PRIVACY STATEMENT

This privacy statement (this “Statement”) describes the practices of People Corporation and its corporate affiliates (“People”, “we”, “us”, “our”) with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct and access your personal information provided to us from you as a user of (a) the website operated at www.bestliferewarded.com and such other locations as made available from time to time (the “Portal”), (b) any front-end software provided by us(the “Software”), and (c) the services we provide through the Portal and/or the Software (collectively, the “Service”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Statement is incorporated by reference to the general Terms of Use and forms an integral part of it. All capitalized terms not otherwise defined herein have the meaning provided in Terms of Use.

1. Introduction and General Concepts

We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Statement to explain our practices for processing your personal information.

  1. Personal Information

    For the purposes of this Statement, “personal information” means any information about an identifiable individual, including but not limited to an individual’s name, home address, telephone number, but excludes any business contact information that is processed solely for the purpose of communicating with that person in relation to their employment or profession, any information that is anonymous or unidentifiable such as web browsing information or aggregate information, and any other information otherwise exempted pursuant to the applicable laws of Canada and other applicable jurisdictions.

    We will only process your personal information in accordance with this Statement, applicable laws and our ordinary business practices. This Statement only covers our processing of personal information.

  2. Third-party personal information

    We do not knowingly collect personal information about any third parties from you and you agree to not provide us with any such third-party personal information for any reason.

  3. Privacy Officer

    We have appointed a Privacy Officer who is responsible for our compliance with this Statement. Information on how to contact the Privacy Officer can be found below.

  4. Other Websites

    Our Portal, Software or Service may contain links or direct you to other third party’s websites, software, service providers or Internet resources (the “Other Providers”) that may interact with the Portal, Software or Service which are provided for your convenience, benefit, and information. When you access any Other Provider, you are contacting another website, software, service provider or Internet resource. We have no responsibility or liability for, or control over, those Other Providers or their processing of your personal information. We encourage you to read the privacy policies of the Other Providers to learn how they process your personal information.

2. Collection of Personal Information

When you use our Portal, Software or Service, we may collect the following personal information about you:
  • Contact information such as name, email address, mailing address, phone number
  • Demographic information such as year of birth, sex-at-birth, and ethnicity
  • Additional information to support your health assessment such as height, weight, lifestyle (e.g., nutrition, exercise) and general state of health/wellbeing/relationships/finances.

To ensure our Portal, Software or Service is optimized for your use and for future communications between us and you, we or our service provider (s) may save your user data in the form of cookies and use such cookies to collect standard Internet log information about how and when you use our Portal. This information may include, but not be limited to, your IP address and location data, weblogs, time, date, your language preferences, browser used, referring web addresses, other communication data, searches conducted, pages visited. You can manage your cookie preferences, but please note that if you refuse to allow cookies certain features of our Portal, Software or Service may not be available for your use.

3. Use and Disclosure of Personal Information

We may use and disclose your personal information for the following purposes as part of our Service through Portal or Software (the “Purposes”) to

  1. Verify eligibility and authenticate the identity of you (and your spouse/ partner/ eligible dependents where applicable)

  2. Assess and evaluate your health status via the Health Risk Assessment Tool

  3. Communicate with you to provide services, contacts, education, materials and/or recommendations related to your health as identified by your Health Risk Assessment or by you

  4. Provide you with promotional communications via email, if you have provided consent to receive and to which you may opt out of at any time (emails will not contain personal health information)

  5. Provide shipping information to prize fulfillment providers where necessary – third-parties used for these purposes sign non-disclosure agreements with People Corporation and are required to keep your personal information confidential

  6. Provide prize related information to your employer for taxable benefit reporting

  7. Provide you with a promotion code(s) to receive BestLife Rewarded bonus points

  8. Email and remind you of daily medication and refills required, if requested

  9. Ensure access to health data, claims data and other data used to enhance your use of the Portal and ensure seamless experiences

  10. Provide you access to third-party benefits, promotions, and discounts that reside outside of the Portal

  11. Perform research and analysis using anonymized data aimed at improving our products, services, and technologies. Research may involve conducting online surveys or focus groups in which you may accept or decline to participate

  12. Respond to your requests for assistance, or to resolve any technical issues you may encounter

  13. Ensure that the Portal, Software or Service is optimized for your use

  14. Provide you access to other People Corporation Portals, Software, and Services that reside outside of this Portal

  15. As otherwise required or permitted by law.

We will only process your personal information for the Purpose(s) outlined above. Otherwise, we will not process your personal information without your consent.

4. Your Consent

We will process your personal information only with your knowledge and consent, except where required or permitted by applicable laws. By using our Portal, Software, or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Statement and as may be further identified at the time of collection.

If you do not consent to the processing of your personal information in accordance with this Statement, please do not provide any personal information to us.

You may notify us at any time that you wish to withdraw or change your consent to our processing of your personal information, subject to legal restrictions and reasonable notice by (i) changing your privacy preferences to the extent such functionality is made available through the Portal, Software or Service, (ii) deleting your account with the Portal, Software or Service and stopping use of the Portal, Software or Service, (iii) opting out of the use of your personal information such as unsubscribing to any newsletter or mailing list subscription that we provide through the Portal. However, upon your withdrawal or change to your consent, we may not be able to provide you with access to the Portal, Software, or Service.

5. Security of Personal Information

The security of your personal information is important to us. We follow and employ generally accepted industry standards as appropriate to the sensitivity of your personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual, and technological safeguards to protect personal information, and require that our service providers do the same. We require that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so we cannot guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

6. Requests for Access to and Correction of Personal Information

Applicable Privacy Laws allow, to varying degrees, individuals the right to access, and request the correction of errors or omissions in, his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:
  • identification of personal information under our custody or control
  • information about how personal information under our control may be or has been used by us, and
  • the names of any individuals and organizations to which the individual’s personal information has been disclosed.

We will respond to requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

7. Retention of Your Information

We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.

8. Data Location

Your personal information collected by us will be processed and stored in Canada.

9. Updates or Changes to Privacy Statement

Privacy laws continue to evolve and, as a result, this Statement may be changed by us from time to time at our full discretion without any prior notice or liability to you or any other person. If we make any material changes, you will be required to re-accept the amended Privacy Statement terms.

10. Contact Information of Privacy Officer

You can direct any questions or concerns regarding our compliance with this Statement to our Privacy Officer by emailing at privacy.officer@peoplecorporation.com.

If you are not satisfied with our Privacy Officer’s response to their question or concern, you may be able to make a complaint under applicable privacy laws. Our Privacy Officer can provide you with the contact information to make such a complaint.

End of Privacy Statement (Last Updated: December 1, 2022).