Privacy

INTRODUCTION

At Life Assure, we are committed to protecting the privacy of the Personal Information of our customers and users of our Digital Services. We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA) and any other relevant privacy legislation governing the protection of personal information.

This Privacy Policy applies to any personal information collected or generated by making inquiries into, applying for, and purchasing or using our products and services. This Privacy Policy also applies when visiting and using our Digital Services. This Privacy Policy will continue to apply for as long as Life Assure holds your Personal Information, including after the termination of any of your product or service agreements with us.

By continuing to use our products and services (including the Digital Services) after the modified version of the policy has been posted, you are accepting the changes to the policy. Accordingly, you are encouraged to review the Privacy Policy frequently. The services that Life Assure provides are constantly evolving and, for this reason, Life Assure reserves the right to update this Privacy Policy from time to time without prior notice to you. Any changes we make to this Privacy Policy will be effective when we post the revised policy on our websites. The date at the top of this policy indicates when it was last revised.

IMPORTANT TERMS

“Personal Information” means information about an identifiable individual. When you make inquiries about, apply for, purchase and/or use Life Assure’s products or services, Personal Information may include things such as:

• contact information (like your name, address, email address, phone number, etc.),
• third-party contact information (like emergency contracts, providing their name, address, email addresses and phone number, etc.),
• demographic information (like your age, sex, gender, marital status, etc.),
• communications information (which includes any information that you communicate to us through any means, directly or indirectly, and that may be Personal Information and that we may, without further notice to you, monitor and record to provide you with the Services and for quality assurance purposes),
• financial information (like banking and credit card information, etc.),
• location information (based on your cellular network coverage, global positioning system (“GPS”) data, and/or network Location Based Services (LBS)), necessary for use of our Products and Services, and
• vital medical information that you share with us (like history of falls, etc.) necessary for use of our Products and Services.

In addition, when you use Life Assure’s Digital Services, Personal Information may include things such as:

• information collected through your activities (typically using tools such as cookies or web beacons), such as device model, browser type, network use, IP address, data transmission information,
• other information such as how you use our Digital Service, including what advertisements you follow and how much time you spend using the Digital Services, and
• certain information about your online activities and social media profiles, such as interests, gender, user name, photos, comments, and content that you have posted/shared, etc.

“Digital Services” means our website, social media accounts, virtual assistant, chatbot, and other online services.

“Life Assure,” “we,” “our,” “us” means Life and Home Security Services Group Inc. and its affiliates collectively.

“User,” “you,” “your” means all customers and users of Life Assure’s products and services, including the Digital Services.

SCOPE AND APPLICATION

Who does this policy apply to?

Life Assure’s products and services are designed for Canadian customers and users. This Privacy Policy applies to all customers and users of Life Assure’s products and services, including the Digital Services (collectively, “User”, “you,” “your).

What information does this policy apply to?

This policy applies to all Personal Information that we collect, use, or disclose about you.

It is also sometimes necessary for Life Assure to collect, use, and disclosure Personal Information about individuals other than yourself, such as your emergency contacts, responders, or the ‘Refer a Friend’ program, and this policy also applies to those individuals.

This Privacy Policy does not apply to information that we de-identify, aggregate, or anonymize in order to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers.

CONSENT

How do we obtain consent?

By using or accessing Life Assure’s products and services, including our Digital Services, and by providing us with your information, you are consenting to the collection, use and sharing of your Personal Information as set out in this privacy policy.

By providing Life Assure with the information and contact details of a personal Responder, you represent that the personal Responder has agreed to act as a responder. Further, by participating in our 'Refer a Friend' program, you confirm that you have obtained the consent of the individual for whose personal information you provide to Life Assure.

Withdrawing consent

You are under no obligations to provide Life Assure with your Personal Information and, subject to legal, business, or contract requirements, you can withdraw your consent to our collection, use and sharing of information at any time by giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products and services. For example, if you choose not to provide us with your address, we will not be able to provide you with any products and services which require Life Assure to send responders to your residence.

COLLECTION OF PERSONAL INFORMATION

How do we collect your personal information?

We primarily collect Personal Information about you from you directly, including in the following circumstances:

• when you communicate with us
• when you request product information or promotional materials from us
• when you apply for a product or service with us
• when you subscribe to communications from us
• when you participate in promotions/competitions or complete a research survey for us
• when you use our products and services, including our Digital Services such as our website and live chat assistant
• when you post content directed at our social medial profile on any social media platform, such as photographs or comments
• when you interact with our social media profile on any social media platform, for example by clicking ‘like,’ ‘follow,’ ‘subscriber,’ or ‘share.’

However, we may also collect Personal Information about you from third parties or public sources. We do so with your consent or as permitted or required by law. For instance, we may collect personal information from the following categories of third parties or public sources:

• credit reporting agencies
• government institutions or regulatory authorities
• public sources such as telephone directories, internet sites, social media platforms, commercially available marketing lists, or government agencies and registries, or public records as defined by applicable laws
• other third parties that you have authorized us to contact

USING PERSONAL INFORMATION

How do we use and share your personal information?

We use your Personal Information to:

• Communicate with you
• Provide you with our products and services
• Keep you informed of new products and services and special offers which may be of interest to you
• Manage and improve your overall experience with Life Assure
• Help us improve and develop products and services that may be of interest to you
• Manage our business and operations, including recordkeeping and internal reporting
• Meet our tax, legal, and regulatory obligations
• Evaluate the effectiveness of our Digital Services, communications, and promotional offers and to improve functionality
• Obtain credit reports on customers
• Collect on debts and outstanding payments

By submitting your information, you authorize Life Assure and its affiliates to communicate with you regarding our products and services, including by email, pre-recorded messages, automated voice dialing, and texts to the email addresses, mobile, and landline phone numbers you provided.

There are also certain circumstances where we may share your Personal Information with third parties (“Authorized Third Parties”), including:

• In order to provide you with our products and services, we may share your Personal Information with third parties such as:

• monitoring centres designated and authorized by Life Assure to provide monitoring services
• third parties that you have authorized us to contact, including emergency contacts or responders
• payment processors
• other third parties that we engage to assist us in providing our products and services

• In order to facilitate and improve the provision of products and services to you and manage our business, we may share your Personal Information with third parties such as:

• IT and communications service providers, testing companies, data management support partners
• record storage facilities
• cloud service providers
• marketing and promotional agencies
• business partners and affiliates

• For credit and collection-related purpose, we may share your Personal Information with third parties such as:

• credit reporting agencies
• debt collection agencies

• Where required by law or applicable regulation in order to meet legal and regulatory requirements, we may share your Personal Information with third parties such as:

• courts
• law enforcement authorities
• other government agencies and regulators
• other parties, if we are required to do so;

Moreover, in the event that Life Assure’s business or assets are sold, in whole or in part, to another company, such transfer of ownership could also include the transfer of your Personal Information to the purchasing company.

When we share your Personal Information with third party service providers so that they can perform certain services on our behalf, these service providers may have access to Personal Information needed to perform their function but are not permitted to share or use such information for any other purpose.

How do we use health information that you have provided?

Life Assure appreciates that health information is highly sensitive and private information. In some circumstances, customers may be asked to share health information, such as your medical history or information regarding certain medical issues, with Life Assure in order to enable us to provide monitoring services. Any health information that you have provided to Life Assure directly (or that a third-party has provided to Life Assure on your behalf) shall be treated as confidential and shall not be disclosed or shared without your consent unless required by law.

SAFEGUARDING PERSONAL INFORMATION

Where will your personal information be stored?

Depending on the nature of the information, your information may be stored at our head office, in computer systems, or in the record storage facilities of Life Assure or our Authorized Third Parties. Service providers and other third parties with whom we share information under this policy, such as the Authorized Third Parties, may perform activities outside of Canada. As a result, Life Assure may use agents or service providers located in the United States (U.S.), to collect, use, retain and process personal information as part of providing services to you. While Life Assure uses all reasonable efforts to ensure that personal information receives the same level of security in the U.S. as it would in Canada, your Personal Information may be subject to the laws of the jurisdiction where it is held. By using our products or services, including our Digital Services, you consent to the transfer of information to countries outside of Canada, including the United States, which may provide different data protection rules.

How will we ensure your personal information is kept safe?

At Life Assure, we take the protection of your personal information seriously. We make reasonable efforts to prevent unauthorized use, sharing, loss and theft of information. We regularly audit our security measures and assess that they remain effective and appropriate. Our employees who have access to your information are aware of the importance of keeping it confidential. Personal Information may be shared with or accessed by our service providers so that they can perform services on our behalf. We are careful when selecting our service providers and require them to have privacy and security standards that meet our requirements. We use contracts and other measures with our service providers to maintain the security of your information and to prevent it from being used for any other purpose other than that for which it was intended. That being said, please be advised that even the best security measures cannot fully eliminate all risks. Accordingly, we cannot guarantee that only authorized persons will view your information and we are not responsible for third-party circumvention of any privacy settings or security measures.

Life Assure’s Digital Services, such as our website, may contain links to third-party sites. Life Assure is not responsible for the information and privacy practices of these third-party sites. We recommend that you read any such third-party site's privacy policy to learn about their information and privacy practices before you provide any Personal Information.

How long will we retain your personal information?

The length of time we keep your information will vary depending on the product or service and the type of information we have. We keep your personal information only as long as reasonably necessary for the purposes we have identified to you, or as required by law. For these reasons, we keep your information beyond the end of your relationship with us. When your information is no longer required, we securely destroy it or make it anonymous.

ACCESS AND CONCERNS

How can you access your personal information?

Customers can access any of their Personal Information retained by us, challenge the accuracy and completeness of such information, and/or request amendments to their information where appropriate by contacting us by email at privacyofficer@lifeassure.com.

What can I do to manage my privacy?

We want to know you better so that we can serve you better while at the same time respecting your choices about how we use your Personal Information. Below is a list of choices you can make to manage your own privacy:

• Manage your social media settings. When you use various social media platforms such as Facebook, Twitter, Instagram, LinkedIn, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share your Personal Information in your social media profiles. Life Assure’s social media activities are bound by the privacy practices and policies of these third-party social media platforms as well as this Privacy Policy. Accordingly, we encourage you to read the applicable privacy notices, terms of use, and related information about how your Personal Information is collected and used on these social media platforms. Depending on your social media settings, certain Personal Information may be shares with Life Assure about your online activities and social media profiles, such as interests, gender, username, photos, comments, and content you have posted/shared, etc.
• Opt-out of receiving promotional materials. If you wish to opt-out of receiving marketing and promotional materials from Life Assure, you may do so by using the “unsubscribe” link in the footer of email communications or by contacting us at privacyofficer@lifeassure.com. Even if you have unsubscribed to marketing communicated, we reserve the right to contact you via phone, email, or mail to give you notices about your account, such as service announcements and administrative messages.
• Enable Do-Not-Track. Most web browsers and some mobile operating systems include a “Do-Not-Track” (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.
• Manage your cookies. We may from time to time provide online ads or send direct mail to customers whom we think may be interested in our products or services. In order to do so, we may collect information about your visits to our website using a “cookie.” You can manage your cookie preferences (including by disabling cookies) in your browser settings at any time. If you want to disable cookies in the Safari web browser, go to Preferences and then to the Privacy pane and choose to block cookies. For other browsers, check with your provider to find out how to disable cookies. If you do disable our cookies in your browser settings, you may find that certain sections of our websites will not work.

Special information for parents

Our products and services, including our Digital Services, are not intended or designed to attract users under the age of 18. We do not collect Personal Information from any person we know to be under the age of 18. However, it is possible that by fraud or deception we may receive Personal Information pertaining to children under the age of 18. If you believe we have collected Personal Information from a person who is under the age of 18, please contact us at privacyofficer@lifeassure.com.

What can you do if you are concerned about your privacy?

If you have any questions, concerns or complaints about this policy or our privacy practices, let us know right away by contacting Life Assure’s Privacy Officer at:

Email: privacyofficer@lifeassure.com
Phone: 1-800-354-5706
Mail: 1760 Main Street, Winnipeg, MB, R2V 1Z7, Canada

If your privacy concerns are not addressed to your satisfaction by Life Assure, you may contact the Office of the Privacy Commissioner of Canada for further guidance:

Website: priv.gc.ca/en
By Phone: 1 800 282 1376 or 819 994 5444
By Fax: 819 994 5424
By TTY: 819 994 6591