Privacy Statement

Verity Life Media Ltd. (“Verity Life,” “we,” “us” or “our”) is committed to protecting the privacy and confidentiality of personal information entrusted to us. We collect, use, disclose, retain and safeguard personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation.

This Privacy Statement explains how Verity Life handles personal information collected through our websites, online services and client community (collectively, the “Services”).

1. Personal Information We Collect

The personal information we collect depends on your relationship with Verity and how you use our Services. It may include:

• Identity and contact information, such as your name, email address and location;
• Account and profile information, such as your username, profile photograph, account preferences and other information you choose to include in your Community profile;
• Community content, including posts, comments, messages, photographs, documents and other information you choose to submit or share through the Community;
• Communications, including inquiries, requests, messages, complaints and other correspondence with Verity Life;
• Technical and usage information, such as IP address, browser and device information, login history, access records, activity logs and information about how you interact with our Services; and
• Consent and preference information, including communication preferences, privacy choices and records of consent.

We seek to limit the collection of personal information to information reasonably necessary for identified purposes.

2. How We Collect Personal Information

We may collect personal information:

• directly from you when you register for or use our Services, communicate with us, complete a form or provide information through the Community;
• automatically through your use of our websites and online services, including through cookies, logs and similar technologies;
• from advisors, service providers or other organizations where permitted by law and appropriate to the services being provided; and
• from other sources where you have provided consent or where collection without consent is authorized or required by law.

3. How We Use Personal Information

Verity Life may use personal information for purposes that include:

• establishing, administering and maintaining user accounts;
• providing and operating our Services and Community;
• authenticating users and managing access;
• providing customer and technical support;
• facilitating Community features and communications;
• administering our business and client relationships;
• communicating service, security and account information;
• maintaining records and audit trails;
• protecting the security and integrity of our systems;
• detecting, investigating and preventing fraud, misuse and unauthorized activity;
• moderating Community content and enforcing our Terms of Use and Community Standards;
• meeting legal, regulatory, contractual and insurance-industry obligations;
• responding to complaints, investigations, audits, litigation or regulatory inquiries; and
• improving the functionality, security and performance of our Services.

Where we intend to use personal information for a new purpose that is not consistent with the purposes for which it was originally collected, we will obtain additional consent where required by law.

4. Community Information and Visibility

The Verity Forward Community allows members to interact and share information with other authorized members.

Information you choose to include in your profile or post within shared areas of the Community may be visible to other Community members. Depending on the features you use, this may include your name, profile photograph, posts, comments and other information you choose to share.

You should not post or upload personal information about another individual, including a client, insured person, beneficiary or family member, unless you are authorized and legally permitted to do so.

The Community should not be used to transmit highly sensitive information, such as Social Insurance Numbers, banking credentials, detailed medical information, complete insurance applications or other confidential client records, unless Verity Life has expressly authorized the Community for that purpose.

5. Monitoring and Security

Verity Life may monitor and review activity within the Community where reasonably necessary to administer the Services, maintain security, investigate suspected misuse, enforce Community rules, meet compliance or supervisory responsibilities, or satisfy legal and regulatory obligations.

This may include access to posts, comments, uploaded content, account activity, security logs and other records associated with use of the Services.

Monitoring will be conducted only for legitimate purposes and in accordance with applicable privacy requirements.

6. Consent

Verity Life obtains consent for the collection, use and disclosure of personal information where consent is required by law. The appropriate form of consent will depend on the nature and sensitivity of the information and the reasonable expectations of the individual.

Where permitted by law, you may withdraw your consent to certain uses or disclosures of your personal information by contacting Verity Life's Privacy Officer.

Withdrawal of consent does not affect processing that occurred before the withdrawal and may be subject to legal, regulatory or contractual restrictions. In some circumstances, withdrawing consent may affect our ability to provide a particular service or feature.

7. Disclosure of Personal Information

Verity Life does not sell personal information.

We may disclose personal information where reasonably necessary to:

• service providers that perform services on our behalf, such as hosting, technology, security, communications, authentication, backup and professional services;
• insurers, advisors or other parties involved in providing or administering services, where authorized and appropriate;
• legal, accounting, compliance and other professional advisors;
• regulators, government authorities, law-enforcement agencies or courts where required or permitted by law;
• investigate or prevent fraud, security incidents or unlawful activity;
• protect the rights, property or safety of Verity Life, our clients, Community members or others; or
• complete a transaction, subject to applicable legal requirements.

Service providers receiving personal information on Verity Life's behalf are expected to use it only for authorized purposes and to maintain appropriate privacy and security safeguards.

8. Service Providers and Processing Outside Your Province

Verity Life may use service providers located in Canada or the US, store or otherwise handle personal information.

As a result, personal information may be processed outside your province of residence and may be subject to the laws of the jurisdiction in which it is processed, including lawful access by courts, law-enforcement agencies, regulators or governmental authorities.

Verity Life uses contractual, administrative and technological measures designed to protect personal information processed by service providers.

Additional requirements apply to personal information subject to Quebec privacy legislation, as described in our Quebec Privacy Notice.

9. Retention and Destruction

Verity Life retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and to satisfy applicable legal, regulatory, contractual, insurance-industry and legitimate business requirements.

Retention periods may vary depending on the nature of the information and the purpose for which it is held.

When personal information is no longer required, Verity Life will securely destroy, delete or anonymize it, as appropriate and subject to applicable law.

Certain information may remain in secure backups or archives for a limited period or may be retained where required for regulatory compliance, litigation, investigations, complaints, fraud prevention or other lawful purposes.

10. Safeguarding Personal Information

Verity Life maintains administrative, technical and physical safeguards appropriate to the sensitivity, amount, format and location of the personal information under our control.

These safeguards may include:

• access controls and authentication;
• encryption and secure transmission methods;
• system logging and monitoring;
• role-based access restrictions;
• employee confidentiality and privacy requirements;
• security and privacy procedures;
• backup and recovery controls; and
• service-provider security requirements.

No electronic system can be guaranteed to be completely secure. Verity Life regularly assesses its safeguards and adjusts them as appropriate based on identified risks and changes in technology.

11. Privacy and Security Incidents

Verity Life maintains procedures for identifying, investigating, documenting and responding to suspected or confirmed privacy and security incidents.

Where an incident involving personal information meets applicable legal reporting or notification thresholds, Verity Life will notify affected individuals, privacy regulators or other authorities as required by law.

12. Cookies and Similar Technologies

Our Services may use cookies and similar technologies to maintain sessions, authenticate users, remember preferences, protect account security, understand how our Services are used and improve functionality.

Where consent is required for non-essential cookies or similar technologies, we will provide appropriate choices regarding their use.

Additional information about the technologies we use and available choices may be provided in our Cookie Notice.

13. Access and Correction

Subject to applicable legal restrictions, you may request access to personal information Verity Life holds about you and request correction of information that is inaccurate or incomplete.

Verity Life may require sufficient information to verify your identity before responding to a privacy request.

Certain information may not be disclosed where access is prohibited or restricted by law, including where disclosure could reveal personal information about another individual, privileged information or information that is otherwise legally protected.

Additional rights are available to individuals whose personal information is subject to Quebec privacy legislation. Please refer to our Quebec Privacy Notice.

14. Children's Privacy

The Services are not intended for children, and Verity Life does not knowingly collect personal information directly from children through the Community except where specifically required and lawfully authorized in connection with an insurance or other permitted business purpose.

Users must not post personal information about minors within the Community unless they are authorized to do so and the disclosure is permitted by applicable law.

15. Changes to this Privacy Statement

Verity Life may update this Privacy Statement periodically to reflect changes to our practices, Services, technology, legal requirements or regulatory obligations.

The current version will be posted on our website with the date of the most recent update. Where required by law, we will provide additional notice or obtain consent before making a material change to how personal information is collected, used or disclosed.

16. Questions, Requests and Complaints

Questions about this Privacy Statement or Verity Life's handling of personal information, as well as requests to access or correct personal information or submit a privacy complaint, may be directed to:

Verity Life will review privacy concerns and requests in accordance with applicable privacy legislation.

Individuals may also have the right to contact the privacy regulator responsible for their jurisdiction if they are not satisfied with Verity Life's response.

Quebec Residents

Individuals whose personal information is subject to Quebec privacy legislation have additional rights and protections. Please refer to Verity Life's Quebec Privacy Notice for information regarding access, correction, portability, profiling, automated decision-making, cessation of dissemination, de-indexing and other rights available under Quebec law.

Subject to applicable legal restrictions, Quebec residents may exercise certain rights regarding their personal information, including the rights to access and correction, withdrawal of consent in appropriate circumstances, data portability, cessation of dissemination or de-indexing, and transparency regarding profiling and automated decision-making.

Access to Personal Information

You may submit a written request asking Verity Life Media Ltd. (“Verity Life”) to confirm whether it holds personal information about you and to provide access to that information.

Verity Life may request information reasonably necessary to verify your identity and, where applicable, your authority to act on behalf of another individual before processing the request. Identity-verification documents will be handled securely and will not be retained longer than necessary to complete the verification and request-management process.

Access may be restricted where disclosure is prohibited or limited by law, including where disclosure would reveal personal information about another individual, confidential commercial information, legally privileged information, or information connected with an investigation or legal proceeding.

Correction and Deletion

You may request that Verity correct personal information that is inaccurate, incomplete or unclear.

You may also request the deletion of personal information that was collected, used, communicated or retained contrary to applicable law. Any deletion request remains subject to Verity Life’s legal, regulatory, contractual and record-retention obligations.

Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent, subject to applicable legal or contractual restrictions and reasonable notice.

Withdrawing consent may affect Verity Life’s ability to provide certain services, maintain your Community account or complete activities that require the relevant personal information.

Cessation of Dissemination and De-indexing

In circumstances permitted by Quebec law, you may request that Verity Life cease disseminating personal information about you or de-index a hyperlink associated with your name that provides access to that information.

This right is not automatic. Verity Life will assess each request in accordance with the applicable statutory criteria, which may include the public interest, freedom of expression, the sensitivity and accuracy of the information, the passage of time and the harm caused by continued dissemination.

Data Portability

You may request that computerized personal information collected directly from you be provided in a structured, commonly used technological format.

Where permitted by law and technically feasible, you may also request that Verity Life transmit the information directly to another person or organization.

This right generally does not apply to information created, derived or inferred by Verity Life, including internal assessments, compliance conclusions, risk analyses, administrative notes or other information generated through Verity Life’s own analysis.

Profiling and Related Technologies

Verity Life may use limited account and activity information to administer the Community, maintain security, understand feature usage and provide relevant content.

Where technology is used to identify, locate or profile an individual, Verity Life will provide the information required by law, including information about the use of the technology and, where applicable, how the relevant functions may be activated or disabled.

Automated Decision-Making

Where Verity Life uses personal information to make a decision based exclusively on automated processing, Verity Life will provide the information required by applicable law.

This may include information about the personal information used, the principal factors and parameters considered, and the individual’s right to submit observations or request further information regarding the decision.

Processing Outside Quebec

Personal information may be communicated to, stored by or otherwise accessible to service providers located outside Quebec, including in other Canadian provinces or other countries.

Before communicating personal information outside Quebec, Verity Life assesses relevant privacy risks and implements contractual, administrative and technological safeguards appropriate to the sensitivity of the information and the purposes for which it is processed.

Information processed outside Quebec may be subject to the laws of the jurisdiction in which it is processed and may be accessible to courts, law-enforcement agencies, regulators or other governmental authorities in that jurisdiction.

Privacy Complaints and Requests

Privacy concerns, complaints and requests should first be submitted to Verity Life’s Privacy Officer.

Your submission should include sufficient information to allow Verity to understand and assess the matter, including:

• the nature of the concern or request;
• the personal information involved;
• relevant dates and circumstances; and
• the resolution or action being requested.

Verity Life will acknowledge the complaint or request, review it fairly, document its findings and communicate the outcome. Additional information may be requested where reasonably necessary to verify identity, assess the matter or complete the investigation.

Person Responsible for the Protection of Personal Information

Questions, complaints and requests concerning personal information may be submitted to the Privacy Officer in writing.

Verity Play details

This section lists the payment details, service providers and cookies Verity Play uses.

Payments

When you subscribe, your payment is handled by our payment processor, Stripe, on its own secure checkout pages. Stripe collects your name, email address, card details, billing address and any tax ID you choose to provide, and uses them to process payments, calculate tax and prevent fraud, under Stripe’s privacy policy. We never see or store your full card number. From Stripe we keep your customer and subscription references, your plan, and your subscription and payment status with its dates (such as renewal, trial end, cancellation or a failed payment), so we can give you access and manage your subscription.

Service providers

• Supabase: database and authentication. Stores your account record, listening progress and session tokens. Hosted in Canada (ca-central-1).
• Stripe: payment processing. Stores your payment method, invoices and tax information. Stripe’s privacy policy applies to that data.
• Cloudflare: media storage (R2), stream delivery, content delivery and bot protection (Turnstile). Audio and video files are stored in a private bucket and served through our own access-controlled stream service; Cloudflare receives your IP address and request headers for delivery and security checks.
• GoHighLevel (GHL): Verity Life Solutions’s CRM. Receives your name, email and a sign-up notification when your email is confirmed.
• Vercel: application hosting. Receives request metadata (IP, user agent, route) and stores it briefly for delivery and security.
• Google Tag Manager: loads on every page to manage the Google Analytics tag below. It sets no cookies; Google receives your IP address and browser type when it loads.
• Google Analytics (loaded through Google Tag Manager): only if you choose Accept on the cookie banner. Receives the pages you visit, your browser and device type, approximate location and a random identifier stored in a cookie. Google signals and advertising features are turned off.
• Resend: sends account and billing emails. Receives your name and email address.
• Upstash: limits repeated sign-in, sign-up and similar requests to protect accounts, and holds a one-time sign-in code when you arrive from Verity Forward. Receives your IP address or account ID and keeps it for a few minutes, at most 15.
• Sentry: error monitoring. When something goes wrong on the site it receives technical details such as the page, browser and device type, with sign-in links and tokens removed first. Stores them in the European Union (Germany).

Processing outside Canada

Your account data, subscription state and listening history are stored in Canada. Stripe, Cloudflare, Vercel, GoHighLevel, Resend, Upstash and Google are based in the United States and may process data there. Sentry stores error reports in the European Union (Germany).

Cookies on Verity Play

• Essential. Keep you signed in and, when you arrive from Verity Forward, sign you in and remember the way back. These cannot be turned off while you use Verity Play.
• Payment processing. Stripe sets cookies on its own checkout pages to prevent fraud.
• Analytics (optional). Google Analytics cookies (_ga, _ga_*) that count visits and show which pages are used. They are set only after you choose Accept on the cookie banner. Decline, or change your mind later, and they are not set.

We do not use third-party advertising or cross-site tracking cookies.

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