LIFELENZ Canadian Privacy Policy

This website (“Site”) and app (App) are owned and operated by Positive Circularity Inc. We are committed to your data privacy. This Privacy Policy details the information we collect about you and how we use it, outlines the steps we take to protect the information you entrust to us, and describes your choices with respect to your information. By registering on this Site and App, submitting any information on our Site or App, or by otherwise accessing or using any of our services, you agree to the terms of this Privacy Policy and consent to the policies and practices described here.

What Information We Collect

We collect certain information from you in order to pursue our lawful business interests, including providing you with access to our services, improving your experience, communicate with you in connection with or regarding our services, and to enhance and improve our website and operations based on insights we are able to obtain from your information, such as whether a given Site layout is convenient and accessible.

We collect only the information necessary to fulfil our lawful business interests and keep your information for only as long as is necessary to fulfil those interests. If you choose not to provide information, we may not be able to provide you with requested services, or information.

We may combine your information with publicly available information and information we receive from or cross-reference with select partners and others. By combining this information, we are better able to communicate with you about our services and promotions and to personalize your user experience; the broader understanding we gain from combining information enables us to more effectively deliver opportunities that lead to user satisfaction, such as relevant communications, tailored suggestions, and special offers.

Information Establishing Your Identity

In order to effectively deliver our services, it is vital that we accurately establish the specific identity of the person who is registering on our Site or our App. In other words, we need to take steps to verify that you are who you say you are, and to be able to distinguish you from other people. We collect certain personal information in order to assist us in establishing your identity, including:

• Name
• Phone number
• Address

Information to Authenticate Your Identity

• Once you have registered as a user, we need to ensure there are measures in place to authenticate your identity when you attempt to access the account you have created. To enable our authentication system to verify that the person attempting to access your account is you, we collect certain information including:
• Knowledge-based information:
• Username
• Password
• Account Information
• Device information:
• Model
• Browser
• IP address

Information Collected in the Course of Using Our Services

Your use of our services may cause us to generate or collect certain information in order to facilitate providing those services and enabling them to be useful, including:

• Scheduling and timekeeping information, such as work schedules and shifts, work offer and shift swap requests and responses, hours worked, estimated earnings and time records
• Work tasks, forms, notices, documents, locations, stations, and notifications, and messages
• Union membership
• Conversations between employees or between employer and employee
• Transactional, usage, and preference information, such as your subscription status, pages visited, types of services accessed, data volumes transferred, shifts offered, response times, number of notifications, advertisements and coupons viewed, and settings chosen
• Other information about actions you perform through our services and that you upload or provide during your use of our services
• Information collected from third parties in connection with your use of the services, including:
• Details of your interactions with other users of our services, such as compliments or complaints about you or your use of our services and/or details of any disputes in connection with our services
• Information about other goods or services you acquired from our business partners or affiliates using our services or in connection with your use of our services (such as confirmation that you made a purchase through our referral program)
• Confirmation of your attendance at a particular shift by your employer (indirectly, this provides location information)
• Personal details necessary to enable us to serve you when you interact with us in person, electronically, or via telephone, such as your name, contact information, date of birth, and billing and credit card details, your camera in order to take a photo avatar (this last point is by choice).
• Information you provide us in connection with goods or services we offer or provide you, that we obtain from you, or that we are considering obtaining from you‍

How We Use Your Information

‍We may use the information we collect from you in the following ways:

Delivering Services, Including:

• Sending you an invitation to use our services (for example, when your employer or potential employer invites you to use our services, we may send you an invitation)
• To provide you with customer or technical support (e.g. by contacting you via email address)
• To facilitate social interactions between you and other users of our services (such as employers)
• To notify you of future changes and improvements to our services
• To provide you with access to the functionality and features of our services (e.g. in order for you to create or update your CV, to request shifts, to find employers or employees)
• To manage our relationship with you and to manage the payment and recovery of amounts payable to us by you

Business and Internal Operations Purposes, Including:

• To analyze data to ensure appropriate service levels are being achieved
• To enable us to operate, maintain and improve the functionality and features of our services
• If you have opted-in to receive advertising or coupons through the LIFELENZ app, to enable third parties to provide you with advertising or coupons in relation to offers for goods or services
• To provide you with other direct marketing communications regarding offers of goods and/or services which may be relevant to you
• To enable us to conduct our business generally, such as notifying our insurers, quality assurance, internal teaching and data processing and handling and in connection with any potential sale of our business and for other purposes which are reasonably necessary in connection with our normal functions and activities
• For our internal management purposes

How We Share Your Information

‍We may share your information in certain circumstances: including:

Affiliated CompaniesWe may share your information with our affiliated companies to fulfil the purposes described in this Privacy Policy, including for data processing, marketing, and administrative purposes.

Vendors and Other Third Parties

We may authorize vendors and other third-party companies to provide certain services. We provide these companies with only the information they need to perform their services and work closely with them to ensure that your privacy is respected and protected. These companies are prohibited by contract from using this information for their own marketing purposes or from sharing this information with anyone other than us. The services provided include:

Information Technology (providers are located in US, Canada & Australia)

• Hosting and operation of the Site and other platforms
• Processing transactions and payments
• Digital marketing and advertising

Marketing, Advertising and Customer Service (providers are located in US, Canada & Australia)

• Marketing or promotional assistance
• Advertising, such as:
• Sending you advertisements and coupons through the LIFELENZ app if you have opted-in to receiving these
• Participating in or administrating our promotions or surveys
• Teaming to provide products, services, or promotions
• Providing customer service
• Third parties who may wish to contact you regarding offers of goods and/or services which you may be interested in, unless you have opted-out of receiving such marketing communications

Legal or Business Requirements, Including:

• Disclosure to comply with the law
• Disclosure to enforce or apply applicable terms and conditions and other agreements
• Disclosure to our legal, financial, or professional advisers
• Disclosure to businesses partnering or considering partnership with us
• Disclosure to third party and its advisers to facilitate financing, securitization, insuring, sale, assignment, bankruptcy, or disposal of all or part of our business or assets
• Disclosure to our insurers for our own insurance purposes
• Protecting the rights, property, or safety of our company, our users, or others
• In connection with a sale or merger

Shared by You, Including:

• Posting to the Site or other public forums, such as social media pages, information you disclose through these services will become public

At Your Discretion, Including:

• At your request
• As described at the point of collection
• With your consent

Automated Information Collection

‍We may collect information about you using automated information collection technologies. Such information may include browser and device information, demographic information and other information provided by you, and aggregated information where we combine your information with the information obtained from other users and other sources. We may use and disclose such information for any lawful purpose.

Cookies and Other Tracking Technology

• We and our service providers use cookies and other related technology to receive and store certain types of information whenever you interact with us, or third parties that use our services, through your computer or mobile device. This information, which includes, but is not limited to: the pages you visit on our site or mobile application, which web address you came from, the type of browser/device/hardware you are using, search terms, and IP address-based geographic location, helps us recognize you and authenticate your access, streamline use of our services by remembering certain details, customize your website experience and make our marketing messages and other communications more relevant.
• The help function of your browser should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued or to not receive cookies at any time. If you set your device to not receive cookies at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of our features.

Device Information

• Depending on your device settings and permissions and how you use our services, we may collect information from each device you use to access our services, such as:
• Location
• IP address
• Details from your address book or calendar connected with your use of our services, such as your attendance at a particular shift or to facilitate social interactions with other users of our Services
• Technical and log information received from your device when you use our services
• LIFELENZ performance or crash logs and other system activity, type of browser, and the third-party site or service you were using before interacting with our services
• Mobile device model name and number, operating system version, and anonymous notification taken (if push notifications are enabled)

Mobile

• If you use a mobile device, your device may share location information (when you enable location services) with our websites, mobile applications, services, or our service providers. We may also track and collect usage data, such as the date and time you use a mobile application to access our servers and the specific information accessed, based on your device number or other identifier. We use this information to improve our services, and provide you more relevant and personalized advertisements, services, and promotions.

Aggregated Information

• We may collect and use aggregated personal information, which does not personally identify you. For example, we may calculate the percentage of our site users who have a particular area code. In the course of aggregating data, we may combine third party data with yours and that of other users.

Cross-Device Identification

• If you use multiple devices to access the Site, we may acquire and utilize capabilities that link your various devices so that content you access on one device can result in relevant advertising on another device. Information we have collected from your different devices may be combined with other information you have provided us. We may use such information to help provide more tailored experiences and consistent services across all of your devices. We also may use this information to help identify when your account is accessed from an unfamiliar device.

Behavioral/Targeted Advertising

• We use cookies and other digital targeting techniques to help determine which of our ads are shown to you on our app. To opt out of this online advertising that utilizes our cookies and digital targeting, please select the menu option in the app. It is accessible through the preferences option.
• We also work with third-party companies that use their tracking technologies (including cookies and pixel tags) on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information over time about your activity on our sites and other sites and your interaction with our advertising and other communications and use this information to determine which ads you see on third-party websites and applications. These technologies and the information collected about you may also be used to track your activity across multiple devices. For more information about this practice and to understand your options including how to opt out of receiving these tailored advertisements, please email privacy@lifelenz.com with any questions regarding your privacy and other concerns with your online experience.
• Please note that even if you opt-out, these tracking technologies may still collect data and you will still see ads, but they will not be targeted based upon the information collected through these tracking technologies.

Promotional Communications

• You may opt out of receiving promotional communications from us at any time by: (i) logging into your online account in the App and updating your preferences; (ii) contacting us by phone, email or postal mail, or (iii) following the removal instructions in the communication that you receive.

Transfer of Information

• If you are located outside of Canada, please take note that information we collect from you may be transferred to other jurisdictions, where the applicable privacy protections may not be as comprehensive as those of your country of residence or citizenship, in order to fulfill the business purposes set forth in this Privacy Policy. By providing us with any information, you consent to your information being transferred to and processed in other countries whose privacy protections may be less comprehensive.

Security of Your Information

• We maintain physical, electronic, contractual, and administrative safeguards to protect your personal information. When we collect or transmit sensitive information such as a credit or debit card number, we use industry standard methods to protect that information. However, you are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

Access and Update Your Information

• In order to keep your personal information accurate and complete, you can access or update some of it in the following ways:
• Review and update your account information, including contact, billing, and shipping information, by logging into your account in the App.
• Email privacy@lifelenz.com with your current contact information and the personal information you would like to access. We will provide you with personal information requested if reasonably available, or will describe the types of personal information we typically collect.

Children's Personal Information

‍Our Site and App are not directed toward children under the age of 13. Furthermore, we do not knowingly collect any personal data from children under the age of 13. No one under the age of 13 should provide any personal data on our Site or App. If a child under the age of 13 has provided us with personal information online, we ask that a parent or guardian email privacy@lifelenz.com .

‍Updates to Privacy Policy

• As we continue to offer you new and different types of content and services, we may modify our information collection, use, or disclosure practices. Should there be a material change to our information collection, use or disclosure practices, it will be applied only to information collected on a going forward basis, and we will update this privacy policy statement and notify you of the changes well in advance of their taking effect.

Data Controller and Contact Information

• The data controller is Positive Circularity Inc, a Company organized and existing under the laws of Delaware US located at Level 10, 315 Montgomery St, San Francisco, CA 94104.
• If you have any questions or concerns about privacy-related issues, you may contact our Data Protection Officer:
• Stephen Kirkby, Level 10, 315 Montgomery St, San Francisco, CA 94104,
  privacy@lifelenz.com, ph +1 415-829-4216.

Your Rights Under Canadian Privacy Law

‍If you are located in Canada, you have the following rights with respect to your personal data. You may contact us at privacy@lifelenz.com if you wish to exercise any of these rights:

• The right to access your data
• The right to collect and delete your data
• The right to object to processing of your data
• The right to object to marketing
• The right to complain to our Data Protection Officer and to relevant data protection authorities

Your Rights Under EU General Data Protection Regulation

‍If you are located in the EU, you have the following rights with respect to your personal data. You may contact us at privacy@lifelenz.com if you wish to exercise any of these rights:

• The right to access your personal data
• The right to update your personal data by emailing us or, where appropriate, amending the personal details contained in your registered account with us. If practically possible, we will make corrections (where appropriate) based on your updated information
• The right to withdraw your consent with respect to data that is collected on the basis of your consent
• The right to request erasure of your data or object to its processing
• The right to data portability
• The right to lodge a complaint with us or with a supervisory authority

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