Our Privacy Commitment to You

 

Last Modified on Mar 9th, 2020

Welcome to LifeLearn Inc. (“LifeLearn”, “we”, “us” and “our” as context dictates). We are committed to preserving the privacy of all individuals, including you (“you” or “your” as the context dictates), who utilize our website and any of its subdomains (including lifelearn.com, lifelearn-cliented.com, sofie.lifelearn.com and lifelearn-ce.com) (our “Website”) to avail communication, collection, payment, content accessing and sharing and other features and benefits (the “Services”). Accordingly, this privacy policy (this “Privacy Policy”) is designed to help you understand how your personally identifiable information (“Personal Information”) is collected, used, stored and disclosed when you engage with us and access the Services.

Before registering, submitting any content or Personal Information, or otherwise engaging with us on our Website, please make sure that you read and understand this Privacy Policy as well as our Terms of Use (together with such other documents, our “Terms”). https://staging.lifelearn.com/terms-of-use/

This Privacy Policy applies to the Personal Information you provide us when using the Services or submitting information to us. In the course of engaging with us, we may also use a third party’s intellectual property, tool or resources (e.g., for payment processing such as Moneris) and such third party’s privacy policy may also apply to you. We encourage you to read and review each privacy policy that applies to you as our Privacy Policy terms may differ from the terms contained in third parties’ privacy policies. Notwithstanding any other sections of this Privacy Policy, LifeLearn shall not be responsible or liable, directly or indirectly, for any damage or loss suffered by you which is caused or alleged to be caused by or in connection with third parties’ privacy policies.

You are under no obligation to provide Personal Information, with the caveat that your refusal to do so may prevent you from using certain portions of the Services. LifeLearn does not collect, use, store or disclose Personal Information without your consent, except as required by law or as set out below.

If you have any objections to the terms in this Privacy Policy, you should not use the Services or provide us with any of your Personal Information, as by providing your Personal Information to us, you will be deemed to have consented to the processing of such data. If you have any hesitations or are unsure about any of the terms contained herein, we invite you to connect with us at the contact details provided below.

 

PART A – COLLECTION OF PERSONAL INFORMATION

Our collection of Personal Information is limited to that which is reasonable under the circumstances, and we only collect your Personal Information with your consent pursuant to our Terms.

  1. Information You Provide
  • Identity Data. We collect the Personal Information that you provide to us, which may include, but is not limited to: (i) basic Personal Information, including your first and last name, date of birth, contact information such as address and telephone number, payment information; (ii) information about your use of the Services; and (iii) analytical information, including, but not limited to, your login data, browser type and version, time zone settling and location, browser plug-in and versions, operating system and platform and other technology on the devices you use to access our Website.
  • Account information. When you use the Services as a registered user, you need to create an account with us. In order to create a registered user account, you will need to provide us with login credentials (which include your email address and password), your name, and certain other information.
  • Communication. You can post comments, leave feedback, correspond with a person on and through our Website. Content, including such comments, feedback, and notes you choose to post through our Website may be occasionally available to the public. You may also contact us via a contact form, email, or by other means (for example, with questions about the Services, for customer support, or to let us know your ideas for new products or modifications to existing products). When you do so, we collect the information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message. Any information that is disclosed in any publicly visible areas becomes public information for both us and other users to use and share.
  • Information about Others. You may decide to provide us third party information, such as names, email addresses, or phone numbers of persons who you would like to utilize the Services (collectively, “Third-Party Data”).

If you use any feature of the Services that allows you to communicate with third parties (such as to refer a third party to the Services or to communicate with them for certain other purposes), either by submitting Third-Party Data to us or otherwise permitting our systems to automatically access Third-Party Data in your possession, you acknowledge and agree that you have the authority of the relevant third party for us to access and use the relevant Third-Party Data and that you have notified these third parties and informed them how their information is collected and used by LifeLearn to provide the Services.

We use Third-Party Data to (i) contact such third party using the Third-Party Data provided, and/or (ii) provide you with an editable template message designed to facilitate communication between you and such third party through the Services. In addition to sending the foregoing communications, we may also send reminders or related messages to you and to third parties on your behalf from time to time where permitted by applicable law. In each case, any such communications sent to third parties using Third-Party Data will provide a means to “opt out” of receiving further communication of the same nature.

  1. Information Collected Passively or Automatically
  • General Usage Data. When you use our Website, we collect certain information by automated means (“Automatic Information”), such as through server log files, cookies (described further below), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to our Website), and embedded scripts (programming code that is designed to collect information about your interactions with our Website, such as the links you click on). Automatic Information will not be published or made public through the Services.

When you use the Services, we may collect user action data using Google Analytics, and technical properties of hardware and software utilized in conjunction with the Services. For example, we may collect the type and model of hardware and/or web browser you are using and the operating system version you are using. When you use the Services, we may also collect information about your location (as described below under the heading “Location”), how long you use the Services for in each session, features you use in the Services, and the actions you take while using the Services.

  • Location. When you use the Services on your computer, mobile device, or other device, the Internet Protocol address (IP address) information may be communicated to us. If we collect and subsequently store such information, it will be in a form that does not personally identify you.
  • Marketing & Communications Data. We collect your preferences in receiving marketing collateral from us and from certain third-parties, in addition to, your communication preferences.
  • Cookies. When you visit our Website, we collect certain information about your activity on our Website, as described below under the heading “Automatic Information”.

For further clarification, cookies are alphanumeric identifiers that are stored on your device with which you access the Services. These cookies allow us to adjust the Services to meet your personal browsing preferences. If your browser is not set to allow cookies, you may not have access to all areas or features of our Website.

The information we collect in this manner may include details about the computer, mobile phone, or other device used to access our Website (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.

Third party vendors may also use cookies to serve you ads based on your visit to our Website. You may opt out of Google’s personalized advertising by visiting “Ads Settings”. You may opt out of other third-party vendor’s use of cookies for personalized advertising by visiting their website, and/or by visiting https://youradchoices.ca/choices/.

The information we collect in this manner is to enhance your user experience. For example, this information allows us to pre-fill form fields as well as provide you with contextual recommendations while using our Website.

 

PART B – USE OF YOUR INFORMATION

We use Personal Information for the purposes stated or implied at the time of collection, including for the following purposes:

  1. Communication

We use the information we collect to contact you for administrative purposes. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem.

We also use the information we collect to send you communications relating to the Services, such as updates on promotions and events, communications relating to products and services offered by us and by third parties, and communications about services we believe will be of interest to you.

You and each user may update your communication preferences anytime by writing us at:

Privacy Compliance Officer, 367 Woodlawn Rd W, Guelph, Ontario Canada N1H 7K9 or dataprotectionofficer@lifelearn.com

  1. Providing the Services

We use the information we collect to operate, maintain, and provide the Services such as enabling access to our Website, customer support or to complete transactions, which may include sharing your information with third parties who are stakeholders in the Services (e.g. the execution of a payment transaction or provision of a product offering). We also may provide a report detailing relevant information to an administrator who has granted you access to the Services pursuant to a purchased license or subscription or to a licensor whose content may be accessed by you through the Services.

  1. Analytics and Product Development

We use the information we collect to analyze data usage trends and preferences in order to improve the accuracy, effectiveness, security, usability or popularity of the Services. Certain third parties whose tools are utilized (e.g. Google Analytics) involving technologies described earlier (cookies, tags, beacons) to help us obtain information and drive certain functionality and improvements require such third parties to collect and storage such information (in accordance with their own privacy policies).

  1. Customization

We use the information we collect, such as device identifiers, to learn how users interact with the Services in order to personalize the content of the Services and improve the performance of our Website.

  1. Legal

We use information we collect to comply with relevant laws or, defend our legal rights, and enforce our Terms.

 

PART C – ANTI-SPAM

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. This consent is sought by LifeLearn and you can contact us at 1 (800) 375-7944 or Privacy Compliance Officer, 367 Woodlawn Rd W, Guelph, Ontario Canada N1H 7K9 or dataprotectionofficer@lifelearn.com. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message.

Should you decide to opt out of receiving marketing communications from us we will process the request within 30 days. However, even if you have opted out, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the products or services we provide to you, or if you contact us with an inquiry.

Opting out of receiving marketing communications from LifeLearn will not opt you out from our business partners; you will also need to follow their opt out process.

 

PART D – CHILDREN’S ONLINE PRIVACY PROTECTION

Our Website and Services are not intended for use by persons under 18 years of age. We do not knowingly collect or use any Personal Information from any persons under 13 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such Personal Information from our database.

 

PART E – TRANSFERS AND DISCLOSURES OF PERSONAL INFORMATION

Other than as disclosed in this Privacy Policy, we will not disclose Personal Information to any external organization without your consent unless we are required or permitted to do so by law, including in the event of a corporate amalgamation, reorganization, change of control or sale.

Your Personal Information may be stored, processed or otherwise used by us, our affiliates, our partners or our service providers, both inside and outside of Canada. As a result, that country’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws. Whenever we use other organizations to provide support services, they will be required to implement proper security measures to safeguard Personal Information, comply with the same obligations as those required of LifeLearn and to allow us to audit them for compliance.

LifeLearn may share your Personal information with business partners who provide our services as well as their own applications and services.

In the event of a Merger or Acquisition, LifeLearn’s Privacy Policy will be reviewed and updated. Where appropriate, Personal Information will be transferred to the controlling entity.

 

PART F – SECURITY AND RETENTION

We take all reasonable steps to protect the security and confidentiality of your Personal Information. We protect the Personal Information within our custody or control with appropriate organizational, technological and physical safeguards.

We store Personal Information in electronic and physical files that are secure, and our security measures include secure on-site and off-site storage, restricted access to records and data processing equipment, password protocols, and encryption and security software. We conduct audits and monitor compliance with our privacy practices.

We only retain Personal Information for as long as is necessary for the purpose for which it was collected. When we no longer are required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the Personal Information we hold for a period of time that is longer than that for which we might otherwise hold.

 

PART G – CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time as we add new products and services, as we improve our current offerings, and as technologies change. If we make a change to this Privacy Policy this will be reflected in the above Last Update date. We encourage you to check back periodically to see if we have made any changes. If we make any material or substantive changes in this Privacy Policy, we will notify you by posting a clear and conspicuous notice of these changes on our Website and in this Privacy Policy.

 

PART H – ACCESS, CORRECTION AND ACCOUNTABILITY

We will strive to keep all Personal Information in our files complete, up-to-date and accurate and need your assistance in doing so.

Any questions, comments or concerns relating to this Privacy Policy, and any requests to correct, access or remove Personal Information collected during your use of the Services, should be directed to the Privacy Officer at:

Attention: Chris Auber

Email: dataprotectionofficer@lifelearn.com

Telephone Number: 1 (800) 375-7944