Golden Aging Answers, a sole proprietorship registered pursuant to the laws of the province of British Columbia, Canada, (“Golden”, “we”, “our” or “us”) respects the privacy of our customers and users and understands the importance of complying with applicable data protection laws. We have adopted the following Privacy Policy to address how we collect, use, disclose and safeguard your information.

This Privacy Policy is based on, and complies with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official website of the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/.

Definition of “Personal Information”

When used in this Privacy Policy, and consistent with applicable Canadian data protection laws, “Personal Information” means any information about an identifiable individual. This may include, without limitation, the individual’s name, date of birth, age, gender, marital status, email address, mailing address, telephone number, income, credit history, financial information, personal preferences and other information about the individual’s family.

Personal Information does not include: (i) information pertaining to an organization as distinct from an individual person; (ii) information provided by an individual in the capacity of an employee of an organization; (iii) an individual’s name, address, telephone number or email address which is listed on a directory or is available through directory assistance; and (iv) other information that is publicly available and is specified by regulations under PIPEDA and similar provincial legislation.

The Information We Collect

The information that we collect depends on how you engage with Golden, the services that you request, your location and applicable law. However, the information that we collect broadly falls into the following categories:

(a) Information from You

You may voluntarily provide certain Personal Information about you to us by mail, by email, over the telephone, through our website or in any other direct manner. For example, we collect Personal Information when you purchase or subscribe for our content and services, create an account, send questions or comments, or otherwise communicate with us through or about our website and content.

The types of personal information that you provide may include your name, email address, telephone number, mailing address, credit card information, and other contact or identifying information that you choose to provide.

If you participate in a video conference with us, we may record the session and retain the recordings. We will notify you first that the session is being recorded so that you can choose not to participate.

(b) Information from Other Sources

We may obtain personal information from third parties and combine such information with the information that we collect from you and such information may be used for the purposes described in the “How We Use Your Information” section below. For example:

• You give permission to those third parties to share your information with us or where you have made that information publicly available online.
• You create or log into your account through a third-party social networking site or one of our integration partners, we will have access to certain information from that service such as your name and account information.
• If you purchase or subscribe to our contents and services, we may receive information from our third-party payment processors.
• We may collect information from unaffiliated third parties so that we can better understand you and provide you with information and offers that may interest you.

(c) Information from Online Technologies

We collect certain types of information electronically, such as information about your device and your use of our website, through technologies such as cookies and web and mobile analysis services. This information helps us understand what actions you take on our website and to ensure that our website is functioning normally. Further information is provided below in the section titled “Anonymous Information and Cookies”.

By accessing our website, you accept the terms of this Privacy Policy and consent to the collection and use of your personal information as set forth in this Privacy Policy. If you do not agree or consent to this policy, please do not use the website.

How We Use Your Information

Golden uses and discloses your Personal Information for the purposes for which it was collected, including:

• Providing you access to our products, contents and services
• Processing payments
• Establishing and maintaining communications with you
• Responding to your inquiries about our products, contents, accounts and other services
• Monitor and evaluate trends, usage, and activities in connection with our website and contents
• Meeting legal requirements

Your Personal Information will not be used without your consent for purposes other than for the purpose for which it was collected, including those listed above, or in accordance with applicable laws. From time to time, we may collect Personal Information for new or additional purposes, in which case we will amend this Privacy Policy to include these new or additional purposes and will obtain your consent through your continued use of our website and services.

You may withdraw your consent at any time, subject to any legal implications. In some cases, if you do not consent to our use or disclosure of certain Personal Information, we may be unable to continue to provide all or part of the contents and services you have requested. You may withdraw your consent by contacting the Privacy Officer through the contact information listed below.

Personal Information may be anonymized and consolidated into group data, which may be shared on an aggregated basis with research firms. The shared data will not disclose your Personal Information and will not enable the recipients to contact you. This Privacy Policy does not apply to aggregated data from which it is not possible to determine the identity of a specific individual. Golden reserves the right to use aggregated data in any way that it determines appropriate.

Disclosure of Personal Information

Golden may disclose your Personal Information in the following circumstances:

(a) In the course of business

Employees of Golden with a legitimate reason for accessing your Personal Information may have access to your Personal Information in the course of business. They must follow all applicable laws and regulations, including this Privacy Policy. Any unauthorized use of or disclosure of Personal Information by any of our employees is prohibited and may result in disciplinary measures.

(b) Services from Third Parties

From time to time, we may use and disclose your Personal Information to our affiliates, service providers, data processors and other third parties (“Third Parties”) in order to meet your needs, provide you with services offered through us or as otherwise authorized by you. In these circumstances, the Third Parties are only given the information that is needed in order to render their service to us. The Third Parties receiving the Personal Information are obligated to keep such information confidential and secure and are prohibited from doing anything with this information that we have not authorized them to do. If required or permitted to do so by law, we will disclose your Personal Information to Third Parties without obtaining your prior approval or providing you with notice thereof.

Our website is hosted through Kajabi, a website hosting and management platform. They provide us with the online platform that allows us to sell and provide our products, contents and services to you. Your data is stored through Kajabi’s data storage, databases and the general Kajabi application. They store your data on a secure server and handle your data in accordance with applicable laws. We encourage you to also review Kajabi’s Privacy Policy at https://kajabi.com/policies/privacy and their Terms of Service at https://kajabi.com/policies/terms.

(c) Sale or Transfer of Business or Other Transaction

We may disclose or transfer your Personal Information to Third Parties as part of a merger, acquisition, debt financing or sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which Personal Information is transferred to Third Parties as one of our business assets.

(d) Other Permitted Reasons

Golden may be required to disclose Personal Information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. We may also disclose information to a government body or agency in order to comply with tax reporting requirements as well as to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers in emergencies or where required or permitted by law. We may also release certain Personal Information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or personal safety of Golden, its clients, employees or other members of the public, in accordance with or as authorized by law.

How We Safeguard Information

We restrict access to Personal Information to those employees of ours and Third Parties who need to know your Personal Information in order to provide products or services to you. We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain regarding clients. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information.

At all times, Golden adheres to applicable legal or regulatory requirements concerning the storage and protection of Personal Information. Where the services of Third Parties are used, these Third Parties and the databases where they store Personal Information may be located outside of Canada. As a result, when your Personal Information is used or stored in a jurisdiction outside of Canada, it may be subject to the laws of that jurisdiction in which it is located.

Anonymous Information and Cookies

Our website collects anonymous information about how our website is used. This means that the information collected cannot be traced back to a specific person. For example, our web servers record certain information automatically from your web browser or mobile device when you visit our website. This information is collected using “cookies”, which are small text files that are saved on your computer when you visit a website that uses cookies, and may include the pages you visited, your IP (Internet Protocol) address, the type of mobile device you use, web browser type and other site usage statistics. This anonymous information is used for research and analytical purposes only in order to better understand how our website is being used and to improve the functionality of the site. It does not reveal any Personal Information about you, the user. This aggregate data may be disclosed to Third Parties, but never with personally identifying information in the resulting data. Most major websites use this technology and most browsers are set up to accept them. You may configure your browser to notify you when you receive a cookie and you may refuse to accept them entirely. However, if you refuse to accept cookies, you may limit the functionality that we can provide to you when you visit our website. You may choose to delete cookies after visiting our website.

Google Analytics

Our website may use Google Analytics, a web and mobile analysis service provided by Google that facilitates an analysis of your use of our website. You may opt out of Google Analytics by installing a deactivation plug-in from Google that will provide you with more control over what data Google can collect on websites you access. However, the deactivation plug-in does not prevent information from being transmitted to us or to other web and mobile analysis services that we may use.

Data Security

Unfortunately, the transmission of information over the internet is not completely secure. Although we will take reasonable steps to protect your Personal Information, you agree to do so at your own risk, as we cannot guarantee the security of your data transmitted to our website.

Where a security breach has occurred, we may try to notify you electronically so that you can take action to protect your Personal Information. By using our website or providing us with your Personal Information, you agree that we can communicate with you electronically regarding any security, privacy or administrative issues relating to our website. We may post a notice on our website to advise of the breach or we may email you a notification to the email address provided to us.

A Notice to International Users

If you are visiting our website from outside Canada, please be aware that you are transferring information (including Personal Information) to or through Canada where our servers are located. By transmitting your information (including any Personal Information), you consent to Golden’s use of your information for the purposes set out in this Privacy Policy.

Accessing and Rectifying Your Information

You have the right to access the Personal Information we keep in your file and request rectifications of any Personal Information in your file that may be obsolete, incomplete or incorrect. If you would like to access your Personal Information or make changes to your Personal Information, please submit a written request to our Privacy Officer through the contact information listed below. We will respond to your request as efficiently as possible.

Changes to this Privacy Policy and Your Acceptance of these Terms

Golden reserves the right to make changes to and to update this Privacy Policy at any time. Such changes will take effect immediately upon posting. We encourage you to check this Privacy Policy from time to time to review the most current version. For your convenience, the last revised date of the current Privacy Policy will be posted at the bottom of this page. If you do not agree with the terms of this Privacy Policy, please do not use our website. By continuing to interact with us following such changes, including by using our website, you will be deemed to have accepted and consented to such changes.

Inquiries

If you have any questions or concerns about this Privacy Policy, or would like to submit a request to access or rectify your Personal Information, please contact our Privacy Officer at GoldenAgingAnswers[AT]gmail.com.

Last Updated: May 3, 2022