Training By Location

LivingWorks Privacy Policy

LivingWorks Education - PRIVACY POLICY

Effective October 30, 2024

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 independently 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 personal 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, languages, location, user activities, badges and awards, organization affiliations and community membership
  • 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
  • Develop Connect profile
  • 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.
  • Develop Connect profile
  • 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
  • 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
  • Intervention data including dates, LivingWorks model used, seeker contact information, profile notes; situational observations including intervention type, contacts (connections to safety), follow up tasks; and SafePlan data including goals, activities, safety contact information and reflections, and intervention sharing information
  • For helping person with thoughts of suicide or self-harm to keep safe.
  • To improve helper’s suicide prevention skills and effectiveness of interventions
  • Intervention information deidentified through anonymization and aggregation, including LivingWorks models used, profile demographics, situational observations, activities and tasks, reflections, support and sharing, and consent information
  • For measuring program effectiveness and platform improvements
  • For suicide research
  • Consent actions for the collection and sharing of data and agreement to Terms of Use and Acceptable Use policies
  • For managing consents
  • Network of Safety user connections, connection requests and invitations, connections contact information and chat content
  • For managing and facilitating networks of Safety in the Connect platform.
  • Develop Connect profile

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 [email protected], 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
  • Anonymized intervention information
  • Research community
  • Personal information of specific training sessions
  • LivingWorks authorized trainers
  • Personal information of specific training programs
  • LivingWorks authorized research partners
  • Intervention information
  • Connect profile
  • Network of Safety information SafePlan, Connections to Safety, Follow up Tasks
  • Hosting service provider (the service provider hosts the system but has no access to encrypted data)
  • Intervention Information
  • SafePlan
  • Connections to Safety and follow-up tasks
  • Helper or support contact as directed and approved by person having thoughts of suicide

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 [email protected]

 

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

SENSITIVE INFORMATION

We will only collect and process 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 will only share your intervention information with another helper with your explicit permission.

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
  • Intervention information including dates, LivingWorks model used, seeker contact information, profile notes; situational observations, intervention type, contacts (connections to safety), follow-up tasks; SafePlan data including goals, activities, safety contact information; and reflections and intervention sharing information
  • For helping person with thoughts of suicide or self-harm to keep safe
  • To improve helper’s suicide prevention skills and effectiveness of interventions
  • Intervention information deidentified through anonymization and aggregation, including LivingWorks models used, profile demographics, situational observations, activities and tasks, reflections, support and sharing, and consent information
  • For measuring program effectiveness and platform improvements
  • For suicide research

LivingWorks may employ the services of third-party service providers to host systems or services. Sensitive data stored in or managed by hosted systems or services is encrypted and not accessible to the third-party service providers.

LivingWorks currently uses the following sub-processors for providing our services https://livingworks.net/third-party-vendors/

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 [email protected]

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 [email protected]. 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: [email protected]

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