Privacy policy

Effective date: June 19, 2019

Exchange Income Corporation (“EIC”, “us”, “we”, or “our”) operates the lifeinflight.ca website in connection with its Life in Flight Program (collectively referred to as the “Service”).

This policy informs you of our policies and practices regarding the collection, use, and disclosure of Personal Data, Usage Data and cookies (each as defined below) when you use our Service, and the choices you have associated with that information.

We use your information to provide and improve the Service. By providing information to us and/or using the Service, you agree to the collection, use and disclosure of information in accordance with this policy.

You may deny or withdraw consent to our collection, use and disclosure of your Personal Data at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, it may prevent us from providing the Service to you. You may contact our Privacy Officer to learn more about denying or withdrawing your consent.

Note to Residents of the European Union: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for European users, this privacy policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR. We process Personal Data when we have a lawful basis to do so in accordance with the GDPR. Generally, this means that we process Personal Data only where we have consent, where necessary to provide you with information, products, or services, or where necessary to comply with our legal obligations. We may also process Personal Data where otherwise allowed by the GDPR for the purposes outlined in this policy (for example, to communicate with you and to respond to your requests). Please see below for further information.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.-

Types of Data Collected

Personal Data

While using our Service (especially if you choose to apply to be a member of the Life in Flight Program), we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Such Personal Data may include:

  • Contact information, like your name, address, e-mail address and phone number;
  • Identifying information, like your date of birth and gender; and
  • Identification documents, like your driver’s license or passport.

We may collect Personal Data for other purposes where we have a legal duty or right to do so, or where we have a good faith belief that it is necessary to protect its property or rights. We do not collect Personal Data for any other purposes, unless we have the consent of the individual to whom the Personal Data relates.

Usage Data

We may also collect information about how the Service is accessed and used, including data collected automatically which is generated by the use of the Service or from the Service infrastructure itself (“Usage Data”). This Usage Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Cookie Data

We use cookies and similar tracking technologies to track the activity on our Service. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

We use the Personal Data, Usage Data and cookies collected from you for various purposes:

  • To provide and maintain the Service
  • To administer, plan and manage the relationship with individuals and to communicate with individuals
  • To assess your application to be a member of the Life in Flight Program (where applicable)
  • To notify you about changes to the Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care, support and requested information
  • To provide analysis so that we can improve the Service
  • To promote the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

EIC and its partners may use your information in marketing or other communication efforts to inform you of current and/or new operations or other developments that EIC or its partners believe will be of interest to you. Any use of your information in this manner will be in accordance with Canada’s Anti-Spam Legislation. You may opt-out of receiving such communications by contacting the EIC Privacy Officer at the address listed below.

Transfer of Data

If you are located outside Canada and choose to provide information to us, please note that all data, including Personal Data, is processed and stored in Canada, and is correspondingly subject to applicable Canadian privacy laws.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data and other information.

Disclosure of Data

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”). These Service Providers may provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. We may disclose your Personal Data to these Service Providers only to perform these tasks, and no Service Provider is or will be authorized to use or disclose your Personal Data for any other purpose.

Legal Requirements

EIC may disclose your Personal Data in the good faith belief that such action is necessary:

  • To comply with a legal obligation
  • To protect and defend the rights or property of EIC
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security and Retention of Data

The security of your Personal Data is important to us. We have in place reasonable policies, procedures and safeguards (including physical, technological, organizational and contractual measures) designed to protect the security of your Personal Data under our control. Additionally, we have taken steps to satisfy ourselves that our Service Providers that may receive your Personal Data in connection with the Service have in place reasonable policies, procedures and safeguards to protect the security of your Personal Data.

The security of your data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We are prepared to take appropriate and timely steps in the event of any incidents involving Personal Data under our control, in accordance with applicable privacy laws. Depending on the nature of the incident, appropriate steps may be limited to making appropriate internal adjustments to our privacy practices, or may include notifying you directly about the details of the incident.

We retain Personal Data only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

Accuracy of Data

We makes reasonable efforts to ensure your Personal Data is accurate and complete. This may involve requesting further information or updates from you in respect of the Personal Data under our control. Relatedly, we rely on you to notify us if there is a change to your Personal Data that may affect your relationship with us. In the event of such change, please contact our Privacy Officer using the information at the end of this Privacy Policy.

We will correct or amend your Personal Data in our files where it can be shown that the information is incorrect or incomplete.

Access to Your Personal Data

We will provide you with access to the Personal Data we hold about you in accordance with applicable laws. We may require that any request for access to Personal Data be made in writing. Generally, there is no cost for such access. However, we reserve the right to charge you a reasonable fee to cover such costs on a case-by-case basis, in accordance with applicable laws. You will be notified in advance if a fee apply.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

GDPR Information

The GDPR sets out obligations and rights with respect to the Personal Data of residents of the European Union. EIC is committed to ensuring that it complies with the requirements of the GDPR. As such, this section outlines additional information relevant to residents of the European Union only. Please see the remainder of our policy above for more information on our privacy practices.

Your GDPR Rights Relating to Your Personal Data

Subject to some exceptions, the GDPR provides you with the following rights:

  • Right of access: You have the right to information about whether and why we process your Personal Data and related information (for example, what Personal Data we are processing).
  • Right of rectification: You have the right to correct any inaccurate or incomplete Personal Data that we hold about you
  • Right to erasure: You have the right to ask us to delete Personal Data that we hold about you.
  • Right to restrict or object to processing: You have the right to ask us to limit or stop our processing of your Personal Data in certain cases (for example, if the Personal Data we are processing about you is inaccurate or is for direct marketing purposes).
  • Right to data portability: You have the right to ask us for a copy of Personal Data we hold about you and to transfer such data to another entity.
  • Right to complain: We encourage you to contact us at the contact information below if you have any questions or concerns with our personal data practices. However, you also have the right to complain to regulatory authorities in your jurisdiction. Please contact us at the contact information below if you need information about the appropriate authority.

You may exercise these rights or find out more about these rights by contacting us at the contact information listed below.

Retention and Storage of Personal Data under GDPR

EIC is based in Canada and processes Personal Data in Canada. The European Commission recognizes Canada as providing an adequate level of protection for personal data. When your information is processed outside of the European Union, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. EIC has taken appropriate technical, organizational, and legal steps to secure this information.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

For further information about EIC’s privacy practices or to make a request for access to Personal Data, please contact EIC’s Privacy Officer at the following address:

Exchange Income Corporation
Attn: Privacy Officer
101-990 Lorimer Blvd, Winnipeg, MB R3P 0Z9
privacyofficer@eig.ca

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