Privacy policy
Last update: September 24, 2024
Definitions
In this Privacy Policy of Innovations Laylah Inc., the company operating the Laylah Website and Platform (referred to as "Laylah"):
The Platform is an application for financial advisers, created and marketed by Laylah.
Personal Information refers to information that makes it possible to identify a person, directly or indirectly. This does not include Business Contact Information, except where privacy laws consider them to be Personal Information. Anonymised information within the meaning of the law is not Personal Information.
Business contact information is information that relates to the performance of a function within an organization, such as an individual's name, title and function, as well as the address, e-mail address and telephone number of the individual's place of work. By "the performance of a function", we mean that this information must have been collected, used or disclosed for the purpose of communicating with the individual in the course of his or her employment, business or profession.
Customer means a customer of Laylah who is a business or other organization and who is not a Consumer. The End User is an employee of Laylah's Customer.
Consumer means the individual whose data is downloaded or entered on the Platform by the End User.
Customer Personal Information means the Personal Information entrusted to Laylah by the Customer and may include the Personal Information of the Customer's End Users and Consumers downloaded or entered on the Platform. This information may include, but is not limited to: name, postal address, email address, date of birth, gender, telephone number, insurance policy information, completed transactions.
End User means an employee of Laylah's Customer who uses the Platform in the course of his or her work.
Scope and application
This Policy applies to Customers of Laylah and to End Users. It also applies to Customer Personal Information that has been entrusted to Laylah for the purpose of providing contracted services, including Customer Personal Information in the possession of Laylah's service providers. If you are a Consumer as defined in this Policy, please carefully read the following section: "Our Commitments to Consumers". We also recommend that you read the Privacy Policy of the Customer with whom you do business directly.
Laylah's employees, subcontractors and agents must comply with the Privacy Policy if they have access to Personal Information or Customer Personal Information in the course of their duties.
Privacy Program
In order to protect Personal Information, including Customer Personal Information, we have implemented policies, practices and procedures relating to the management of Personal Information in our possession or custody.
These internal policies and procedures govern the collection, use, disclosure, retention and destruction of Personal Information, as well as the handling of complaints, information security and data governance. These policies and practices also set out the framework for implementing privacy impact assessments, and for preventing and responding to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer.
The collection of Customer Personal Information via our Platform complies with the requirements of this program.
Privacy Officer
Laylah's senior management has delegated the management of the privacy program to the Privacy Officer. The duties of the Privacy Officer are to internally manage and monitor Laylah's privacy program.
It is the Privacy Officer who approves and implements the privacy policies and procedures, ensures their proper functioning and reports to Laylah's senior management on the effectiveness of the program.
The Privacy Officer is also responsible for providing the necessary support in the event of a question, complaint or request relating to the protection of Personal Information. For more information, please consult the "Contact us" section.
Consent
We do not have a direct business relationship with Consumers. For this reason, we require our Customers to ensure that they have obtained all mandatory consents from Consumers. This requirement also applies to the Personal Information of minors, which may be entered on the Platform. In particular, Consumers should have consented to their Personal Information, and that of their dependent children, being managed by Laylah in accordance with this Privacy Policy.
We also require our Customers to provide legally required notices to End Users and Consumers and to ensure that the use, collection or communication of Personal Information between Laylah and the Customer is authorized.
Collection and use
Laylah obtains ownership of the Customer's Personal Information when the Customer imports End User and Consumer data into the Platform. At the same time, the import of data may also result in the collection of Personal Information for Laylah for specific purposes, listed below.
When we develop and improve our product, we make sure to limit the fields of collection of Personal Information to what is strictly necessary for the performance of our contracts, to enable the Customer to achieve its objectives.
In the same way, we require our Customers to limit the sharing of Personal Information to that which is necessary to achieve their objectives.
The following are the purposes for which Laylah collects and uses Personal Information and Customer Personal Information to provide its Services: To establish and maintain a commercial relationship with our Customers; To consolidate the Customer's or End-User's Personal Information scattered over several accounts in the Platform via data sources and integrations selected by the Customer or End-User; To develop, improve, promote or supply products and services to our Customers, including for diagnosing technical problems or improving functionality; To investigate and resolve incidents; To support our Customers in requests to exercise the rights of End Users or Consumers or to resolve disputes; For any other purpose permitted by law, in particular to respond to requests from police authorities or governments.
Laylah collects and uses Personal Information for the following purposes: To maintain and improve the operation and security of the Website and the Platform; To meet contractual, legal and regulatory requirements; For research and statistical purposes; For the management and administration of the Customer's user account; To contact you if you use our online forms; To prevent and detect suspicious or fraudulent activities or activities in breach of our terms of use; To investigate and resolve incidents; For any other purpose permitted by law, in particular to respond to requests from police authorities or governments.
Should the End-User or Customer refuse to provide the information required to open and administer his or her user or customer account or withdraw his or her consent to the use or communication of his or her Personal Information or the Customer's Personal Information, Laylah may be unable to provide the End-User or Customer with the products and services subscribed to and may be obliged to terminate its business relationship with the Customer or End-User.
Communication and transfer of personal information
Laylah only discloses or transfers Customer Personal Information as required or permitted by the contract with the Customer or as otherwise required or permitted by applicable law.
Laylah may from time to time need to share Personal Information with its subcontractors or agents to help us make available all the features of our Platform and websites (maintenance, analysis, legal requirements, fraud detection, marketing and development). They will only have access to Personal Information that is necessary to perform these tasks on our behalf and they are required not to disclose or use it for any other purpose.
Please note that these subcontractors or agents may be located in Canada or in other jurisdictions or countries. Please be aware that we have contractual agreements with these subcontractors to ensure the security of the data we entrust to them and that we conduct privacy impact assessments before disclosing any Personal Information outside the province of Quebec. Although the Personal Information we transmit is protected by appropriate security measures, Personal Information may be made available to foreign government agencies under applicable laws.
Conservation
Laylah has established retention periods for Personal Information in its custody. Laylah will retain Personal Information only as long as it remains necessary or relevant for the identified purposes, unless otherwise required by contract with the Customer or by legal or regulatory requirements. Once these time limits have expired, Laylah will return or destroy the Personal Information in accordance with the contract with the Customer or its internal policies for the management of Personal Information.
Safety measures
Laylah makes the security of the Personal Information it collects, uses and maintains a priority. Accordingly, Laylah ensures that security safeguards appropriate to the sensitivity of the data are in place to protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction.
To the extent possible and applicable within the scope of our services, Laylah implements, maintains and monitors technical and administrative measures to help protect the security, integrity, availability and confidentiality of the Personal Information we collect or have in our custody.
Accuracy
Laylah relies on the Customer and the End-User to ensure the ongoing accuracy of the Personal Information that Laylah collects, uses and retains for the purposes set out above.
Incident management
Laylah's Privacy Program includes incident detection and response practices and procedures designed to facilitate the prompt reporting to the Customer of incidents involving the Customer's Personal Information.
Since Customer Personal Information belongs to the Customer, the Customer is generally responsible for the management and follow-up of security or privacy incidents with Consumers. In accordance with its contracts with Customer, Laylah will provide reasonable assistance to support Customer in investigating the incident and complying with its obligations, for example with respect to notifications to affected individuals (including End Users and Consumers) and reporting the incident to the appropriate privacy commissioners or other relevant parties.
Access to information and similar rights
Since we do not have a direct business relationship with the Consumer, Laylah will generally refer requests for access to information, correction of Personal Information or other such requests from End Users or Consumers to the Customer, unless Laylah has contracted to do so with the Customer as part of its provision of services.
Our commitments to Consumers
This section describes Laylah's Personal Information management practices when the Consumer ("you", "your") does business with one of our Customers who uses the Platform and uploads your data to it. This section also applies to your visit to our website.
Please note that your visit to and use of our website and Platform is also governed by our Terms of use.
Transparency
Transparency about our Personal Information management practices is an integral part of our Privacy Program.
This Privacy Policy attempts to inform you as fully as possible about our practices for managing the Personal Information entrusted to us by our Customers when your data is imported into the Laylah Platform. All Personal Information contained in the Platform, whether yours or that of your dependent children, may be collected, used and retained by Laylah to fulfill its contractual obligations and the purposes listed above.
Our Privacy Officer has been specifically appointed to help you with any privacy-related questions you may have.
Accountability
We assume the responsibilities incumbent on us by virtue of the applicable laws. Our accountability is limited to the services we provide to our Customers. Brokerage firms, brokers and other companies that retain our services remain accountable by law for the management of your Personal Information. We strongly recommend that you also read their privacy policy.
Limitation
When developing and updating our products, we always keep in mind our objective of reducing to a strict minimum the collection and use of your Personal Information for the operation and management of our Platform.
Similarly, if it is possible for us to use de-identified or anonymised information to achieve the purposes listed above, we will favour these methods.
We retain your Personal Information only for as long as a profile in your name is open and active on the Platform. Upon deletion of your profile by our Customer, Laylah will destroy your Personal Information, subject to retention periods imposed by its contracts, internal policies and by law.
Security
We are aware of our role as guardian of your Personal Information and that of your dependent children and for this reason, we endeavour to implement the best reasonable security measures to maintain the security, integrity, availability and confidentiality of our Platform.
Access to Personal Information
Our Customers can access your profile and view your Personal Information at any time. They may also modify or correct this Personal Information upon request. In the event that it is impossible for our Customers to modify certain Personal Information themselves or to consult it via their account, please contact our Privacy Officer.
Cookies and other similar technologies
Our Website and Platform allow us to collect information about visitors and users through certain tracking technologies, such as cookies and pixels. This information may include, but is not limited to: IP address, web browser, operating system, click streams.
Connection cookies
Cookies are small data files that are commonly stored on your device when you use websites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. Laylah collects Personal Information provided by cookies.
Pixels
Web beacons are tiny images that we can place in our web pages or emails. They can be used, for example, to anonymously obtain the number of times a particular page has been visited by an Internet user. As their name suggests, web beacons are invisible and any part of our sites, including the advertising messages displayed on them, may contain web beacons. Unlike cookies, invisible pixels are not placed on your computer.
Connection indicators and pixels
These technologies do not contain any personally identifiable information.
Laylah uses different types of cookies (collectively referred to as cookies here):
- Performance and functionality cookies: These cookies help to personalise and improve the user experience. For example, they may remember your preferences so you don't have to re-enter information more than once, or they may remember your login details so you don't have to re-enter them each time you use the site. They enable us to understand your behaviour in order to improve our services and our sites.
- Cookies for security purposes: These cookies help protect your accounts from unauthorised users. They help maintain session integrity and provide enhanced security, blocking unauthorized attempts to access your account.
Laylah mainly uses 2 types of cookies:
- Session cookie: This cookie is stored for the duration of your visit to our sites, after which it is deleted from your device. It identifies you and is then deleted when you leave our sites.
- Persistent cookies: This cookie is stored on your device until it expires and will be retrieved the next time you visit our sites. Our persistent cookies last for 30 days.
Please note that the use of cookies only identifies you as a user and does not recognise you in any other way.
Deactivating cookies
You can prevent the personalisation functions of our sites by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device.
However, if you decide to refuse cookies, certain pages or sections of our sites may not be displayed correctly or certain functions may not be available.
Links to websites
It is important to understand that this Privacy Policy does not apply to other third-party websites that may be accessed through links on our sites. We are in no way responsible for these third-party sites, their content or access to them. Consequently, any Personal Information that you transmit via these sites is subject to their privacy policies. It is your responsibility to read these policies to ensure the protection of your Personal Information.
Contact us
Our Privacy Officer is available to answer any questions, requests or complaints regarding Laylah's privacy practices. Here is his contact information:
Privacy Officer Innovations Laylah inc. 401-1400 Maguire Ave. Quebec City, QC, G1T 1Z3 privacy@laylah.ca
If you are a Consumer, Laylah may direct your request to its Customer, if that is more appropriate.
In the event of a complaint regarding this Privacy Policy, our Privacy Officer will investigate the matter and inform the complainant of the procedure to be followed. If the complaint is justified, the specific situation will be corrected and the complainant will be informed.
Laylah would like you to know that we are committed to responding promptly and accurately to all your questions and concerns about the confidentiality and security of Personal Information and about our privacy policies and practices.
Changes to this privacy policy
We revise the Policy from time to time to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice either on our Platform, our Site or by e-mail. However, in all other circumstances, the posting of a new version of the Policy on our Site or your continued use of the Site or Platform will suffice as notice and consent to changes in the Policy.