Luma Education Portal

Effective 2019-10-08

We have a big responsibility when you use our services!

That's why we work hard to protect your information and put you in control.

iMatr's Privacy Policy is designed to help our users understand what information and data we collect, why we collect it, and how we put you in control to update, manage and delete your information.

Let's get started

Our platform helps users to investigate, explore and engage Canadians in new political and social democratic ways. Our services include:

  • Information on candidates, elected politicians, organizations, government and the political system

  • Profile information supplied by users, politicians, organizations and government

  • Perspectives on what Canadians think about specific issues affecting their lives, their democracy, governance, the political system and their representative politicians

  • Statistical data on user's historical activities on our platform

iMatr's platform can be used in a variety of ways. For example, a user can sign up with simply an email address and password and use our information resources as a Canadian. With this degree of privilege, a national Canadian perspective is provided for all services. In contrast, our platform may also be used with greater precision. Users can refine their Scope of View and interact and gain information on a local, regional, and provincial or territorial perspective by supplying their relevant location information. By also defining their Zone, users are provided with ward, riding or district privileges.

Across our various Scopes of View, users can adjust their privacy settings to control what we collect and how your information is used.

To help explain things as clearly as possible, we've included examples and definitions of key terms. And if, by chance, there are any questions about this Privacy Policy,
please Contact us.

What information do we collect when users engage our platform?

iMatr collects information to continually improve services to all our users. From determining basics like which language a user speaks, to more complex things like which ads users find most interesting, to which politicians, organizations or government agencies users might like online; the information we collect, and how that information is used, depends on how our users engage our platform and how they manage their privacy controls.

When a user is logged out of our platform, their platform activities may have engaged politicians with our Contact Engine service. IMatr stores the information it collects with unique identifiers tied to the browser or device a user is using, or to the platform activity it is performing. This helps for example, to maintain the dashboard preferences and Scope of View settings of all users.

When you're signed in, we also collect information that we store with your iMatr account, which is strictly treated as personal information.

User supplied information

When a user creates an iMatr Account, by registering their email and password, they provide us with personal information which includes an email address and password. Users can also choose to contribute additional personal information by creating Start Up, Basic, Contact Engine or University/College profiles. Premium Service users, or organizations and governments who are contributors, may also provide payment information linked to their account.

Our platform also collects the content a user creates, uploads, or receives from others when using our services. This includes things like the hosting or linking of an issue, suggestions for issue categories and sub-categories, links, e-Petitions, Smiles, Pokes, or SoCos, a user may create.

Feedback and results provided to our Contact Engine users, provide by politicians, governments and organizations, are also collected.

Categorizing your activity

As a community of users, which includes registered and Contact Engine users, our platform separates user activity and personal information into two domains.

  • Registration

  • The contents of registered user profile vary. Regardless of what level of privilege a user gains as a result of their profile's Scope of View, all user profile information is treated as personal information.

    Sensitive information such as the names, addresses, email address and telephone number of users, not explicitly provided in an e-Petition, or a Smile, Poke, or SoCo to a politician, are treated as personal information.

    All profile information, unless explicitly initiated and used by a user in a platform activity is personal information.

    Contact engine PINs and the user provided mailing address needed to a receive a PIN in the mail, are treated as personal information.

  • Community Platform Activity

  • All elements of a user's profile are treated as personal information until such time, a user chooses to execute a platform activity where the activity is dependent on an element or elements of of a user's profile. For example, in order to engage a local politician in your ward with one of the tools in the Contact Engine Toolbox, iMatr is required to disclose from your profile, your name, address, email, and telephone number, to your chosen politician. Otherwise, how would the politician contact the user reaching out?

    Disclosures such as Smiles, Pokes, SoCos and e-Petition e-Signatures, occur only when there is a user initiated platform activity. In contrast, user's who choose not to engage politicians, organizations or government, with Contact Engine Tool Box activities, all profile information is treated as personal information.

    MyZone selections, are also treated as personal information unless they are used by a user to engage a MyZONE politician.

    User's submitted positions on issues are treated as personal information, unless they are used to engage politicians.

    When it comes to the personal identity of users, for the purposes of displaying What Others Think on various issues, only a user's name and address are treated as personal information. All other profile information is used to generate various Scopes of View.

    A user's MyTacker tags, are also treated as personal information save and except, that they are used by iMatr to generate content relative to a user's chosen tag of interest in a platform activity.

    Other demographic details in a user's profile, without identifying the user, are used by iMatr to provide statistical information to other users, politicians, organizations and government on What Others Think and what's important to Canadians.

    If a user engages our platform to send and receive messages from MyZONE politicians, we may collect browser type information and settings, operating system and network information, and corresponding IP addresses for both the user and politician.

    Users can visit their iMatr account to find and manage activity information that's saved in their account.

Your location information

Valid user location information is an integral part of our platform. iMatr collects information about a user's location, which help identify politicians, organizations and government that fall within the user's chosen Scope of View.

A user's location is determined by one or more of the following: GPS, google's geolocation API, and a users IP address.

The type of location data iMatr collects depends on our user's account and device settings. For example, a user may turn off their device's location setting to on or off. A setting in the off position, does not provide iMatr any location information and greatly diminishes a user's ability to access relevant information on their chosen Scope of View and to perform platform activities

To see what information Google collects when the on setting is used, please check out the  Google Privacy Policy.  Under this setting, iMatr temporarily obtains from Google the user's location so it may serve up to the user, using MyZONE and Google's geolocation API, those political representatives responsible for the user's location.

For users who want to engage politicians with the platform's Contact Engine, the user supplied mailing address and the manner of PIN payment are treated as personal information.

User's may manage their location history by managing their profile account.

Available Public & Private Sources of Information

For iMatr users who are:

  • politicians

  • organizations

  • governments, government agencies or departments

  • university/college student bodies, universities and colleges

our platform collects information about these types of users from publicly accessible sources. For example, if a politician's name appears in a local newspaper, our platform may index that article and display it to other users who have requested relevant content.

iMatr may also collect information regarding these categories of users from trusted partners, including marketing partners who refer to us potential customers of our platform services, and security partners who provide us with helpful information to protect against abuse and loss of platform integrity.

Why iMatr Collects Data

We use data to build better services

iMatr strives to improve our democracy, promote accountable and responsible political dialog, and to provide Canadians a platform to have their say - and to see what others think; all within the context of the politics and government of the day, personally focused through the lens of a user's chosen Scope of View.

Data drives our services

Our user information is used to provide the services our users request, like delivering up important user supplied issues which may fall within iMatr issue categories and sub-categories. We use this information also to perform statistical analyses. For example, this data may tell us which issue is most popular on a particular day.

We also use user information to create the content they request. For example, issues and categories that are important to users can be submitted to iMatr for inclusion within its content.

Maintain & Improve our Services

Our users provide us information to ensure that our services are working as intended with the level of confidence and integrity we expect. For example, tracking server outages and troubleshooting issues that users report, all act to support our content and data model, maintain our infrastructure and invoke needed changes.

Provide Personalized Services

User supplied information customizes and personalizes our services and content to a user's chosen Scope of View. For example, when a user enters in their Start Up profile that they live in Alberta, IMatr uses this information to provide issues and content that concern Albertans and not Nunavut, or some other province or territory.

Depending on the user's profile information, we also supply relevant issues, news and views that relate to any user supplied demographic. For example, if you are a female, personalized content and issues and news regarding females in Alberta can also be provided.

Personal information such as your name, telephone number or address is never shared with content providers or advertisers, although it allows iMatr to perform personalized services, unless a user asks us to do so by performing a platform activity that is reliant on their personal information. For example, a politician may have a pro-choice stand on abortion. A user would like to support the politician with a Smile from their Contact Engine Toolbox.

Platform activities such as Smiles, Pokes, SoCos and e-Petitions, reveal some of the initiator's and receiver's personal information such as their name, address, email, and telephone number; together with their personal view on an issue in the case of Smiles and Pokes, or in the case of a SoCO, for whom a user might vote.

Measure usage and performance

Our platform data is also used for analytics and usage measurement. For example, we can determine which category of issues are important to Canadians by analyzing user visits to our platform. And we can use this data to let politicians and government know what's important to Canadians.

Communicate with users

We use information we collect from our users, like their email address, to communicate with them directly or to provide to users, easy access to their political representatives. For example, a notification may be sent to a user's email or their mobile phone if their appears to be suspicious activity on their iMatr account from a location inconsistent with their MyZone.

If you contact iMatr, we'll keep a record of your information so that we may better help solve the subject of you're reaching out.

Protect our users, our democracy, the public and iMatr

User supplied information helps improve the integrity, safety and reliability of our platform services. This data allows iMatr to detect, prevent, and respond to fraud, abuse, security risks, and democratic tampering, including the detection and remediation of technical issues that could harm our platform, its users and our democracy.

User choices regarding the information we collect and how it's used

Privacy Controls

The key controls for managing a user's privacy across our platform can be found in both the Profile Manager and MyZone. In addition, the Privacy Policy and its definitions, is meant to help users understand what information iMatr collects, what is considered personal information and under what circumstances is personal information is released.

Managing, reviewing, and updating your information

Ad settings

Users can manage their preferences about the ads shown to them by adjusting their Scope of View. For example, if a user does not want to see provincial advertisements from their provincial government, political parties, politicians, and organizations, then the user must broaden their Scope of View to a national or Canada perspective.

Browser settings

Users can also control what information iMatr collects by adjusting their browser settings. For example, if you are using Google, you can configure your browser to indicate when iMatr has set a cookie in your browser.  Browsers can also be configured to block all cookies from a specific domain or all domain names.

Blocking certain iMatr cookies will limit and/or restrict a user's ability to successfully engage our platform. For example, users who turn off Google's location settings, will not be able to use the Google Maps geolocation API. IMatr relies on this Google service in order to locate users within their Zone during Start Up and MyZONE profile set up.

User Accounts

Users can control what others may see about them without the inclusion of their personal information, by adjusting their Start Up, Basic, Contact Engine and MyZONE profiles and settings. For example, users who provide their opinion on an issue are simply known by their non-personal information attributes, as one of many, in particular sample grouping. By example, opinions of males, living in Ontario, are collected from user data supplied by Ontario male profiles. Although this data tells other users, organizations and governments what Ontario males think about a certain issue, this information extracted from the Ontario male user data set, does not name any of the users, nor identifies them within the grouping.

At iMatr, certain platform activities can not occur unless certain personal information is provided by a user wishing to conduct a platform activity. For example, in order to enter into a SoCo, parties to the agreement are required to provide personal information such as their name, address, telephone number, postal code, and appropriate electoral Zone. If a user does not want a politician to see their personal information then the user should not engage in platform activities which require and provide personal information to counterpart users.

Not having personal information in a user profile restricts all Contact Engine platform activities and prevents the unintentional release of personal information.

Ways to review and update your information

  • Dashboard

  • Users can review and update their information by using dashboard platform activities found in MyVoice, MyProfile, MyZONE, and MyTracker.

    For example, if a user deletes their opinion on a particular issue in MyVoice, it will also be deleted from MyTracker, under the user's complete list of opinions given.

  • Platform Activity

  • A user's platform activity can be reviewed and updated within either the module that generated the user information, or in MyTracker. For example, in order to update a user's Basic profile, the Profile Manager would be used, as it generated the user's Basic profile in the first instance.

    Reviewing past platform activity can also be achieved by resubmitting past actions. For example, if a user has already sent a Smile, Poke, or SoCo to a politician, or has previously signed an e-Petition, or given an opinion on an issue, iMatr redirects the user, with a message that the submitted platform activity has already been done, showing the previous submission.

Removing and deleting your information

To delete information tied to an iMatr account, users can:

  • Delete content from specific platform activities

  • Search for and then delete specific items using MyActivity

  • Delete their entire IMatr account

For users looking to amass citizen award points for their platform activities, user's information must remain on our platform for at least the 1 year qualifying period. Temporary content and user information, deleted prior to the qualifying period cannot be used and recognized towards award venues.  Users uninterested in being recognized for their contributions to their society and Canadian democracy, may delete their information at anytime.

In certain cases, iMatr retains data for limited periods when it is required for legitimate business or legal purposes. Users can read about iMatr's data retention periods, to see how long it takes our platform to delete user information.

iMatr takes every precaution to ensure that our platform protects user information from accidental or malicious deletion. For this reason, there may be delays between when a user deletes something and when copies of the information is deleted from our systems.

When users share their information

Many of our platform activities let you share information with other users. How you share your information remains in your control. For example, by knowing what a platform activity does, a user can then decide on whether or not they want to participate in the platform activity and as a consequence, release and share the information related to the platform activity. By example, if a user does not want their personal information such as their name, address, telephone number and email address to be shared with a politician, a government body, or co-eSignatories to an e-Petition, then they should not sign an e-Petition. The validity of any petition, is based on it being signed by verifiable real signatures.

Remember, when you share your information publicly as in an e-Petition, your content may become accessible to the public by search engines.

Users who are signed in and engage politicians, government or organizations, by the nature of their chosen platform activity, may or may not expect to have their personal information such as their name, address, telephone number and email kept private, simply by the nature of the platform activity. For example, a politician in a ward may receive a Smile from a user constituent. The politician may need to release the Smile sender's personal information to other constituents if the politician is questioned about the issue. By example, other constituents may ask a question like, "Who else in the neighborhood supports this action?"

When iMatr shares user information

With user consent

iMatr does not share your personal information with politicians, companies, organizations, and governments outside of iMatr except in the following cases:

With your consent, implied by your chosen platform activity.

Examples of implied consent when using a platform activity include:

  • Displaying a user's registered opinion on an issue in What Others Think or What's Trending without identifying the user's name, street address, telephone number and email address. As part of the data used to create and depict a pie chart, the user's point of view is provided in the data set as a data point, as a consequence of the platform activity.

  • Displaying a user's platform activity as part of a grouping without providing the user's personal information  For example, we share information with our users and the public about which platform activities are popular and display trends of user's activities within various groupings. Without the user's implied consent to disclose this activity combined with the activities of other user's, iMatr would not be able provide the information necessary to show the popularity and data trends of issues to platform users and the public.

Our platform shares personal information outside of iMatr when we have your consent. For example, a platform activity like a Poke, requires that the selected MyZone politician, respond to a user on a particular issue. Without the implied consent by a user to release personal information such as the user's name, address, telephone number, and email address, in the poke platform activity initiated by the user, how would the politician verify that the user is a valid constituent, or equally important, have the necessary personal information to contact the Poke sender with their response or thoughts on the issue.

With user's own site administrators

If you are a politician or user who works for government or an organization that uses services like Google, your domain administrator who manages your account may have access to your browser account and therefore your browser iMatr activity. They may be able to:

  • Access and retain information stored in your browser, such as your IMatr searches

  • View data and statistics regarding your account like how many times you have visited various IMatr platform pages

  • Change your email account used to communicate with our platform

  • Suspend or terminate your email account used to communicate with our users

  • Receive your IMatr information in order to satisfy applicable law, regulation, legal process, or an enforceable judicial request

  • Restrict your ability to delete or edit your iMatr information or privacy settings

For external and payment processing

Our platform provides information to trusted affiliates such as payment processors, payment gateways and credit card providers, in order to process a user's payment request. For example, a user's service request, product code, and payment amount may be provided to a credit card company, or paypal, in order complete the purchase of user requested services.

For legal matters

iMatr will share personal information to outside authorities if there is a requirement by law or if iMatr has a good-faith opinion that access, use, preservation, or disclosure of the information is reasonably necessary to:

  • Comply with any regulations, legal process, or enforceable government request. Information about the number and types of requests we receive from governments can be found in our Data Transparency Report.

  • Protect, investigate and enforce applicable iMatr Terms of Service violations

  • Discover, detect, prevent or address fraud, security, risks to platform integrity, or technical issues

  • Protect against harm to Canadian democracy, the rights, property or safety of our users, the public and iMatr as required or permitted by law.

Should iMatr become involved in a merger, acquisition, or sale, iMatr will continue to ensure the confidentiality of user's personal information and give affected users advance notice before any personal information is transferred or is subject to a different Privacy Policy.

Keeping user's information secure

Security built within our platform

All platform services and platform activities are built with strong security features that continuously monitor and protect a user's information. The information and insight iMatr gains helps detect, and automatically react and block, security risks and threats from ever reaching its users. Should a security risk or threat prevail, the platform will notify users and help guide them through steps to stay better protected.

IMatr works hard to protect all users and its platform from unauthorized access, content alteration, user compromised integrity, and the disclosure and or destruction of information we store. Our security involves not only hardware and software elements, iMatr also includes physical PINs mailed to user supplied addresses.

Examples of some security features include:

  • Encryption protocols for information in transit between users

  • Encryption of your personal information

  • Security features like 2 Step Verification for Politicians, PIN authentication and verification for all Contact Engine users, and the preemptive use of email and SMS notification of suspicious activity

  • Regular review of our information collection, storage and processing software and hardware operating practices, including physical security measures of our facilities, to prevent unauthorized access to our systems

  • Restricted access to personal information by iMatr employees, contractors, and agents who need that information to process it for platform activities and other processing activities in compliance with iMatr's Privacy Policy

  • Implementation of strict contractual confidentiality obligations for anyone with access to user personal information, with serious disciplinary or termination procedures for offending parties

  • Use of security questions in addition to password protection

  • 3 step identity verification for users of Contact Engine platform activities

Data transfers across the internet

iMatr engages servers around the world which complying with certain legal frameworks relating to the transfer of data (EU-US and Swiss-US Privacy Shield Frameworks). Regardless of whether your information is processed outside the country in which you live, iMatr provides the same protections within these other countries as described in its Privacy Policy.

Complaints received by users regarding data transfer issues, are responded to by contacting the person who made the complaint. In order to resolve any complaints, iMatr works with local data protection authorities where user information is stored and where the user's platform activity was initiated.

About this policy, when it applies

iMatr's Privacy Policy applies to all of the platform services offered by iMatr Canada LLC, including third-party sites such Google and advertising services found on the iMatr platform.

This Privacy Policy does not apply to:

  • The conduct of the information practices of other companies, organizations, politicians and governments that advertise iMatr services

  • Services offered by other companies, organizations, politicians and governments, including products or sites that may include iMatr platform activities, displayed to users in browser search results or be linked from our services.

Changes to this policy

This Privacy Policy may change from time to time. A user's rights under this Privacy Policy will not be reduced without a user's explicit consent. If a change should occur, the date the last change was published, including archived versions, are available for a user's review. If a Privacy Policy change is significant, a more prominent notice, including email notification, will be provided to users.


Contact Engine Toolbox

A location within the Contact Engine where registered users, who have created a Contact Engine profile, and have obtained and activated their PIN, are permitted various platform activities to engage politicians with a Smile, Poke, or SoCo.


Are Our users may be Canadian citizens or residents, politicians, organizations and governments. Although they are not users in a strict sense, companies may also be contributors.


Examples of devices include; a computer, tablet, smart phone, and ip service provider. Each device is identified by a unique IP address.

Payment Information

Payment information provided by contributors is treated as confidential and private information, only available to iMatr payment processing staff, third party payment processing agents, payment gateways and iMatr banking affiliates. It includes customer or user name, invoice reference and credit card or paypal information.

Personal Information

Personal information includes private and sensitive information such as: name *, address *, telephone number *, email, user-type, gender, race, age, marital status, religion, education, income range, type of work, health, how you became Canadian, federal and provincial political affiliation, MyZONE politicians selected, opinions and positions on issues and any PIN * obtained from iMatr.

Entries denoted with an asterisk *, are encrypted when stored and decrypted only when required by an user initiated platform activity.

Platform Activity

A platform activity is any action, entry, input, view or request made to iMatr or its platform by a user. Initiated by a user, a platform activity is directed by the sole, unfettered discretion of the user, in their pursuit of platform information.

Platform activities which engage politicians using the Contact Engine Toolbox, require the release of personal information such as the user's name, address, telephone number, email and the user's political Zone. By engaging Contact Engine Tool Box activities such as a Smile, Poke, or SoCo, a user implicitly consents to provide legal authority to iMatr and the platform to release personal information as required, to the intended political recipient of the Contact Engine platform activity.

e-Petitions by their vary nature, also require the release of personal information to the Addressee, applicable MyZone politician, and the e-Signatories of the e-Petition Users who provide their e-Signature to an e-Petition platform activity, implicitly consent to provide legal authority to iMatr and the platform to release personal information such as their name, address, city/town, province, postal code, country, telephone number and date of signature, together with the e-Petition's entire premise.

Opinions on issues, including user's positions on questions, are treated as personal information; with the proviso that opinions and positions may be released on a no names basis in the context of a grouping of users. The platform activity in which a user provides this implicit consent is, What Other Think.

To be clear, the identity of an individual user, who has expressed an opinion within a grouping, can not be released to the public without the express consent of the user.

Express consent for user platform activities is provided by, the implicit consent, contained, and inherent, in the Contact Engine Tool Box activities.

For political candidates and elected politicians, the express consent to release their positions on issues to the public, is provided when political candidates and elected politicians:

  • Respond to a Smile, Poke, or SoCo

  • Provide a response to a user's emailed e-petition.

  • Directly input their opinion or position on an issue by using the platform activity, MyVoice.

The entire premise of the iMatr platform rests on the need and requirement for politicians to publicly voice their positions on issues to their constituents in a transparent and democratic way. Equally, citizens expect the ability and opportunity to let politicians and government know what they think, and what's important to their constituencies. These important democratic principles and requirements are achieved through the various platform activities performed by iMatr users with their implicit or express consent.


A privilege is a level of access or Scope of View a user obtains. Given certain consideration, such as a payment for service, a user is permitted access to services or platform activities unavailable to other users.

IMatr's founding principle of public reciprocity also provides user consideration. When a user contributes no name personal information such as their gender, race, religion, age, marital status, education, income range, type of work, health, how they became Canadian and their federal or provincial political affiliations, users are permitted and are given the privilege to see What Others Think in their like grouping.  For example, by contributing a user type as a non-voter, a user gains the privilege of seeing What Other non-voters Think?

Relevant Content

Relevant content is any public or private information that provides additional information on politicians, organizations, governments or users, or to an issue or question being considered.

Scope of View

A user's profile information in important. It creates a user's Scope of View. It tell iMatr where in Canada a user is, and helps the platform direct issues and News & Views that are relevant to their profile area. Users who do not complete their Start Up or Basic Profiles, can't be located. All that's known under these circumstances is that they a concerned Canadian who is somewhat interested in politics.

To improve their vantage point to see the things that affect their city, town, region or province; including other demographic factors related them, users submit profile information in increase or decrease their Scope of View.

Unique Identifiers

A unique identifier is a string of characters that can be used to uniquely identify a browser, app, or device.  Identifiers vary in their permanence, how they may be accessed and whether a user may reset them.


When a user engages MyZONE, each user creates their own personal Zone. A Zone identifies a user's various political jurisdictions or election areas based on the user's geolocation. The multiple electoral boundaries and areas found in a Zone are used to identify corresponding politicians who represent areas within the Zone. Politicians chosen from the Zone who are of interest to a user, are selected and then stored in the user's account. Collectively, these politicians of interest are referred to as MyZONE for platform activity.

Luma Education Portal

iMatr helps Canadians use democratic technology to be active participants in the digital age, and now students, too, can be at the forefront of the global political arena. iQed offers students the opportunity for dynamic and meaningful engagement while learning about the people, governments, and important issues that make up our political world. The dawn of a new democracy is here.

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