OUR LIFE OFFERING PRIVACY POLICY
1. Personal Identification Collection and Use
We collect, use, store and share your personal information.
This privacy policy is about our collection, use and disclosure of your personal information.
2. What Information We Collect; Your Consent
When you use our LIFE Fulfilment Tool to subscribe for our securities under our LIFE Offering you consent to our collecting personal information from you including
• your name
• your address
• your email
• your phone number
• your social insurance number
(collectively, “your personal information”)
• payment information such as your credit card information (“your payment information”) (which is collected and processed for us by Stripe)
3. How We Use Your Personal Information
(a) We use your personal information to fulfil your subscription for our securities.
(b) We provide your personal information to our registrar and transfer agent to issue to you our securities, to record your ownership on our security holder register and ledgers, to deliver to you certificates or other evidence of your ownership of our securities and to communicate with you as required under applicable corporate and securities laws, for instance in connection with any meetings of security holders and delivery of our financial statements and other continuous disclosure documents to you.
(c) We provide your personal information to securities regulatory authorities or regulators as required under applicable securities laws. You authorize the indirect collection of your person information by them and confirm that you have been notified by us:
(i) that we will be delivering your personal information to the securities regulatory authority or regulator;
(ii) that your personal information is being collected indirectly by the securities regulatory authority or regulator under the authority granted to it in applicable securities laws;
(iii) that your personal information is being collected for the purpose of the administration and enforcement of applicable securities laws; and
(iv) that the title, business address and business telephone number of the public official who can answer questions about the securities regulatory authority’s or regulator’s indirect collection of your personal information is as follows:
A. British Columbia Securities Commission, P.O. Box 10142, Pacific Centre, 701 West Georgia Street, Vancouver, British Columbia V7Y 1L2, Inquiries: (604) 899-6854, Toll free in Canada: 1-800-373-6393, Facsimile: (604) 899-6581, Email: inquiries@bcsc.bc.ca;
B. Alberta Securities Commission, Suite 600, 250 – 5th Street, SW Calgary, Alberta T2P 0R4, Telephone: (403) 297-6454, Toll free in Canada: 1-877-355-0585, Facsimile: (403) 297-2082;
C. Financial and Consumer Affairs Authority of Saskatchewan, Suite 601 - 1919 Saskatchewan Drive, Regina, Saskatchewan S4P 4H2, Telephone: (306) 787-5879, Facsimile: (306) 787-5899;
D. The Manitoba Securities Commission, 500 – 400 St. Mary Avenue, Winnipeg, Manitoba R3C 4K5, Telephone: (204) 945-2548, Toll free in Manitoba 1-800-655-5244, Facsimile: (204) 945-0330;
E. Ontario Securities Commission, 20 Queen Street West, 22nd Floor Toronto, Ontario M5H 3S8, Telephone: (416) 593-8314, Toll free in Canada: 1-877-785-1555, Facsimile: (416) 593-8122, Email: exemptmarketfilings@osc.gov.on.ca, Public official contact regarding indirect collection of information: Inquiries Officer;
F. Autorité des marchés financiers, 800, Square Victoria, 22e étage, C.P. 246, Tour de la Bourse, Montréal, Québec H4Z 1G3, Telephone: (514) 395-0337 or 1-877-525-0337, Facsimile: (514) 873-6155 (For filing purposes only), Facsimile: (514) 864-6381 (For privacy requests only), Email: financementdessocietes@lautorite.qc.ca (For corporate finance issuers); fonds_dinvestissement@lautorite.qc.ca (For investment fund issuers);
G. Financial and Consumer Services Commission (New Brunswick), 85 Charlotte Street,, Suite 300 Saint John, New Brunswick E2L 2J2, Telephone: (506) 658-3060, Toll free in Canada: 1-866-933-2222, Facsimile: (506) 658-3059, Email: info@fcnb.ca;
H. Nova Scotia Securities Commission, Suite 400, 5251 Duke Street, Duke Tower, P.O. Box 458 Halifax, Nova Scotia B3J 2P8, Telephone: (902) 424-7768, Facsimile: (902) 424-4625;
I. Prince Edward Island Securities Office, 95 Rochford Street, 4th Floor Shaw Building, P.O. Box 2000 Charlottetown, Prince Edward Island C1A 7N8, Telephone: (902) 368-4569, Facsimile: (902) 368-5283; and
J. Government of Newfoundland and Labrador, Financial Services Regulation Division, P.O. Box 8700, Confederation Building 2nd Floor, West Block, Prince Philip Drive, St. John’s, Newfoundland and Labrador A1B 4J6, Attention: Director of Securities, Telephone: (709) 729-4189, Facsimile: (709) 729-6187.
“Your personal information" includes any personal information as that term is defined under applicable privacy legislation, including, without limitation, the Personal Information Protection and Electronic Documents Act (Canada) and any other applicable similar, replacement or supplemental provincial or federal legislation or laws in effect from time to time and without limiting the foregoing, but for greater clarity, means information about an identifiable individual, including but not limited to any information about you and includes information provided by you.
(d) You expressly acknowledge and agree that we may be required to provide applicable securities regulators, or otherwise under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), a list setting forth the identities of the purchasers of our securities and any personal information provided by you, and you hereby represent and warrant that to the best of your knowledge, none of the funds representing the subscription proceeds to be provided by you (i) have been or will be derived from or related to any activity that is deemed criminal under the law of Canada, the United States, or any other jurisdiction, or (ii) are being tendered on behalf of a person or entity who has not been identified to you; you hereby further covenants that you shall promptly notify us if you discover that any of such representations is untrue or ceases to be true, and shall provide us with appropriate information in connection therewith.
(e) We may provide your personal information to third parties such as our auditors or our legal counsel or law firm for compliance purposes or to resolve any disputes or claims.
(f) We use your personal information to verify your identity and your eligibility to subscribe for our securities, to detect fraud and other illegal or inappropriate activity, to conduct research and analysis and to comply with applicable laws or respond to legal process.
(g) We may or our LIFE Fulfilment Tool may use your personal information to improve our LIFE Fulfilment Tool.
4. Third Party Policies
We believe our registrar and transfer agent, securities regulatory authorities or regulators and our auditors and law firm have procedures and policies and systems to securely store and use your personal information only for valid purposes.
5. How Do We Store & Protect Your Information
Although no system can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in accordance with applicable laws and regulations, as appropriate to the sensitivity of your information. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.
6. Security of Data
The security of your data is important to us, but remember that no method of electronic or physical transmission, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know, who will only process your personal data on our instructions and who are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach or suspected breach where we are legally required to do so.
7. How Long Do We Keep Your Information?
Except as otherwise permitted or required by applicable law or regulation, we only keep your information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, reporting or regulatory obligations. If we dispose of your information, we will do so in a way that is commercially reasonable taking into account the sensitivity of the information. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
8. Transfer of Data
Your personal information may be transferred to — and maintained on — computers located outside of your province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Canada and choose to provide your personal information to us, please note that we transfer the data to Canada and process it there.
Your consent to our Privacy Policy by your submission of your personal information through our LIFE Fulfilment Tool represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our Privacy Policy and no transfer of your personal information will take place to an organization or a country unless we are satisfied there are adequate controls in place including the security of your data and other personal information.
9. Disclosure of Your Personal Information
We may disclose your personal information in the good faith belief that such action is necessary to:
• To comply with a legal obligation
• To protect and defend our rights
• To prevent or investigate possible wrongdoing in the use of our LIFE Fulfilment Tool
• To protect the personal safety of users of our LIFE Fulfilment Tool or the public
• To protect against legal liability
10. Children
Use of our LIFE Fulfilment Tool and subscription for our securities is not permitted for anyone under the age of 18 (a “Child”).
We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with personal information, accurate or otherwise, please contact us. If we become aware that we have collected personal information from a Child without verification of parental consent, we take steps to remedy, which may include contacting you, reversing or rescinding any subscription for our securities and restricting the personal information from our records and systems.
11. We May Have Other Privacy Policies
This privacy policy specifically addresses your use of our LIFE Fulfilment Tool to subscribe for our securities and our collection of your personal information using our LIFE Fulfilment Tool and our use of your personal information to fulfil your subscription.
We may have other privacy policies which may be available on our websites, including our website from which you accessed our LIFE Fulfilment Tool.
12. International Users
Our LIFE Fulfilment Tool is located and operated in Canada and principally intended for use by Canadian residents. It is not available for use by US Persons, or for use in or from the United States. International users (Non-Canadian and Non-US) may use our LIFE Fulfilment Tool in compliance with our LIFE Offering subscription agreement and terms.
If you choose to use our LIFE Fulfilment Tool from the European Union or other regions of the world with laws governing data collection and use that may differ from Canadian law, then please note that you are transferring your personal information outside of those regions to Canada for storage and processing. Also, we may transfer your data from Canada to other countries or regions in connection with storage and processing of data, fulfilling your subscription, and operating our LIFE Fulfilment Tool. By providing any information, including personal information, through our LIFE Fulfilment Tool, you consent to transfer, storage, and processing of your personal information.
13. Changes
We may change our privacy policy from time to time. Changes to our privacy policy will be reflected here. Material changes to our privacy policy will be posted here, and may be provided via e-mail or another method, as appropriate, under applicable law. You should regularly check for any changes to our privacy policy.
14. Contact
We welcome your questions regarding our privacy policy. Please contact us at:
Our Fulfilment Tool
Privacy Officer
50 Richmond St. E., Suite 300
Toronto, Ontario M5C 1N7