February 24, 2022
1. The data we collect about you
Generally, you control the type and amount of information you provide us when you download and use the app, create an account, subscribe to a service we provide or request notifications to be sent to you. The data we process and how it is used depends on how you use the app and the information you choose to store. Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (Non-Personal Data). We do not collect or hold your Personal Data other than (1) for the creation of a user account; (2) for the purpose of supporting you in your use of the app; or (3) based on the necessity of performance of a contract we have with partner companies who subscribe to our service to use the app to communicate, interact or transact with you. Our legal basis for collecting and using your Personal Data will be based on the necessity of performance of a contract with you and to respond to, and support, service issues.
Personal Data that we collect would include:
Your name or other contact details;
Your username and/or email address when you activate an account to use the app;
Messages you send to us by email, social media, mail or other means;
Any personal information that you input into the app;
Any personal information about other individuals that you may input into the app; and
Any other personal information you may provide to us voluntarily through your use of the app and our services.
When we communicate with you, we will use the email address you provide when you registered as a User. You may change your contact preferences at any time through your on-line account.
Personal Data from Third Parties
We provide the ability for third parties to share data with us for storage in the app digital wallet on your mobile device. We are not in control of the personal data held by the third party or any processing by that third party or the content or accuracy of that personal data when it arrives. You should refer to the third party for this information. We rely on the explicit consent which you give to the third party prior to receiving data from them so that we can create a record of that information in your app digital wallet.
Information We Collect Automatically
We automatically collect information (“Technical and Usage Data”) regarding the actions you take when using the app. In some countries this information may be considered Personal Data under applicable data protection laws. Technical and Usage Data helps us understand trends in our users' needs so that we can better consider new features or otherwise improve the app.
When you use the app, some examples of the Technical and Usage Data we collect could include:
The type of mobile device you use;
Your mobile device's unique device ID;
the IP address of your mobile device;
Your mobile operating system;
The type of mobile Internet browsers you use;
Available storage space;
Connection type (e.g. WiFi vs. cellular); and
information about the way you use the application.
We may store such Technical and Usage Data itself and/or such information may be included in databases managed by our third party service providers. We use this information and pool it with other information to track, for example, the total number of users of our app. We use this information to help us understand how people use the app and to make enhancements to it.
We may also use GPS technology (or other similar technology) to determine your current location. If you do not want us to have your location information, you should turn off the location services for the mobile application located in your mobile phone settings and within the app.
2. Tracking Technologies
Most web browsers are initially set up to accept cookies. You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser's "help" directory. However, certain features of our website may not work if you delete or disable cookies.
3. How We Use Your Information
We will use your Personal Data for the following purposes:
Business Relationship: We will use your Personal Data to manage our business relationship with you and to support your use of the app. We may also use your Personal Data to meet contractual requirements with companies that subscribe to the app and use it to interact or transact with you, for example to complete a quotation that you have requested for home or auto insurance.
Providing Monitoring and Support: We will use your Personal Data to provide you with access to, and support for, your use of the app and to monitor your use of the app. If you have any technical problems using the app, you have the option of requesting live support from Brunvalley. In providing support, we may have access to your Personal Data
Requests: If you contact us by email or otherwise, we will use the Personal Data you provide to answer your question or resolve problems.
Other Products, Services and Events: We may use your Personal Data to contact you in the future about products, services and events that may be of interest to you. You can opt-out of such contact from Brunvalley using the unsubscribe link in email communications or contact us directly.
Customer Data is data and information, including Personal Data, owned and provided by our customers that subscribe to our service to use the app to interact with their client base. Brunvalley only uses Customer Data according to instructions from our customer.
Service Improvement: Brunvalley may use your Personal Data and other information collected through the app and our website to help us improve the content and functionality of the app. Brunvalley may also use aggregated anonymous data about your use of the app that is not identifiable with respect to an individual to better understand our users and to analyze, improve, support and operate the app.
Note to draft: are users able to backup their LifesWallet account in our environment to allow them to recover it or access it from a different device?
Brunvalley will never sell Personal Data or Customer Data. For data aggregation purposes we may use your Non-Personal Data but any such data aggregation would not include any of your Personal Data.
4. Who We Share Your Personal Data With
As the circumstances warrant, we will disclose your Personal Data to the following categories of recipients:
To our partner companies or customers who have subscribed to our services to use the app to communicate and interact with you and who you have consented to interact with and/or receive notifications from;
To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
In response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Brunvalley will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and any other content and information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to or comply with legal requests (including court orders and subpoenas) (i) to protect the safety, property or rights of Brunvalley or of any third party; (ii) to prevent or stop any illegal, unethical, or legally actionable activity, or (iii) to comply with the law;
To any other person with your consent to the disclosure.
5. Your Interaction with Third Parties
The app allows you to interact with our partners and customers or other third parties and to share your Personal Data with them. You are in complete control of your interactions. Where you agree to allow third parties to receive, collect, see or share data about you, we are not in control of those third parties and are not responsible for their privacy statements or the way in which they use your data. All of your activity on the app is encrypted through secure technology, meaning all data, excluding photographs you may upload, that is exchanged between you and the app and anyone you choose to share your data with is secure.
We recognize our legal obligations to protect the Personal Data we have gathered about you. We have therefore implemented appropriate technical and organizational measures to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of Personal Data. These arrangements include industry-standard security measures including physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access. Unfortunately, because of the inherent nature of the Internet, we cannot guarantee against the possible loss or misuse of your Personal Data. We strongly urge you to protect any passwords you have to the app and not to share them with anyone.
7. Data Retention
We will retain your information for as long as your account is active or where we have an ongoing business need to do so (for example, to comply with applicable legal, tax, or accounting requirements). We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it; or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. As noted above, we may retain your Non-Personal Data for an indefinite period and use it for data aggregation and statistical analysis purposes.
8. Third Party Links
9. Third Party Service Providers
We use third-party service providers to provide some services that are necessary or ancillary to the services we provide, such as for data storage, and some of these services may include processing Personal Data. External third parties include providers of our cloud services such as AWS and Google. These service providers are located in Canada. In order to provide security and confidentiality or your Personal Data, Brunvalley has undertaken contractual and other measures to ensure our service providers provide adequate protection for Personal Data and that all processing is done with an appropriate level of confidentiality and security. Where we use service providers to support our app, we may transfer personal data outside of Canada but will ensure appropriate safeguards are in place including only transferring information to countries and service providers deemed to provide an adequate level of protection and security measures.
11. How to Contact Us
If you have any questions or concerns about our policy or use of your Personal Data, please contact us by email at [insert email address] or by using the contact details below:
Brunvalley Cloud Solutions Inc.
315 Hampton Road
Quispamsis, NB E2E 4M9