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