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.
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.
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.
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.
Use of Information The information collected via the System, including personally identifiable information, is used mainly in the following ways:
Sharing of Information We may share non- personally identifiable information, aggregate information regarding Site and System usage with our affiliates, partners and advertisers.
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.
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.
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: email@example.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: firstname.lastname@example.org
Last Updated: March 21, 2019