Privacy Policy - LIV Magazine

This privacy policy describes how our company collects, uses and discloses your personal information and data when you use our services through our websites and/or application.

This Privacy Policy outlines Sommer Digital Inc. ("we", "our" or "the Company"), owner and operator of LIV Magazine webApp and mobile application, practises with respect to information collected from Users who access our Mobile Application (App) or otherwise share personal information with us (collectively: "Users").

Grounds for data collection

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are or may be subject too.

This Personal Information Protection Policy, in compliance with PIPEDA, outlines the principles and practises we will follow in protecting personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our App Users’ personal information and allowing our App Users to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to LIV Magazine.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of LIV Magazine

When you use the App, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.

What information we collect on our webApp

We collect two types of data and information from Users.

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the App (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our App. We may also collect information on your activity on the App (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the App.

Survey Information: When you participate in a survey on our App you may be required to submit information such as age, income, rankings, feedback and other requirements to provide the information required out of the survey.

Contest Information: When you participate in a contest, we may request additional information as part of the contest entry requirements. This could include age, income, rankings, feedback and other requirements.

Program Information: From time to time, we introduce temporary or permanent programs, such as a birthday club, where you may be required to provide additional information such as age so we can professionally deliver on the program promises.

Registration information: When you register to our App you will be asked to provide certain details such as: full name; e-mail or physical address, and other information.

How do we receive information about you?

We receive your Personal Information from various sources:

When you voluntarily provide us your personal details in order to register on our App;

When you use or access our App in connection with your use of our services;

From third party providers, services and public registers (for example, traffic analytics vendors).

What information do we collect?

Your privacy is important to us. We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our App or access our services.

A "cookie" is a small piece of information that a App assigns to your device while you are viewing a App. Cookies are helpful and can be used for various purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier.

The App uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;

b. 'persistent cookies ' which are read only by the App, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our App may not operate properly, and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the App. Google Analytics collects information such as how often Users access the App, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our App and services. Google Analytics collects the IP address assigned to you on the date you visit Apps, rather than your name or other identifying information. We do not combine the information collected using Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this App is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or Apps throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

What information we will collect on the App

We collect two types of data and information from Users.

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the App (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our App. We may also collect information on your activity on the App (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the App.

Survey Information: When you participate in a survey on our App you may be required to submit information such as age, income, rankings, feedback and other requirements to provide the information required out of the survey.

Contest Information: When you participate in a contest, we may request additional information as part of the contest entry requirements. This could include age, income, rankings, feedback and other requirements.

Program Information: From time to time, we introduce temporary or permanent programs, such as a birthday club, where you may be required to provide additional information such as age so we can professionally deliver on the program promises.

Registration information: When you register to our App you will be asked to provide certain details such as: full name; e-mail or physical address, and other information.

Geographic Location Information: This App may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this App. Personal Data collected: Geographic position.

Access to third party services' accounts: These services allow this App to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.

Access to the Facebook account (This App): This service allows this App to connect with the User's account on the Facebook social network, provided by Facebook Inc. Permissions asked: Check Ins, Email, Likes, Photos and Publish App Activity.

Content commenting: Content commenting services allow Users to make and publish their comments on the contents of this App. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when users do not use the content commenting service.

Facebook Comments (Facebook): Facebook Comments is a content commenting service provided by Facebook Inc. enabling the User to leave comments and share them on the Facebook platform. Personal Data collected: Cookie and Usage Data.

Interaction with external social networks and platforms: These services allow interaction with social networks or other external platforms directly from the pages of this App. The interaction and information obtained by this App are always subject to the User’s privacy settings for each social network. If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook): The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook Inc. Personal Data collected: Cookie and Usage Data.

How we receive information about you

We receive your Personal Information from various sources:

When you voluntarily provide us your personal details in order to register on our App;

When you use or access our App in connection with your use of our services;

From third party providers, services and public registers (for example, traffic analytics vendors).

Your privacy is important to us. We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our App or access our services.

A "cookie" is a small piece of information that an App assigns to your device while you are viewing an App. Cookies are helpful and can be used for various purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier.

The App uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;

b. 'persistent cookies ' which are read only by the App, saved on your mobile phone for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze app usage.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our App may not operate properly, and your online experience may be limited.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or Apps, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

Facebook permissions asked by this app

This App may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy. The permissions asked are the following:

Basic information: By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the user has made more of their data public, more information will be available.

Check Ins: Provides read access to the authorised user's check-ins

Email: Provides access to the user's primary email address

Likes: Provides access to the list of all of the pages the user has liked.

Photos: Provides access to the photos the user has uploaded, and photos the user has been tagged in.

Publish App Activity: Allows the app to publish to the Open Graph using Built-in Actions, Achievements, Scores, or Custom Actions. The app can also publish other activities which are detailed in the Facebook Publishing Permissions document.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the App Users voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either in writing, before or at the time of collection.

1.2 We will only collect App Users information that is necessary to fulfil some or all of the following purposes:

To verify identity;
To identify App Users preferences;
To open and manage an account;
To deliver requested products and services
To guarantee a reservation;
To provide a donation receipt (if eligible and required);
To enrol App Users in a program;
To send out membership information;
To contact our App Users for fundraising;
To ensure a high standard of service to our App Users;
To meet regulatory requirements;
To collect and process payments for goods and services

1.3 In addition to the different uses listed above, we may transfer or disclose Personal Information to our subcontractors.

1.4 In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be in different jurisdictions across the world, for any of the following purposes:

Hosting and operating our App;
Providing you with our services, including providing a personalised display of our App;
Storing and processing such information on our behalf;
Providing you with marketing offers and promotional materials related to our App services;
Performing research, technical diagnostics, or analytics;

Policy 2 – Consent

2.1 We will obtain App Users consent to collect, use, or disclose personal information (except where, as noted below, we are authorised to do so without consent).

2.2 Consent can be provided electronically, through an authorised representative, in writing or orally or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the App Users voluntarily provide personal information for that purpose.

2.3 Consent may also be implied where an App User is given notice and a reasonable opportunity to opt-out of their personal information being used for mail-outs, the marketing of new services or products, fundraising and the App User does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), and App Users can withhold or withdraw their consent for Sommer Digital Inc. to use their personal information in certain ways. A user's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service, product or offer. If so, we will explain the situation to assist App Users in making the decision.

2.5 We may collect, use or disclose personal information without the App Users knowledge or consent in the following limited circumstances:

When the collection, use or disclosure of personal information is permitted or required by law;
In an emergency that threatens an individual's life, health, or personal security;
When the personal information is available from a public source (e.g., a telephone directory);
When we require legal advice from a lawyer;
For the purposes of collecting a debt;
To protect ourselves from fraud;
To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose personal information where necessary to fulfil the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

Conducting App Users surveys to enhance the provision of our services, provide entertainment, gather user generated content;
Contacting our App Users directly about products and services that may be of interest;
Contacting our App Users about a contest and winners;
Contacting our App Users about unique offers and promotions

3.2 We will not use or disclose App Users personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell App Users lists or personal information to other parties unless we have consent from our App Users to do so.

Policy 4 – Retaining Personal Information

4.1 If we use App Users personal information to make a decision that directly affects the App Users, we will retain that personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

4.2 Subject to policy 4.1, we will retain App Users personal information only as long as necessary to fulfil the identified purposes or a legal or business purpose.

4.3. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications, and anything else as required by applicable laws and regulations.

4.4 We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that App Users' personal information is accurate and complete where it may be used to make a decision about the App Users or disclosed to another organisation.

5.2 App Users may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer or designated individual.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organisation to which we disclosed the personal information in the previous year. If the correction is not made, we will note the App Users correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of App Users' personal information in order to protect it from unauthorised access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that personal information is appropriately protected:

The use of App Users ID’s, passwords, encryption, firewalls
Restricting access to only persons who need to know
In the case of printed material, the use of locked filing cabinets, securing rooms where the personal information is held.
Require any service providers to provide comparable security measures.

6.3 We will use appropriate security measures when destroying personal information such as:

Deleting electronically stored information
Properly destroying physical drives so they cannot be operated
Confidentially shredding printed documents

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

6.4 Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse of our App, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Policy 7 – Providing App Users Access to Personal Information

7.1 App Users have a right to access their personal information, subject to limited exceptions including;

the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
the disclosure would reveal personal information about another individual;
the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.
the information is protected by solicitor-client privilege;
the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organisation;
the information was collected or disclosed without consent, as allowed under section 12 or 18, for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;
the information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act:
- under a collective agreement,
- under an enactment, or
- by a court.
The information is in a document that is subject to a solicitor's lien.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer or designated individual.

7.3 Upon request, we will also tell App Users how we use their personal information and to whom it has been disclosed if applicable. You may request to:

Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
Request rectification of your personal information that is in our control.
Request erasure of your personal information.
Object to the processing of personal information by us.
Request to restrict processing of your personal information by us.
Lodge a complaint with a supervisory authority.

7.4 We will make the requested information available within 30 business days or provide written notice of an extension where additional time is required to fulfil the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the App User of the cost and request further direction from the App User on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the App User in writing, providing the reasons for refusal and the recourse available to the App User.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or designated individual is responsible for ensuringSommer Digital Inc. compliance with this policy and the Personal Information Protection Act.

8.2 App Users should direct any complaints, concerns or questions regarding Sommer Digital Inc. compliance in writing to the Privacy Officer or designated individual. If the Privacy Officer or designated individual is unable to resolve the concern, the App User may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for the LIV Magazine App Privacy Officer or designated individual:

Email: oliver@sommerdigital.ca

Policy 9 – Processing of App Users Information

9.1 The Data Controller or others designated by the Data Controller processes the data of App Users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

9.2 The data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

9.3. In addition to the Data Controller, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the App administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the owner. The updated list of these parties may be requested from the Data Controller at any time.

Policy 10 – Third Party Platforms and Services

10.1 Access to third party services' accounts, location-based interactions, content commenting and interaction with external social networks and platforms can be included in our App.

10.2. Users on our App may interact with social media platforms including Facebook, Instagram, YouTube, Tumblr, TikTok, Twitter, Snapchat and other social media platforms that are currently available or new social media platforms that may come online in the future. The services allow interaction with social networks or other external platforms directly from the pages of our App. The interaction and information obtained by the App are always subject to the Users privacy settings for each social network. If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.

10.4 We may use various links to display information within the App. App Users should refer to the displayed information Apps to understand their privacy policies which may differ from ours.

Policy 11 – Content Posting and Commenting

11.1 Content commenting services allow App Users to make and publish their comments on the contents of this application. Depending on the settings chosen by the owner, App Users may also leave anonymous comments.

11.2 If there is an email address among the personal data provided by the App Users, it may be used to send notifications of comments on the same content, including content that may be offensive or contradicts our privacy and contesting policies.

11.3 App Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when App Users do not use the content commenting service.

Policy 12 – Additional Information About Data Collection and Processing

12.1 The personal data may be used for legal purposes by the Data Controller or others designated by the Data Controller, in court or in the stages leading to possible legal action arising from improper use of this application or the related services.

12.2 The App Users are aware of the fact that the Data Controller may be required to reveal personal data upon request of public authorities.

12.3 The App does not support “Do Not Track” requests.

12.4 To determine whether any of the third-party services the App uses honor the “Do Not Track” requests, please read their privacy policies.

12.5 The Data Controller or anyone designated by the Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If an App user objects to any of the changes to the policy, the App user must cease using the App and can request that the Data Controller or anyone designated by the data controller erase the personal data. Unless stated otherwise, the then-current privacy policy applies to all personal data the Data Controller has about App Users.

Last updated September 18, 202

Veronica Alastre