LW Innovations Ltd.’s Privacy Policy 

Thanks for using the Last Words Website and Mobile App! LW Innovations Ltd. (“LW Innovations”) is committed to your right to privacy and recognizes your need for appropriate protection and management of any personal identifiable information you provide us. In this policy, we describe how we collect, use and handle the information retained when you use our Services. 

Capitalized terms not specifically defined herein shall have the meaning ascribed to them under our Terms. 

This Privacy Policy forms an integral part of LW Innovations’ Terms, including any warranty disclaimers and limitations on liabilities, as specified in the Terms. 

Please carefully review this Privacy Policy. If you choose to register to the Site, System and/or Services, you agree to the use of such information and data in accordance with this Privacy Policy. If you do not wish to be bound by the terms of this Privacy Policy, please discontinue using and accessing the Site. 

Protect Your Privacy LW Innovations’ Services are intended mainly for safekeeping and creation of Digital Assets, to allow our Users to share such Digital Assets with others (Trustees and/or Heirs) via the Services, and/or to publish such Digital Assets, including on social media. Digital Assets may contain sensitive and highly private information. Subject to our Terms, LW Innovations does not generally review or restrict what you create or choose to share via the Services. LW Innovations shall in no event be liable for content of any Digital Assets and you are solely responsible to protect your privacy by what you decide to voluntary, and at times publicly, share online. 

Information Collection 

The following information is collected in order to provide the Services and to understand the Users’ needs, including the improvement and protection of the Services: 

We collect information from and about the devices you use to access the Services. This includes data such as IP addresses, the type of browser and device you use, the web page you visited before coming to our Site, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. 

We also use technologies like cookies and pixel tags to provide, analyze, improve, protect and monitor our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. This information is non-personal information, anonymous, does not identified you as an individual or lead us back to any of our Users (except under specific circumstances described in this policy). You can visit our Site without cookies by programing your browser to block cookies, but please be aware that some features of the Site may not function properly and that such blocking may prevent us from providing some or all of the Services to you. Check the browser’s help menu to learn how to change your cookie preferences. 

Cookies that may be found on the Site but do not originate from LW Innovations are not covered by our Privacy Policy. We do not have access or control over these cookies. 

Personally Identifiable Information We may ask you to provide personally identifiable information for various reasons and at various times and accordingly we will collect only personally identified information that is specifically and voluntarily provided by you. For example, as a part of your registration process, or if you chose to fill out a profile, you may provide us with personal information such as your name, contact information, including email address and phone number, gender, date of birth, occupation, marital status, etc. We may also collect personal information and data if you submit it to us in other contexts by using the Services, for example, information regarding third parties, such as Heirs and Trustees or information submitted through the creation of Digital Assets. 

This privacy policy applies to the management of personally identifiable information in any form whether oral, electronic or written. LW Innovation reserves the right to amend this Privacy Policy from time to time. 

Use of Information The information collected via the System, including personally identifiable information, is used mainly in the following ways: 

To manage and administer your account, including to process and fulfill your instructions with respect to Trustees and Heirs, to identify you on our System, to send you information related to Services, to respond to your questions or comments, to inform you of material changes or additions to this Privacy Policy or our Terms, or to contact you with legal notices. In order to contact you we may use any of the contact details and methods you provided us with. To optimize the content we display and to provide you with a more personalized experience by serving you materials more relevant to your preferences. to analyze traffic and click stream patterns, demographics of our users base, interests and use of the Services, for general business analytics and in order to constantly improve and maintain our Services and for developing new features and services. To help prevent fraudulent use of our services and ensuring the technical functioning of our network. To send you special offers, promotions and marketing information, from us and our affiliates or from third parties we believe whose products and services may be of interest to you, by using any of the contact details and methods you provided us with. You may choose at any time to opt-out and to not receive these communications. To manage and develop its business and operations, including personnel and employment matters. To develop, enhance, market or provide products and services. To meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of the Company, provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy. If you choose to register or submit information to the Services, you agree to the use of such data in accordance with this Privacy Policy. 

The Site may contain links to our business partners or affiliates and links to other third party sites. Before you choose to provide any personally identifiable information to any of these third parties, please be aware that the collection and disclosure of your personal information will be governed solely by such entities privacy policy, and LW Innovations makes no representations or warranties of any kind regarding these policies nor assumes any responsibility thereof. 

Sharing of Information We may share non- personally identifiable information, aggregate information regarding Site and System usage with our affiliates, partners and advertisers. 

LW Innovations uses certain third parties providers who help us offer, improve, protect and promote our Services. These third parties may access your personally identifiable information and/or Digital Assets and/or personally identifiable information of a User’s Heirs and Trustees, only to perform tasks on our behalf and in compliance with this Privacy Policy. 

Notwithstanding anything to the contrary, LW Innovations reserves the right to disclose to law enforcement, regulatory or other government agencies and third parties, any information provided by you and/or gathered by us, including without limitation, personally identifiable information (including Trustees’ and Heirs’ personal details), as well as Digital Assets, in the event we believe that such disclosure is reasonably necessary for the purposes of: (a) complying with any applicable law, regulation, legal process or government request; (b) protecting any person from death or serious bodily injury; (c) preventing, detecting, counter measuring or otherwise addressing potential fraud or abuse or security or technical issues of LW Innovations or our Users; or (d) protecting the rights, property or safety of LW Innovations, including its subsidiaries, partners, affiliates or the public; (e) enforcing or applying LW Innovations Terms and other agreements. 

Information Security We follow generally accepted standards and take appropriate security measures to protect information submitted to us against unauthorized access to or unauthorized alteration, disclosure or destruction of data. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Please contact us if you have any questions about security on our Site or Application. 

Transfer of Information: At times, LW Innovations may use Third Parties outside of Canada to perform services which involve some or all of a User’s personally identifiable information. This may require transfer of information to those Third Parties. This information is subject to the laws of the Third Parties’ jurisdiction, including laws with respect to Disclosure of such information. Therefore, please note that any information that you share via the Service may be transferred out of your country or residence and you provide your consent to such transfer through the use of the Services. 

Minor’s Privacy Protection The Site and/or Services covered by this Privacy Policy are not designed for or intentionally targeted at children 18 years of age or younger. It is not our policy to intentionally collect, solicit or maintain information about anyone under the age of 18, except under explicit permission from such Minor’s parents or legal guardian. 

Obtaining Consent 

LW Innovations will make a reasonable effort to make sure Users understand how their personally identifiable information will be used. LW Innovations will obtain consent from Users before or when it collects or uses the personally identifiable information. LW Innovation will not attempt to deceive users into giving consent. 

Note: If any User at any time has any questions or concerns about the Privacy Policy, the user can email: Info@lastwords.com 

Refusing or Withdrawing Consent 

Subject to legal and contractual requirements, a User can refuse to Consent to LW Innovations’ Collection, use or Disclosure of personally identifiable information about the User, or a User may withdraw the User’s Consent to LW Innovations further collection, use or disclosure of personally identifiable information at any time in the future by giving LW Innovations reasonable notice, unless: i) the consent relates to certain information required for credit approval which a User applies for or accepts, ii) the consent is otherwise required by law or iii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If a User refuses or withdraws the User’s Consent, LW Innovations may not be able to provide the User or continue to provide the User with access to the Site, System and Services. 

If a User wishes to refuse or withdraw their consent to LW Innovations further collection, use or disclosure of personally identifiable information they may contact: info@lastwords.com 

Access and Correction 

A User may request that LW Innovations provide them access to their personally identifiable information or provide the information about the use or disclosure of their personally identifiable information. Note: that LW Innovations may refuse to provide access to a User’s personally identifiable information if: i) the information is protected by legal privilege; ii) the disclosure would reveal confidential information that is of a commercial nature and is not unreasonable to withhold that information, iii) the information was collected for an investigation or legal proceeding; iv) the disclosure of the information might result in that type of information no longer being provided to the organization when it is reasonable that that type of information would be provided; v) the information was collected by a mediator or arbitrator or was created in the conduct of a mediation or arbitration for which the mediator or arbitrator was appointed to act; vi) if the information related to or may be used in the exercise of prosecutorial discretion. 

LW Innovations shall not provide access to a User’s personally identifiable Information if: i)the disclosure of that information could reasonably be expected to threaten the life or security of another individual; ii) the information would reveal personal information about another individual; and/or iii) the information would reveal the identity of an individual who has in confidence provided an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity. 

If a User wishes to access or correct their personally identifiable information they may contact: disputes@lastwords.com 

General LW Innovations reserves the right to assign or transfer any and all of its rights herein without restriction or notification to you, including the information collected from you and our Users, to a successor entity in the event of a change of control of LW Innovations. In such case, the information transferred will remain subject to the terms and conditions set forth in any then applicable Privacy Policy. 

We may revise content and terms of this Privacy Policy at any time and without notice to you by updating this page, at our sole discretion. Any modification or change shall be effective upon posting by LW Innovations on the Site and/or System, and you agree to be bound to any such changes or modifications when you use the Site and/or System after any such change is posted. Users are advised to periodically check LW Innovations Privacy Policy and our Terms for any updates. 

For questions about our privacy policy, please contact us at info@lastwords.com. 

Last Updated: March 21, 2019