Website Privacy Policy

Updated:  April 22, 2019

Background

At Layla Care Inc. (“Layla”, “us” or “we”), we are committed to safeguarding and protecting your privacy. This privacy policy (the “Privacy Policy”) applies to: (i) Layla’s website found at: www.layla.care, including all webpages forming part of that website (“Webpages”); and (ii) any other websites, digital properties, audio offerings, mobile applications and/or mobile enabled sites that are owned and/or operated by Layla and that do not have a separate privacy policy (collectively, the “Website”). Webpages may contain policies or terms that are specific to their content (e.g. payment terms), and, unless expressly stated otherwise, such policies and/or terms are in addition to and not a substitution for the Privacy Policy.

By using the Website, you acknowledge that you:
• have read and understood this Privacy Policy; and
• and you agree and consent to the collection, use, and disclosure of your Personal Information (as defined below) in accordance with the terms of this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use the Website or supply your Personal Information to us. You must only submit Personal Information about another individual if you have the consent of that individual (or their legal guardian or substitute decision-maker, where applicable). Failure to obtain such consents is your responsibility, and not that of Layla.

If you sign up to receive paid services from Layla, you will be sent a client intake / profile form. The Client Intake Form requests much more detailed Personal Information and as such, is subject to a different privacy policy that can be accessed at www.layla.care/privacy-policy

Purpose of Privacy Policy

The purpose of this Privacy Policy is to inform you about the types of Personal Information we collect, use, and disclose in providing you with the Website. It explains:
• 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.

CONTENTS

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

Amendments to Privacy Policy

From time to time, we may make changes to this Privacy Policy.  The Privacy Policy is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Policy under which it was collected, unless we have your consent to treat it differently.

1. What is Personal Information and what Personal Information do we collect?

“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.

2. How and when do we collect Personal Information?

We will always collect Personal Information by fair and lawful means.  We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent to do so, or as otherwise required or permitted by law.  Generally, however, we collect Personal Information directly from you when you voluntarily provide it in the course of using the Website. For example, Personal Information may be collected when you visit the Website, request information from us, or register for an account through the Website. In any event, we limit our collection of Personal Information to that which is necessary to fulfill the purposes identified in this Privacy Policy. We collect, use and disclose your Personal Information only in accordance with this Privacy Policy.

3. Where do we store Personal Information?

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.

4. For what purposes do we collect your Personal Information?

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.

5. What safeguards have we implemented to protect the Personal Information that you provide?

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.

6. Who will have access to the Personal Information that you provide?

Your Personal Information will also be accessible to our employees and third party service providers on a “need-to-know” basis (i.e. where the employee or service provider requires such information to assist us with a Purpose). However, prior to gaining access to your Personal Information, we require all of our employees and third party service providers to enter into agreements with us under which they are bound to abide by applicable law (including privacy laws), this Privacy Policy and our other related policies and procedures.

7. To whom do we disclose Personal Information that you provide?

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.

8. When and how do we obtain your consent to collect, use and disclose Personal Information?

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).

9. Cookies, Google Analytics, etc.

(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 also used for the following reasons:•When you return to the Website, cookies enable us to retrieve the information you previously provided, to help you more easily use the features that you customized. Because of our use of cookies, we can deliver faster and more accurate results and a more personalized Website experience. For example, if you register for Website, a cookie helps us to recall your specific information (such as user name, password and preferences).• When you watch a video clip or listen to an audio clip on through the Website, a cookie may take note of which media player (such as Real Player or Windows Media Player) and which type of clip (high or low bandwidth) you prefer to use on your computer. Note, however, that you can change your video and audio preferences at any time, or choose a player each time you view or listen to a clip.• Some parts of the Website use cookies to track your traffic patterns. We do this in order to determine the usefulness of the Website's information to our users and to see how effective our navigational structure is in helping users reach that information. The Layla does not correlate this information with data about individual users, nor does it share this information or sell it to any third party.• We also use cookies to identify users who have been banned from using the Website or any of our forums for behaviour that contradicts the Terms and to track click streams, for load balancing and to enable you to navigate through the Website using redirection pages.

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 a copy of Google’s Privacy Policy: http://www.google.com/intl/en/policies/privacy/
• 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/

10. How long will we use, disclose or retain Personal Information that you provide to us?

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.

11. How can you contact Layla about privacy concerns?

Our Chief Privacy Officer can be contacted by emailing: contact@layla.care or by calling: 1-888-695-2952. You have the right to request access to the Personal Information we have collected about you. You may request their Personal Information by submitting a written request to our Chief Privacy Officer. If you believe there is a mistake in your Personal Information you have the right to request that it be corrected, by sending a request to our Chief Privacy Officer.  If you have any other questions about this Privacy Policy or our privacy-related practices and procedures, please contact our Chief Privacy Officer.

12. Other Information

Links to websites and social media platforms not under Layla’s control are provided for your convenience only (“Third Party Websites”). We:
• We also do not endorse the Third Party Websites or their content. This Privacy Policy does not apply to Third Party Websites.  
• 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.

You should review the privacy policy (together with the terms and conditions of use) of any Third Party Websites before providing any personal or other information.