Privacy Policy

Privacy Policy

Last Updated  AUGUST 2024

1. Overview

LiFet Media Inc. (“LiFet,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy”). This Privacy Policy describes how we collect and use your Personal Information when you visit our website atlifet.ca or otherwise use the Platform as described further in the Terms of Service, and that you may provide in electronic messages to LiFet.

Please read this Privacy Policy to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree and consent to this Privacy Policy.

LiFet may change this Privacy Policy at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

This Privacy Policy is subject to and governed by the LiFet Terms of Service. The Services are part of the Platform and are described further in the Terms of Service.

2. The Types of Information That LiFet Collects About You and How LiFet Collects Information About You

LiFet may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).

“Personal Information” refers to data by which you may be personally identified, such as name, email address, employer, job title and department, and telephone number.

“Non-Personal Information” means data that is about you, but does not identify you specifically. If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

We collect Information:

• Directly from you when you provide it to us. When you subscribe to a newsletter, create an account, make a purchase or request information from LiFet, we will ask for things like your name, contact, billing, shipping and communication information, and account ID or credentials in order to fulfill your request. If you set up an appointment with us through the Platform, attend a trade show or event, or otherwise contact us, you may also voluntarily provide similar information. If you submit any Personal Information about other people to us or to our service providers, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy (for example, by asking for their consent).
• From third parties. We obtain information through partners, vendors, suppliers, and other third parties. The parties from whom we obtain information are typically corporate enterprises (although some may also be educational or public enterprises) and they may be located in any of the locations in which we do business. These enterprises largely fall into the following categories: Advertising and marketing companies, data set and information vendors, public database providers, social media platforms, partners, providers of products or services, hosts or vendors at events or trade shows, research partners, or enterprises that use LiFet Services. We take steps to confirm that information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Information to us. We might also obtain information through a partner, or co-create datasets with a partner, as part of our business operations. This kind of data is used for work like improving the Platform and other LiFet Services, enhancing existing products and developing new capabilities and features. In some cases we combine Personal Information about individuals that we receive from multiple sources, including directly collected from you or through your use of the Platform.
• Automatically as you navigate through the Platform or during the time in which you utilize our Services. We collect information about how you interact with the Platform through the use of cookies, pixel tags, and similar technologies. Please view our separate Cookies Policy (CA) for more information on our use of cookies and similar technologies, how you can manage cookies and how we respond to Do Not Track signals.

3. How LiFet Uses Personal Information It Collects About You and the Purposes for the Collection and Use

We use Personal Information that we collect about you or that you provide to us for the following purposes:

• For Functionality and Development of the Platform and LiFet Services. We use information to provide, offer, and personalize the Platform and other LiFet Services provided to you. Some information, like your IP address, is used to communicate with your device to provide network connectivity, measure usage levels of the Platform, diagnose server problems, and provide security features. Other business purposes that depend on the use of your information include data analysis related to testing, modifying, improving or developing new products, services, and technologies, and to identify trends. Some Platform features may leverage artificial intelligence (“AI”) tools to enhance performance capabilities. We do NOT retain Personal Information to develop, improve, or train generalized AI or machine learning models, including user data provided via third-party APIs, including but not limited to Google Workspace APIs. LiFet Platform’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. We use cookies to make our websites and the Platform operate, work more efficiently, and provide analytic information. Technologies similar to cookies, such as pixel tags are also used in connection with the Platform. For more information on our use of cookies, please read our Cookies Policy (CA).
• For Customer Support, Platform Updating, and Reporting. The Platform may use information to provide LiFet with updates and reports, and to check that the Platform is working properly. Update functions may automatically check your system to see whether files need to be refreshed, updated, or modernized, in order to provide you with the up-to-date security, versions, features, options, and controls associated with your systems or devices. We rely on information to analyze performance and improve and maintain the Platform. We also rely on Personal Information you provide to us to provide you with customer support for the Platform and other LiFet Services, and to verify eligibility for promotional offers.
• For Business Operations. We use information to operate our business; for example, to perform accounting, auditing, billing, reconciliation, and collection activities. Other business purposes that depend on the use of your Personal Information include crime or fraud monitoring and prevention, protecting our legal rights, and performing contractual obligations. We also use Personal Information to contact you to advertise, market, and sell LiFet Services in accordance with your communications preferences.
• To Communicate. We use contact information to send messages; to provide LiFet Services; to respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and to send marketing or informational materials like newsletters or white papers, in accordance with your communication preferences. We occasionally conduct surveys or do focused research or studies which may require you to voluntarily share Personal Information in order to participate. These activities typically have additional notices that provide more information about the use of your Personal Information and to which you may be asked to consent.
• For Advertising and Marketing. We may use Personal Information collected from you, combined with information about what advertisements you viewed and other information we collect, to enable us to provide personalized content and to study the effectiveness of advertising and marketing campaigns. You may choose whether to allow or deny uses or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, we may not be able to provide you with certain personalized LiFet Services and content on the Platform.
• For Statistical Purposes to Improve the Platform. We may compile Platform statistics into traffic reports, which help LiFet understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the LiFet Platform, we are likely to highlight that information on the Platform home page. This Information helps us create a better overall experience for Platform users.

LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS): If you are in the European Economic Area or the United Kingdom, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.

Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests.

LiFet is the Data Controller of all Personal Information collected through the Platform in the EEA and the United Kingdom, except with respect to the Services (where LiFet is the Data Processor) or where a supplemental Privacy Policy says otherwise. The contact details for LiFet are set out in the “HOW TO CONTACT US” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact information provided below.

5. When LiFet Media Inc. Shares Your Information

We work with authorized suppliers and business partners to provide the Platform and other LiFet Media Inc. Services. When we share your Personal Information with these companies, we implement appropriate measures to limit the use of your information only for legal and authorized purposes that are consistent with this Privacy Policy, along with suitable confidentiality and security measures.

We also share information with third parties for advertising and marketing purposes; when required by law or to respond to legal processes; to protect our customers; to safeguard lives; to maintain the security of the Platform; and to protect our legal rights. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

• With Suppliers. Our authorized vendors and suppliers may require Personal Information to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a variety of software and tools at LiFet Media Inc., processing Personal Information using these tools as part of our regular business operations. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
• For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, provide content services, enable them to offer more personalized ads, and study the effectiveness of our campaigns. We use third-party companies to communicate regarding goods and services that may be of interest to you, in accordance with your preferences. You may receive this content through various means such as email, phone, or when you access and use the Platform or other LiFet Media Inc. Services, as well as other websites. Content may be based on information obtained from previous purchases or transactions, your device’s physical location, your viewing history of advertisements and content, or through cookies and similar technologies. Please read our Cookies Policy (CA) for more information. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you deny such uses, our partners may not be able to provide you with the applicable Platform Services and content.
• Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• With Your Consent. LiFet Media Inc. may disclose your Personal Information to any other person or entity where you consent to the disclosure. For information about how to decline our advertising and marketing, please see the section entitled “Your Choices & Rights” below.

We do NOT share your phone number or opt-in consent with third parties unless we’ve received your express written consent to do so.

We also share non-personally identifiable information, such as anonymized or aggregated information, with suppliers for purposes such as analysis, identifying trends in our products, and aiding research and development of new LiFet Media Inc. Services.

LiFet Media Inc. does not sell any of your Personal Information for monetary compensation.

6. Information From Children

We do not knowingly collect, use, or disclose information from children under 16. If we learn that we have collected the Personal Information of a child under 16—or the equivalent minimum age depending on the jurisdiction—we will take steps to delete the information as soon as possible. If you are under 16, do not provide any information about yourself to LiFet Media Inc., including your name, address, telephone number, or email address. If you become aware that information of a child under 16 years of age has been provided, please use the methods provided under the “HOW TO CONTACT US” section below.

7. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on LiFet Media Inc.’s behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) – including any Personal Information you disclose to other organizations through or in connection with the Platform or other LiFet Media Inc. Services.

8. Do Not Track

Some browsers incorporate a “Do Not Track” (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

9. YOUR LEGAL RIGHTS

LiFet Media Inc. respects your rights in how your Personal Information is used and shared. Depending on where you live, you may have rights to request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from LiFet Media Inc. at all). See below for more information, depending on your location.

10. European Privacy Rights

If you are in Europe, you may have additional rights under the GDPR, the UK GDPR, or nFADP. Additional choices and rights may be available to you depending on which LiFet Media Inc. Services you use.

• Access, Correction to or Deletion of Your Information. If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the “HOW TO CONTACT US” section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.

At your request and where the law requires us to do so, we will confirm what Personal Information we hold about you. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “HOW TO CONTACT US” section below. We may charge a processing fee for this service where permitted by law and will require evidence of your identity before fulfilling your request.

• Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland. You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. You can exercise these rights by making a written request in one of the ways described in the “HOW TO CONTACT US” section below.

Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.

If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, contact your local data protection authority. Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you. Under certain conditions, you may invoke binding arbitration. For additional information on pre-arbitration requirements, please see Annex I of the DPF Principles.

• Advertising and Marketing Choices. We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes. You may access or update your contact details and modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue, or product delivery. Some advertising content is delivered through the Platform’s use of cookies and similar technologies. Our Cookies Policy (CA) includes more information on LiFet Media Inc.’s use of such technologies for advertising and other purposes.

11. International Compliance

LiFet Media Inc. is a global company with its headquarters in Canada. As such, we may transfer your Personal Information between Canada and our affiliates and business partners in other countries. We may also transfer your Personal Information to our third-party service providers, who may be located in a different country from you.

LiFet Media Inc. transfers information internationally to operate efficiently, improve performance, and create redundancies to protect information in the event of an outage or other problem. In doing so, we will process your Personal Information in a manner that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

Whenever LiFet Media Inc. collects or processes Personal Information of customers in the European Economic Area (EEA), we will take appropriate steps to comply with the General Data Protection Regulation (GDPR) and relevant privacy laws. These measures may include executing Standard Contractual Clauses with third-party data processors to ensure that the Personal Information of customers in the EEA receives adequate protections while being transferred internationally.

12. Data Privacy Framework

LiFet Media Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LiFet Media has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. LiFet Media has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit dataprivacyframework.gov. LiFet Media further agrees to notify you without undue delay if its self-certification under any of the Data Privacy Frameworks is withdrawn, terminated, revoked, or otherwise invalidated and provide appropriate steps to stop and remediate any unauthorized processing of such personal data.

13. California Privacy Rights

This section is addressed to California residents only and provides more information about your rights under the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.), as amended. Subject to certain exceptions, the CCPA grants California residents the rights to: be notified about the collection, use, disclosure, sale, or sharing of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the “sale” or “sharing” of Personal Information (where such information is sold or shared); limit the use or disclosure of Sensitive Personal Information (as defined under CCPA); and to not be discriminated against for exercising such rights.

LiFet Media does not sell your Personal Information. If you wish to exercise your right to opt-out of LiFet Media using your Personal Information for cross-contextual targeted advertising purposes (called “sharing” under the CCPA), you may do so by using the details in the “HOW TO CONTACT US” section or the appropriate withdrawal mechanism provided to you on the Platform.

You can request access to, correction of, or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that LiFet Media may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CCPA. If you submit a request to exercise rights under CCPA, LiFet Media will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with LiFet Media and the sensitivity of the Personal Information at issue. If LiFet Media denies your request, we will explain why.

You can designate an authorized agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, LiFet Media may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CCPA. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and LiFet Media will respond to any request from such authorized agent in accordance with the CCPA.

The Privacy Policy describes the categories of Personal Information that LiFet Media collects and how LiFet Media uses such Personal Information. If LiFet Media collects Sensitive Personal Information, we limit our use of the Sensitive Personal Information to uses: (1) you have authorized, (2) that are required to fulfill your requests for goods or services, or (3) that are otherwise allowed by the CCPA or required by other laws or regulations.

The categories of Personal Information collected, disclosed, and sold from California residents over the preceding 12 months and LiFet Media’s applicable retention periods include:

Personal Information Category	Retention Period	Business Purpose	Collected	Disclosed	Sold
Identifiers (such as name, address, IP address, email, etc.)	See Section 3 of Privacy Policy: “Retention of Your Personal Information”	For functionality, customer support, business operations, communication, advertising and marketing, and statistical purposes.	Yes	Yes	No
Personal information defined in Civil Code Section 1798.80(e) (such as signature, SSN, financial information, and insurance information, etc.)	No	No	No
Protected personal information (such as gender, religion, sexual orientation, or disability)	No	No	No
Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, etc.)	See Section 3 of Privacy Policy: “Retention of Your Personal Information”	For development, customer support, business operations, communication, advertising and marketing, and statistical purposes.	Yes	No	No
Biometric information	No	No	No
Internet or other similar network activity (such as information on a consumer’s interaction with a website, application, or advertisement, etc.)	See Section 3 of Privacy Policy: “Retention of Your Personal Information”	For functionality, business operations, and statistical purposes.	Yes	Yes	No
Geolocation data	No	No	No
Audio, electronic, visual, thermal, or olfactory information	No	No	No
Professional or employment-related information	No	No	No
Education information	No	No	No
Inferences (such as analytics and preferences)	Yes	Yes	No

14. Colorado Privacy Rights

This section is addressed to Colorado residents only and provides more information about your rights under the Colorado Privacy Act or “CPA.” Subject to certain exceptions, the CPA grants Colorado residents the rights to: be notified about the collection, use, disclosure, or sale of their Personal Information; request access to, deletion of, or correction of their Personal Information; and request to opt out of the use of Personal Information for targeted advertising, sale, or certain profiling.

You can request access to, correction of, or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that LiFet Media may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CPA. If you submit a request to exercise rights under CPA, LiFet Media will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with LiFet Media and the sensitivity of the Personal Information at issue. If LiFet Media denies your request, we will explain why. If we have not responded to your request or asked for additional time to respond to your request within 45 days after you send us a request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us using the details in the “HOW TO CONTACT US” section.

You can designate an authorized agent to make a request under the CPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, LiFet Media may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CPA.

15. Connecticut Privacy Rights

This section is addressed to Connecticut residents only and provides more information about your rights under the Connecticut Data Privacy Act or “CTDPA.” You can exercise your rights by using the details in the “HOW TO CONTACT US” section. If we inform you that we decline to take action regarding your request, you have the right to appeal our failure to take action by contacting us using the details in the “HOW TO CONTACT US” section.

16. Utah Privacy Rights

This section is addressed to Utah residents only and provides more information about your rights under the Utah Consumer Privacy Act or “UCPA.” You can exercise your rights by using the details in the “HOW TO CONTACT US” section.

17. Virginia Privacy Rights

This section is addressed to Virginia residents only and provides more information about your rights under Virginia’s Consumer Data Protection Act or “VCDPA.” Subject to certain exceptions, the VCDPA grants Virginia residents the rights to: be notified about the collection, use, disclosure, or sale of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the use of Personal Information for targeted advertising, sale, or certain profiling; and to not be discriminated against for exercising such rights.

You can request access to, correction of, or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that LiFet Media may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by VCDPA. If you submit a request to exercise rights under VCDPA, LiFet Media will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with LiFet Media and the sensitivity of the Personal Information at issue. If LiFet Media denies your request, we will explain why. If we have not responded to your request or asked for additional time to respond to your request within 45 days after you send us a request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us using the details in the “HOW TO CONTACT US” section.

18. Amendments to This Privacy Policy

LiFet Media reserves the right to update this Privacy Policy from time to time. LiFet Media will notify you of any material changes to this Privacy Policy by posting the updated policy on the Platform and updating the effective date above. You are encouraged to review this Privacy Policy periodically to stay informed about how LiFet Media is protecting your Personal Information.

19. How to Contact Us

If you have any questions about this Privacy Policy, please contact us at: support@lifet.ca