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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.