will only be used for this purpose.
We may not be able to provide personal information to you if doing so would violate the privacy of a third party or if certain personal information is subject to legal privilege, contains information proprietary to us or a third party, is too costly to retrieve, or cannot be disclosed for other legal reasons. If we are unable to provide access to all or part of your personal information, we will explain our reasons for such a decision.
Where you have been provided with access to your personal information which is under our control, you shall be able to challenge the accuracy and completeness of your personal information and have it amended as appropriate.
Personal information that is disclosed to third parties by us will be subject to the general laws applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, we may not be legally permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, we will provide an account of the collection, use and disclosure of personal information and, where reasonably possible, we will state the source of the personal information. In providing an account of disclosure, we will provide a list of organizations to which we may have disclosed your personal information when it is not possible to provide an actual list.
Challenging compliance with privacy laws
All questions or concerns regarding our privacy practices should be directed to our Privacy Officer.
We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures. We will inform you of the outcome of the investigation regarding your complaint.
Language
You and Manitoba Innovates have requested and agree that this Privacy Policy and all documents related to this Privacy Policy be drawn up in English. Les parties ont demandé que cette convention ainsi que tous les documents que s'y rattachent soient rédigés en anglais.
Contact Us
If you have any questions or concerns about this Privacy Policy or about our information handling practices, please contact our Privacy Officer at:
Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/.