PRIVACY NOTICE
Last updated July 19, 2022
This privacy notice for Enjoy Canada Life (“Company,” “we,” “us,” or “our“) describes how and why we might collect, store, use, and share (“process“) your information when you use our services (“Services“), such as when you:
- Visit our website at https://enjoylivingcanada.com/ or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you disagree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please get in touch with us at info@enjoycanadalife.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Enjoy Canada Life and the Services, your choices, and the products and features you use. Click here to learn more.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not accept any communication from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your data only when we have a valid legal reason. Click here to learn more.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Click here to learn more.
How do we keep your information safe? We have organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here: __________, or by contacting us. We will consider and act upon any request by applicable data protection laws.
Want to learn more about what Enjoy Canada Life does with any information we collect? Click here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
The personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide us when you register on the Services, express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You.
The personal information we collect depends on the context of your interactions with us and the Services, your choices, and the products and features you use. The personal information we collect may include the following:
- names
- email addresses
- mailing addresses
- usernames
- passwords
Sensitive Information.
We do not process sensitive information.
Social Media Login Data.
We may allow you to register with us using your existing social media account details, like your Facebook, Twitter, or other social media accounts. If you write this way, we will collect the information described in the section “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, Location, information about how and when you use our Services, and other technical details. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings)
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this data may include your IP address (or proxy server), device and application identification numbers, Location, browser type, hardware model, Internet service provider and mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data, such as information about your device’s Location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current Location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by turning off your Location setting on your device. However, if you opt-out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account and keep your budget in working order.
- To save or protect an individual’s vital interest. We may process your information when necessary to keep or cover an individual’s vital interest to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
This section applies to you if you are in the EU or UK.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may depend on the following legal grounds to process your personal information:
- Consent. We may process your information if you have permitted us (i.e., permission) to use your data for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Legal Obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your data for a particular purpose or in situations where your authorization can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and support cannot be obtained in a timely way
- For investigations and fraud detection, and prevention
- For business transactions, provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be the victim of financial abuse.
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information, the group is suitable for purposes related to investigating a breach of an agreement or an infringement of the laws of Canada or a province.
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If an individual produced it during their employment, business, or profession, the collection is consistent with the purposes for which the information was created.
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In Short: We may share information in specific situations described in this section and with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs, we may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). Please refer to this link to learn more about Google’s Privacy Policy. We obtain and store your Location on your device (“cache”). You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or are under common control.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise our Services but are not affiliated with our Services.
The Services may link to third-party websites, online services, or mobile applications and contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. Including a link to a third-party website, service, or application does not imply our endorsement. We cannot guarantee the safety and privacy of the data you provide to third parties. This privacy notice does not cover any data collected by third parties. We are not responsible for any third parties content or privacy and security practices and policies, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Our Cookie Notice sets out specific information about how we use such technologies and how you can refuse certain cookies.
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Services allow you to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned but will often include your name, email address, friends list, profile picture, and other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes described in this privacy notice or otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend reviewing their privacy notice to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will need us to keep your personal information for longer than the period users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
You have certain rights under applicable data protection laws in some regions (like the EEA, UK, and Canada). These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv), if applicable, to data portability. In certain circumstances, you may also have the right to object to processing your personal information. You can make such a request by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section below.
We will consider and act upon any request by applicable data protection laws.
Suppose you are located in the EEA or UK, and you believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and implied license, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent anytime by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or by updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages necessary for your account’s administration and use, respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some data in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers, mobile operating systems, and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized at this stage. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information provided below.
If you are under 18, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To ask about removing such data, don’t hesitate to contact us using the contact information provided below. Include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
E. Biometric information | Fingerprints and voiceprints | NO |
F. Internet or other similar network activity | Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
G. Geolocation data | Device location | YES |
H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video, or call recordings created in connection with our business activities | NO |
I. Professional or employment-related information | Business contact details to provide you with our services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
J. Education Information | Student records and directory information | NO |
K. Inferences are drawn from other personal information | Inferences are removed from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitating the delivery of our Services and responding to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers under a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for business purposes, such as undertaking internal research for technological development and demonstration. This is not considered the “selling” of your personal information.
Enjoy Canada Life has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Enjoy Canada Life has disclosed the following categories of personal information to third parties for a company or commercial purpose in the preceding twelve (12) months:
- Category A. Identifiers include contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
- Category B. Personal information, as defined in the California Customer Records law, includes your name, contact information, education, employment, employment history, and financial information.
- Category F. Internet or other electronic network activity information includes browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements.
- Category G. Geolocation data, such as device location.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?“.
Your rights concerning your data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. Suppose you ask us to delete your personal information. In that case, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know.
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal data that we traded or disclosed for a business purpose;
- the types of third parties to whom the personal data was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
By applicable law, we are not obligated to provide or delete consumer information de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine whether you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification. However, suppose we cannot verify your identity from the information we maintained. In that case, we may request that you provide additional information to verify your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we confirm with you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
- You can designate an authorized agent to request the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly assigned to act on your behalf by the CCPA.
- You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the request submission date.
To exercise these rights, you can contact us or refer to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice to comply with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at __________ or by post to:
Enjoy Canada Life
__________
__________
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: __________.