LivingWorks Privacy Policy

LivingWorks Education - PRIVACY POLICY

Effective June 6, 2022

Your privacy is important to LivingWorks Education Inc. and its affiliates (collectively, “LivingWorks“, “we“, “our” or “us“). To provide our services to you, we need to collect, store, use, and disclose some of your personal information. We have developed this privacy policy (the “Privacy Policy“) to inform you of the ways in which we may collect, use and disclose your personal information. This Privacy Policy applies to LivingWorks, the livingworks.net website and all related mobile apps, e-commerce shops, social media apps, desktop apps, and software services (collectively, the “Platform“), any services offered by us (“Services“), and to any program or joint venture LivingWorks participates in. In this Privacy Policy, “you” and “your” mean you, provided you have created an account on the Platform, provided any information to us, or applied for, enrolled in, or used any Services.

General

We will only collect, use and disclose your personal information where we have a lawful basis for doing so. Usually this will require that we obtain your informed and express consent for the collection, use and disclosure of your personal information for a particular purpose. However, in certain circumstances your consent is not required. Some examples where consent may not be required are: where the collection, use or disclosure of the personal information is reasonable and required for LivingWorks to comply with a legal obligation; for purposes of direct delivery of training or learning services or direct use of support or other resources available on the Platform or in a de-identified form for research or development; or for a vital interest of yours—for example, if a circumstance required your medical history to be disclosed for emergency treatment. We may collect, use and disclose your personal information without your consent or knowledge in those limited circumstances.

We may amend this Privacy Policy from time to time. If we make material changes in the way we use personal information, we will notify you by posting an announcement on the Platform or sending you an email. Users are bound by any changes to the Privacy Policy when they use the Platform or Services after such changes have been first posted.

What personal information does LivingWorks collect and how do we collect it?

We receive and store personal information you provide to us through the Platform, the Services, or in any other way. The types of personal information we collect may include: your name, email address, occupation, age range, place of work, address (city, state or province, country), interests, and IP address.
We may also collect personal information from you relating to your experience of our training programs, such as: demographic information and outcomes of the application of your learning from our training programs (whether an intervention occurs after the training, on what dates the training and any intervention occurred, and what types of resources you accessed). We will collect these types of information to enable us to fulfill our contractual obligations to you by providing our services that you request; to use in aggregated form to contribute to public health research initiatives and the field of suicidology, and other public interest purposes; and for scientific research purposes which respect your right to data protection and provide suitable and specific measures to safeguard your fundamental rights and the interests.
We use common internet technologies, such as cookies and beacons, on our websites and emails, to help provide you with a better, faster, and safer experience, and to provide you with customized resources, learning and support. See our cookie policy, available at https://www.livingworks.net/cookiepolicy for more information.
Unless otherwise required or permitted by law or unless otherwise set out in this Privacy Policy: (i) we will only collect your personal information directly from you, and (ii) when we collect your personal information we will inform you of the uses and disclosures that we intend to make of your personal information.

How do we use and share personal information we collect?

LivingWorks may use the personal information you provide for such purposes as allowing you to set up a user account and profile that you may use to interact with the Services, improving the content of the Services, and research and development to support new products and advance the field of suicidology.
Information about our users is an integral part of our business. We use your personal information in order to provide you with: information you request, customized learning and support resources, the Platform and the Services, and to help us develop new Services that meet your needs, all in a manner consistent with this Privacy Policy.
We do not share your personal information with third-party marketers.
We will use personal information you provide only for purposes consistent with the reason you provided it.
When we temporarily provide personal information to companies that perform services for us, such as Shopify, we require those companies to protect the information in the same manner as LivingWorks. These service companies may not use your personal information for any other purpose than the reason you provided it to LivingWorks.
We share personal information with employers and host organizations to understand training uptake and related activity. Limited portions of this information will be personally identifiable—specifically, information about which employees have completed specific training courses. The purpose of this information sharing is to enable employers to track the effectiveness of their training programs. All other personal information shared with employers will be shared as aggregate or anonymous information, formatted such that there is not a serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.
We may share such information with third-party research partners in an aggregated form as part of a segment of users or in a de-identified form, but we would not share such information in a manner that specifically identifies you.
The Services may contain links to other sites. LivingWorks is not responsible for the privacy policies or practices on other sites. When linking to another site, you should read the privacy policy stated on that site.
We neither rent nor sell your personal information to anyone for their own use; however, we may provide aggregate or anonymous information to third parties for research purposes, by license or otherwise, provided there is not a serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.
We may temporarily collect and use geolocation data relating to your IP address or mobile device, but not specific to your location, to help provide access to local crisis resources for you and for statistical analysis for suicide prevention research.
By providing your email address to us, you expressly consent to receive emails from us, however you may unsubscribe from this service at any time. We may use email to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us or our partners.

What choices do I have regarding LivingWorks use of my personal information?

You have certain choices relating to your personal information we collect and use. You may request that we provide you with access to the personal information that we hold about you. You may ask us to correct any errors or delete any of the information we have about you. We note, however, that your ability to exercise these choices is not absolute. In some circumstances (for example, if the information is protected by legal privilege or if the information was collected for an investigation or legal proceeding), we may be permitted or obliged to deny such requests. In addition, to protect your privacy and the privacy of others, we may have to verify that you are who you say you are before we can give you access to, change or remove information about you.
We may retain your personal information for as long as your Services account is active or as long as we are legally permitted or obligated to retain it to comply with our legal obligations, resolve disputes, and enforce our agreements.
You can remove or change content or information that you have posted on the Platform on your account and profile through the Platform or you can ask us to remove it by emailing info@livingworks.net. Even after you remove information from your account or profile, copies of that information may remain viewable elsewhere, if there are legal reasons why we may need to retain it. Removed and deleted information may remain on backup media for a period of time prior to being deleted from our servers.
If you ever decide to delete your LivingWorks account, please email info@livingworks.net from the email address used on your LivingWorks account. LivingWorks will terminate your account within 7 working days of receiving the request. Notwithstanding the foregoing, we will retain information as required by applicable law and we will not delete any information that has already been aggregated or anonymized.

GDPR (the European Union’s General Data Protection Regulation) compliance

LivingWorks is committed to compliance with the GDPR and its principles, including: prioritizing informed consent respecting the collection of personal data; lawful processing of personal data; maintaining accurate, updated, and secure personal data; and respecting data subjects’ rights concerning their personal data.

LivingWorks is a controller of our users’ personal information. If you have questions about our GDPR compliance, please contact our Data Protection Officer (DPO), Brian Bleakley at info@livingworks.net.

Our GDPR compliance actions include: creating and maintaining this Privacy Policy; appointing our DPO; periodically reviewing the personal data we collect, store, manage, process, and control; assessing our bases for processing personal data to ensure there is a lawful basis for all such processing; monitoring our systems to identify and investigate potential personal data breaches; and, providing training to our employees and raising the awareness of GDPR compliance throughout our business.

How to contact us

You may contact us, to ask questions, raise concerns or exercise choices relating to this Privacy Policy, in the following ways:

Privacy Officer: Brian Bleakley

Mail: 151 Canada Olympic Road SW, Suite 500, Calgary, Alberta, CANADA, T3B 6B7

Toll Free in North America 1-888-733-5484

International 1-403-209-0242

Email: info@livingworks.net

We will make every effort to answer your questions or resolve your concerns.

Effective September 12, 2023

PURPOSE OF THE POLICY

Privacy is important to LivingWorks Education Inc. and its affiliates (collectively, “LivingWorks”, “we”, “our” or “us”). To provide our services, we need to collect, store, use, and disclose some personal information. We have developed this privacy policy (the “Privacy Policy”) to inform individuals about how we may collect, use, and disclose their personal information.

SCOPE OF THE POLICY

This Privacy Policy applies to LivingWorks, the website(s) and all related mobile apps, e-commerce shops, social media apps, desktop apps, and software services (collectively, the “Platform”), any services offered by us (“Services”), and to any program or joint venture LivingWorks participates in.

In this Privacy Policy, “you” and “your” mean you as the user, provided you have created an account on the Platform, provided any information to us, or applied for, enrolled in, or used any Services.

This Privacy Policy only applies to information LivingWorks collects directly from you. Information that trainers collect is not covered by this policy, and you should receive a separate privacy policy from them to find out how they use your information.

INTRODUCTION

This policy was developed based on industry best practices, consultation with privacy professionals, users, advisory groups, and LivingWorks staff; universal privacy principles; and applicable global privacy regulations including, but not limited to, EU General Data Protection Regulation, UK General Data Protection Regulation, Australian Privacy Principles, California Privacy Rights Act and Canada’s Personal Information Protection and Electronics Documents Act.

POLICY STATEMENT

INFORMATION WE COLLECT

We may collect and process the following information:

Types of Information	Purpose
Personal information including name, email, occupation, age range, place of work, address, phone number, interests, IP address, credentials, purchase history, and languages.	Register for products and services. Respond to requests for information. Authenticate and manage user sessions. Provide customer service. Deliver LivingWorks learning platforms. Inform about products and services. Deliver LivingWorks Trainer programs. Statistical research.
Site usage activity.	Analyze platform usage to optimize user experience.
Survey Information including demographic information, age range, learning outcomes, program feedback, and post program activities.	Program development. Contribute to public health research initiatives and public interest programs. Contribute to the field of suicidology. Scientific research.
Program information including attendance and dates.	Program management and metrics.
Trainer profiles including personal information, languages spoken, special population groups, professional qualifications, sensitive information regarding recent personal losses to suicide and learning challenges/disabilities.	Trainer application. Pre-screen and qualify individuals to enroll in a trainer program.
Military site Training Coach information including social security number, social insurance number, Australian business number, driver’s license and copy of passport.	For training coaches who conduct training on a military site who do not already have military ID granting them access to the base. This information is restricted to the ASIST Coordinator and ASIST Operations Manager and Administrators.
Employee information including name, address, phone number, email address, social insurance number, employment status, benefits information, performance records, next of kin for identification, annual review of performance and benefits.	For employment purposes.
Supplier information including individual and/or organization names, business addresses, phone number and email address.	For ordering services and supplies.
Verbal responses provided (using online microphone and camera) during online training.	Used for practicing responding to situations. This information is transitional, used only in that training session, and is not stored.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

When we collect and use your personal information, we have one or more legal grounds to do so. These include:

You gave us permission to use your information for a specific reason. You can withdraw your permission at any time by contacting privacy@livingworks.net, but if you do, we may not be able to provide you with our service anymore.
We need to use your information to follow the law, such as keeping records or giving information to a government or law enforcement agency.
We, or a third party, have a legitimate reason for using your information, and it is not outweighed by your privacy rights or interests.

INFORMATION WE SHARE

We might share your information with third parties, including trainers, to provide the services you need. We only share what is necessary for the service. Third parties must follow our rules about keeping your data safe.

Independent trainers might use your information to offer other services within their portfolio of professional services. If a trainer wants to use your information for something other than LivingWorks training, this will need to be agreed to between you and the trainer separately.

LivingWorks does not sell your personal information.

We disclose personal information with third parties as set out below:

Types of Information	Type of Third Party
Personal information	Service providers including hosting provider, customer service provider, customer relationship management service providers, marketing providers, learning platform, file hosting services.
Within a sponsored seat/license: Personal information Aggregated program information and outcomes Anonymized survey information	Host organizations
Aggregated program information, survey results and outcomes	Research community
Personal information of specific training sessions	LivingWorks authorized trainers
Personal information of specific training programs	LivingWorks authorized research partners

WHAT RIGHTS DO I HAVE TO ENSURE THE PRIVACY OF MY PERSONAL INFORMATION?

As a valued customer of LivingWorks, you have certain rights that help you to take control of your personal information and privacy. If you want to use any of these rights, you can contact privacy@livingworks.net

Privacy Right	Description
Right to Be Informed	You have the right and expectation that we provide clear and concise descriptions of our privacy practices.
Right to Access	You can request a copy of the personal information that we have about you.
Right to Delete	You can ask us to delete some or all your personal information. However, if you ask us to delete all of it, we may not be able to provide you with our services anymore.
Right to Rectification	You can ask us to correct any incorrect personal information we have about you.
Right to Know if We Sell your Information	You have the right to know if we ever sell your personal information and to whom. LivingWorks does not sell your information.
Right to Opt-Out of Sale	You are entitled to prohibit us from selling your personal information. LivingWorks does not sell your information.
Right to Non-Discrimination	You have the right to receive equal service and price, even if you exercise your privacy rights.
Right to Restrict Processing	You can ask us to limit or stop processing your data under certain circumstances, like if you want to contest its accuracy.
Right to Data Portability	You can receive your data from us in a common, machine-readable format.
Right to Object to Processing	You can object to the processing of your personal data.
Right to Avoid Automated Decision Making	You will not be subject to a decision that is based solely on automated processing (without any human involvement) if it could have legal consequences for you.

We will only collect, use, and share your sensitive information with your explicit permission, according to the law, or in a way that makes it impossible for anyone to connect it to you.

We will ask for your explicit permission if we need to use your sensitive information to protect your life or someone else’s.

SENSITIVE INFORMATION

We may collect and process the following sensitive information:

Types of Sensitive Information	Purpose
Survey information regarding experiences with suicide, race, ethnic origin, and gender diversity.	Optimize and deliver LivingWorks learning platforms. Mental health research.
Trainer information including learning challenges/disabilities and recent individual experiences with suicide.	Ensure proper support in place for trainers to create a successful training environment.

HOW DOES LIVINGWORKS PROTECT MY INFORMATION?

We are committed to protecting the confidentiality of your information. We take reasonable measures to secure your information, including the implementation of industry standard organizational and technical controls. These controls include defense in depth, access controls, secure development, and risk management.

MINORS UNDER 16 YEARS OF AGE

Protecting the privacy of minors is especially important to us, so we have added protections and restrictions designed to help protect personal information relating to children under 16 years of age (“Child User”).

LivingWorks only collects information from children under 16 years old if their parents or guardians have given us permission. If a teacher or school administrator has the authority to give us permission, we can collect information from the child. The teacher or school administrator must collect written consent from the parents or guardians, as required by privacy laws, on our behalf and provide that information upon request by us. We also ask for the child’s birth date to make sure we have the right safety measures in place for their age.

If you are a child under 16, please do not send us any personal information unless your parents or school have given us permission, and only send us the information we need to provide LivingWorks services.

If we find out that we have accidentally collected personal information from a child without permission, we will delete it right away. If you think a child has given us information without permission, please contact us at privacy@livingworks.net.

If you are a teacher or school administrator, you need to make sure that you have permission from parents or guardians to give us information about Child Users. You should give the parents a copy of our privacy policy and get written consent from them as required by privacy laws and provide this to us upon request.

INTERNATIONAL TRANSFERS OF MY PERSONAL INFORMATION

Sometimes we may need to transfer your personal data to another country outside of your country of residence. In such cases, we will ensure that the transfer complies with applicable laws and regulations. We will act appropriately to protect your privacy rights in accordance with the requirements of your country of origin.

HOW LONG DO YOU KEEP MY INFORMATION?

We may keep your personal information for as long as your Services account is active or as long as we are legally allowed or required to keep it for reasons such as fulfilling our legal obligations, resolving disputes, or enforcing our agreements.

DATA BREACH NOTIFICATION

In the event of a breach of our security safeguards that poses a risk of significant harm to you, we will notify you as soon as possible. We will also promptly notify the appropriate authorities as required by applicable laws.

WHO DO I CONTACT IF I HAVE A CONCERN ABOUT LIVINGWORKS’ PRIVACY PROGRAM?

If you have any questions or concerns about this Policy or how we keep your information safe, please email us at privacy@livingworks.net. We will get back to you within thirty (30) days. If we do not, or if our answer is insufficient, you can escalate to an applicable data protection authority.

VERIFIABLE REQUEST

We want to make sure that we protect your privacy, so we may not be able to fulfill a request or may ask for more information to confirm the identity of the person making the request. We usually expect that the request comes from someone who has an account with us and is logged in, the email address registered to that individual or someone who we recognize as providing a service on your behalf.

EMAIL MARKETING

We do not send marketing emails to people who have not agreed to receive them first. Sometimes we might send emails to invite you to register for the Service if your organization has asked us to.

If we send you a marketing email, it will have instructions on how to stop getting them in the future. You can opt out of marketing correspondence relating to the Service by clicking on the unsubscribe link in the marketing email.

If you say that you do not want marketing emails, we might still send you some types of emails to notify you about the Services or that are required by law.

DOES LIVINGWORKS USE COOKIES?

We use common internet technologies, such as cookies and beacons, on our websites and emails, to help provide you with a better, faster, and safer experience, and to provide you with customized resources, learning and support. See our cookie policy, available at https://www.livingworks.net/cookiepolicy for more information.

THIRD PARTY PRIVACY POLICIES

Our Services may contain links to other sites. If a link directs you to a third-party site, the third party’s privacy policy will then apply to any information you provide. LivingWorks is not responsible for the privacy policies or practices on other sites. It is important to read and familiarize yourself with the third party’s privacy policy.

CHANGES TO THIS POLICY

Sometimes, we may update this Privacy Policy. If we make significant changes to how we use your personal information, we will let you know by showing a message on the login page for a certain period. If you continue to use our website or services after we make these changes, it means that you agree to the new Privacy Policy.

HOW TO CONTACT US

You may contact us, to ask questions, raise concerns or exercise choices relating to this Privacy Policy, in the following ways:

Privacy Officer: Data Privacy Office
Mail: 151 Canada Olympic Road SW, Suite 500, Calgary, Alberta, CANADA, T3B 6B7
Toll Free in North America 1-888-733-5484
International 1-403-209-0242
E-mail: privacy@livingworks.net

We will make every effort to answer your questions or resolve your concerns.

DISSEMINATION OF POLICY

The Policy Owner is responsible for correctly filing this policy, training the staff whose functions are governed by it, and designating an Administrator Responsible for this policy. The Administrator Responsible ensures the policy is reviewed and updated on the designated schedule.

LivingWorks Privacy Policy

LivingWorks Education - PRIVACY POLICY

Effective June 6, 2022

General

What personal information does LivingWorks collect and how do we collect it?

How do we use and share personal information we collect?

What choices do I have regarding LivingWorks use of my personal information?

GDPR (the European Union’s General Data Protection Regulation) compliance

How to contact us

Effective September 12, 2023

PURPOSE OF THE POLICY

SCOPE OF THE POLICY

INTRODUCTION

POLICY STATEMENT

INFORMATION WE COLLECT

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

INFORMATION WE SHARE

WHAT RIGHTS DO I HAVE TO ENSURE THE PRIVACY OF MY PERSONAL INFORMATION?

SENSITIVE INFORMATION

HOW DOES LIVINGWORKS PROTECT MY INFORMATION?

MINORS UNDER 16 YEARS OF AGE

INTERNATIONAL TRANSFERS OF MY PERSONAL INFORMATION

HOW LONG DO YOU KEEP MY INFORMATION?

DATA BREACH NOTIFICATION

WHO DO I CONTACT IF I HAVE A CONCERN ABOUT LIVINGWORKS’ PRIVACY PROGRAM?

VERIFIABLE REQUEST

EMAIL MARKETING

DOES LIVINGWORKS USE COOKIES?

THIRD PARTY PRIVACY POLICIES

CHANGES TO THIS POLICY

HOW TO CONTACT US

DISSEMINATION OF POLICY

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