By using the Website, you acknowledge that you:
• how we collect, use and disclose Personal Information;
• the choices you have regarding the use and disclosure of Personal Information; and
• how you may correct Personal Information.
1. What is Personal Information and what Personal Information do we collect?
2. How and when do we collect Personal Information?
3. Where do we store Personal Information?
4. For what purposes do we collect your Personal Information?
5. What safeguards have we implemented to protect the Personal Information that you provide?
6. Who will have access to the Personal Information that you provide?
7. To whom do we disclose Personal Information that you provide?
8. When and how do we obtain your consent to collect, use and disclose Personal Information?
9. Cookies, Google Analytics, etc. (a) Cookies - Generally (b) Google Analytics (c) Facebook Pixel
10. How long will we use, disclose or retain Personal Information that you provide to us?
11. How can I contact Layla about a privacy concern?
12. Other Information
“Personal Information” is any information that about an identifiable individual. The type of Personal Information that we may collect may include, for example, name, contact information, such as email address and residential address, social media identifiers (e.g. Twitter handle and Facebook profile, etc.), internet protocol (IP) address, and other information that falls within the definition of “Personal Information” that we did not request, but that you provide to us.
We store Personal Information that you provide on our servers or those of our service providers. Personal Information may be sent to another jurisdiction for processing and while the information is in another jurisdiction it may be accessed by the courts, law enforcement and national security authorities of such jurisdiction.
Generally, we identify the purposes for which we use the Personal Information that you provide at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use Personal Information for the following purposes:
• providing information to you regarding products and services that Layla believes may be of interest to you;
• to send you information and updates regarding Layla and the products and services we offer;
• to respond to your inquiries, questions, and/or other requests;
• to de-identify it (i.e. make it so that it is no longer identifies you). Layla may use de-identified information (i.e. information that is no longer Personal Information) for any reason it determines appropriate;
• to permit you to use some of the online tools available on our Website;
• for such other uses of Personal Information for which you provide your consent from time to time; and
• as otherwise permitted or required by applicable law.
We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification.
We will only disclose your Personal Information where we are permitted and/or required by applicable law to do so. We identify to whom, and for what purposes, we may disclose Personal Information, at the time we collect such information from the individual to whom it relates (or their legal guardian or substitute decision maker, as applicable) and obtain such that individual’s consent to such disclosure except as required or permitted by applicable law. For example, in accordance with section 7(2)(b) of PIPEDA, Layla may, without knowledge or consent, use Personal Information for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. In the event that we are required by applicable law to disclose your Personal Information without your consent, we will aim to disclose only the specific information that is required in the circumstances and, where required and/or if permissible, will inform you about the disclosure.
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing any Personal Information you provide to us for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances. We also require users who are submitting Personal Information to the Website that is about another individual, to only do so if they have the consent of that individual (or their legal guardian or substitute decision-maker, as applicable).
(a) Cookies - Generally
The Website may use “cookies” to help personalize and maximize your online experience. Cookies are text-only pieces of data that a website transfers to your hard drive or other website-browsing equipment for record-keeping purposes. Cookies often include unique, non-personal identifiers and permit the Website to recognize you and to keep track of your preferences. Three types of cookies may be employed during your visit to the Website: • third-party cookies: these are installed by third parties (including Google and Facebook, as described below in paragraphs (b) and (c) of this Section 9) with the aim of collecting certain information to carry out various research into behaviour, demographics, etc. An example of such a cookie is Facebook like button or sharing on social media options;•“session” cookies, which are not permanently stored on your hard drive and are permanently deleted from your computer after two hours of inactivity or when you end your session (i.e. leave the Website), and are used solely to help you to navigate the Website; and•“persistent” cookies, which remain on your computer so that the Website can recognize you when you return. Persistent cookies will remain on your computer after you have left our Website and will expire when you log out of the Website, or 60 days after your last visit for security cookies.
Cookies are not used to run programs or to deliver viruses to your computer. Cookies are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you.
Please note that while most browsers are initially set to accept cookies, you have the ability to disable cookies if you wish, generally through changing your internet browser settings. It may also be possible to change your browser settings to enable acceptance of specific cookies. For more information on enabling and disabling cookies, please refer to the help section on your browser. Disabling cookies may cause some of the Website or functions of the Website to become unavailable or inaccessible.
(b) Google Analytics
The Website may use web analysis services provided by Google Inc. (“Google”), specifically, “Google Analytics” and “Google Tag Manager”. Among other things, Google Analytics would track traffic to, from and within the Website and provide Layla with information regarding use of the Website. Information collected by Google, including cookies and usage data, is processed in the United States of America and may be subject to the laws of that jurisdiction (including the federal Patriot Act). Google Analytics may:• set or read cookies on browsers of users of the Website; and • otherwise receive information from users’ browsers. However, prior to being stored on Google’s servers, your IP address is anonymized.
For more information on Google Analytics, please visit:
• For further information regarding how Google uses information from sites or applications that use Google’s services: www.google.com/policies/privacy/partners/
• To opt out of Google Analytics data collection and/or to obtain instructions on removing Google Analytics from your browser: https://tools.google.com/dlpage/gaoptout
(c) Facebook Pixel
The Website may also use Facebook Pixel to better understand the actions taken by users of the Website and to offer such users products and/or services in line with their interests, by providing measurement services and targeted ads.
For more information on Facebook Pixel, please visit:
• For a copy of Facebook’s Data Policy: https://www.facebook.com/about/privacy/
• For further information on cookies and other storage technologies used by Facebook, including information on how to opt-out of same: https://www.facebook.com/policies/cookies/
We will use, disclose or retain Personal Information that you provide to us for as long as necessary to fulfill the Purpose(s) for which that Personal Information was collected, and as permitted or required by applicable law.
Links to websites and social media platforms not under Layla’s control are provided for your convenience only (“Third Party Websites”). We:
• Do not offer any guarantee and are not responsible for the information found through the Third Party Websites.
• Disclaim any and all liability for Third Party Websites including the accuracy and reliability of the content of such websites.