PRIVACY POLICY - CANADA

Last updated March 8, 2024

PLEASE READ PRIVACY POLICY CAREFULLY, AS IT CONTAINS IMPORTANT INFORMATION ABOUT HOW WE COLLECT, STORE, USE, PROCESS, RECORD, RETAIN, MANAGE, DISCLOSE, TRANSFER, SHARE, AND PROTECT YOUR PERSONAL INFORMATION IN CONNECTION WITH THIS SITE. IN ORDER FOR US TO PROCESS YOUR APPLICATION OR ANY TRANSACTIONS REQUESTED BY YOU IN CONNECTION WITH THIS SITE, WE OR THIRD PARTIES MAY NEED TO CONDUCT A CREDIT CHECK ON YOU TO VERIFY YOUR CREDIT SCORE.

1. This Site. Thank you for visiting bankbeach.com (this “Site”). This Site is owned and operated by Beach Life Network Inc. (“Company”, “we”, “us”, “our”, or words of similar meaning). This Site provides you with information regarding products and services offered by third parties that we work with, including customers, service providers, and trading partners (each, a “Third-Party Affiliate”). By clicking on the links provided, this Site provides you with the ability to connect with Third-Party Affiliates in order to receive more information about their products and services as well as the ability to purchase them.
2. This Privacy Policy. This privacy policy (this “Privacy Policy”) is provided by Company and applies to personal information we collect in connection with this Site. This Privacy Policy sets out and explains the types of personal information that are collected from you in connection with this Site, how we collect, store, use, process, record, retain, manage, disclose, share, transfer, and otherwise handle (collectively, “Handle”, “Handled”, “Handling” or other variations thereof) your personal information, how we protect your personal information while in our possession, and to or with whom we may disclose or share your personal information. We appreciate the trust you place in us when you choose to visit, access, and use this Site and link or connect to the websites of Third-Party Affiliates, and we take our responsibilities regarding your personal information seriously. This Privacy Policy describes the measures we take to protect the security of your personal information, and it tells you how you can contact us to ask us to:
   1. access, change, or not use the personal information you have provided to us;
   2. withdraw any consent you previously provided to us;
   3. refrain from communicating with you about our products or services; and
   4. answer any questions you may have about our privacy practices.
   Please read this Privacy Policy carefully so that you understand how we Handle and protect your personal information. If you do not agree to us Handling your personal information or if you do not agree to the terms of this Privacy Policy, you may choose to not provide us with any of your personal information. You may revoke your consent to the Handling of your personal information by us at any time by notifying us of your revoked consent via email to [email protected] or via our Contact Us page.
3. Changes to this Privacy Policy. Company reserves the right to change, modify, restate, or replace this Privacy Policy at any time and from time to time, including for the purposes of ensuring that our policies are in line with Canadian federal privacy law and best industry practices. You should review this Privacy Policy from time to time to ensure that you are aware of and accept any changes made. To obtain a current copy of this Privacy Policy, you may contact our Privacy Officer via email at [email protected].
4. Personal Information and Privacy Law. In general, “personal information” is information about an identifiable individual, subject to more particular definitions or interpretations under Canadian privacy laws, including the federal Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA) and similar legislation in the provinces of Canada, other than the Province of Québec (“Privacy Law”). Privacy Law gives consumers the right to limit the sharing of personal information. Privacy Law requires us to tell you how we Handle and protect your personal information. This Privacy Policy does not apply to any information that is not personal information, as defined under Privacy Law.
5. Territorial Limitation. This Site is only intended to market and sell to residents of Canada, excluding the Province of Québec (the “Territory”). If you are a resident in a jurisdiction outside the Territory, you are not permitted to access or use this Site (in whole or in part). By accessing or using this Site or any portion of it, you represent and warrant that you are a resident of the Territory. It is our policy to comply with Privacy Law within each jurisdiction in which we operate in the Territory. Privacy Law and an individual’s right to privacy may be different from one jurisdiction to another in the Territory. This Privacy Policy covers only those activities that are subject to the provisions of Privacy Law in the Territory. If you are at all unsure as to whether or how this Privacy Policy applies to you, please contact our Privacy Officer for more information via email to [email protected] or via our Contact Us page.
6. Minors. This Site is not directed to people under the age of 18, and we do not knowingly collect personal information from minors, including by way of this Site. If we become aware that we have inadvertently received personal information from a visitor under the age of 18 in connection with this Site, we will delete all such personal information from our records. If you are aware that people under the age of 18 accessed the Site and share personal information with us, please contact our Privacy Officer for more information via email to [email protected] or via our Contact Us page, so we can delete all such personal information from our records.
7. Your Consent. We will only Handle your personal information with your consent or as permitted or required by Privacy Law. If you provide your consent for us to Handle personal information about another person, we will require you to have obtained the consent of that individual to enable us to Handle their personal information as described in this Privacy Policy. Consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. By accessing and using this Site or by clicking on any of the links on this Site or by accessing or using any of the websites of Third-Party Affiliates or by providing us or Third-Party Affiliates with personal information for any reason, including to complete a questionnaire or a transaction, you consent to all Handling of your personal information by us and Third-Party Affiliates as described in this Privacy Policy. Your consent to the Handling of your personal information may be implied by the fact that you have provided personal information to access or use this Site or the websites of Third-Party Affiliates or related products and services or where the Handling of personal information is necessary for, or directly relates to, the provision of products and services by us or Third-Party Affiliates. If you provide us with your personal information for a secondary reason (e.g., newsletter subscription or marketing messages), we will ask you directly for your expressed consent and provide you with an opportunity to withdraw your consent or unsubscribe. If you provide personal information about another person to us, we require you to have obtained the consent of that individual to enable us to Handle their personal information as described in this Privacy Policy. If you choose to provide personal information to us, we assume that you consent to the Handling of your personal information as outlined in this Privacy Policy.
8. Revoking Consent. If you do not wish to consent to our Handling of your personal information, please do not provide your consent by using this Site or any portion of it, including by clicking on any buttons or links or completing any questionnaires on this Site, and do not provide your personal information to us. If you change your mind about your consent and wish to revoke your consent, subject to Privacy Law, you may revoke your consent at any time by notifying us of your revoked consent via email to [email protected] or via our Contact Us page. We honour and respect all such notices in accordance with Privacy Law. If you revoke your consent to certain uses of your personal information, we and Third-Party Affiliates may no longer be able to provide you with products and services or access to or use of this Site.
9. Collection of Personal Information. We Handle and protect personal information in accordance with Privacy Law as necessary to, or to enable Third-Party Affiliates to, offer and provide consumers with products, services, and information and generally to fulfill our responsibilities with respect to our business. When you are no longer our customer, we may continue to share your personal information as described in this Privacy Policy, subject to Privacy Law. We collect personal information directly from you or through our interaction with you, including by way of this Site. We may also obtain personal information about you from other sources, including payment processors, fraud detection partners, and third-party analytics tools. Subject to Privacy Law, the types of personal information we collect may include:
   1. identifying information, such as first and last name, date of birth, address, postal code, email address, telephone numbers, other contact details, and other similar information, including as required to verify identity and prevent fraud;
   2. certain demographic information, including age, gender, health information, whether you are a smoker or non-smoker, employment information, employer and employment information, income, income sources, home ownership or rental information, home valuation, mortgage value, current interest rates, vehicle ownership or leasing information, and other similar information;
   3. credit and financial information, including assets, liabilities, credit history, credit score, credit and bank account information, debit and credit card information, payment preferences, billing and shipping address, billing information, use of proceeds from financing, and related contact information;
   4. information in connection with the financial-related products and services that you may seek from us, including for example, having us suggest credit cards, loans, and other financial products that, based on our experience and the information you provide to us, will most likely be acceptable to you;
   5. profile and account information, including contact, purchase, and preference information, information about any purchased or subscribed for products or services, product or service review information, promotional information, and other information about any profile or account you may have with us or any Third-Party Affiliates;
   6. information that you enter into, or submit to us by way of, questionnaires on this Site;
   7. preference information, such as product, service, and marketing preferences and interests as well as purchase or order information;
   8. incidental information relating to interaction with us or Third-Party Affiliates or the purchase of products or services, including returns, refunds, comments, opinions, evaluations, ratings, disputes, and other information we may collect in the course of providing products or services;
   9. information shared with us or destined to Third-Party Affiliates;
   10. location information of devices used with this Site or the websites of Third-Party Affiliates, if device settings allow for the collection of location information;
   11. device and browsing information, including IP addresses, information about your phone, tablet, computer, or device, online browsing activity, activity logs (including user activities, what groups users are a member of, posting data, document creation, and courses completed), unique device identifiers, cookie identifiers, device and browser settings and information, Internet service provider (ISP) information, information about when and how you access and use this Site or the websites of Third-Party Affiliates (such as the date and time of your visit or use), the websites you visit before coming and after leaving this Site or the websites of Third-Party Affiliates, how you navigate and what you search for using this Site or the websites of Third-Party Affiliates, the web pages and items and products and services you view using this Site or the websites of Third-Party Affiliates, and the products and services you purchase; and
   12. any other information that we or Third-Party Affiliates may collect with your consent or as permitted or required by Privacy Law.
10. Cookies.
    1. When you visit this Site, our systems track the pages you visit, the pages you download, the websites you came from and your browser type and software. It also notes your IP address. We use cookies, web beacons, pixels, clear gifs, and other similar tracking technologies (“Cookies”), which may be stored on or accessed from your device when you use or visit this Site or any website or app that posts a link to this Site, including session cookies (that store logged-in state and site activities), user input cookies (information entered into forms and that may be stored to survive refreshing your browser), settings cookies (that store user settings and capabilities), activity cookies (that store activity states, current courses, current time, and current page), and tracking cookies (including those of Google Analytics). A Cookie is a small text file that can be stored on and accessed from your device when you visit this Site. It takes up very little room on your system, enables us to collect information about how you use this Site, and helps us estimate the number of people who use this Site and which areas of this Site are most popular. The use of Cookies enables us to create a more customized experience for you. It allows this Site to recognize your device as distinct from those of other users. Login Cookies eliminate the need for you to re-enter your username and password each time you return to our website. By continuing to access and use this Site, you agree that Company can store and access Cookies.
    2. We use Cookies to, among other things, identify you and your interests, to remember your preferences, to enhance your user experience, for marketing purposes (including targeted ads), to track your use of this Site, for analytical purposes. We or Third-Party Affiliates may collect information about your online activities in connection with this Site to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based, and contextual means. These partners track your online activities over time and across websites by collecting information through automated means, including through the use of third-party Cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on these websites. This data collection takes place both on this Site and on third-party websites that participate in the ad networks. This process also helps track the effectiveness of marketing efforts.
    3. We may use Cookies to control access to certain content on this Site, to protect this Site, to prevent spam and fraud, for compliance purposes, and to process any requests that you make from us or third parties. We may use persistent Cookies to improve your experience of using this Site. This includes recording your acceptance of our Cookie policy to remove the Cookie message which first appears when you use this Site. Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track Internet usage.
    4. To administer this Site and for research purposes, we may also contract with third parties to track and analyze statistical usage and volume information from the users of this Site. These third parties may use Cookies to help us improve the user experience on this Site, manage associated content, and analyze how users navigate and utilize this Site. We may contract with third parties to send emails to users who have provided us or such third parties with their contact information. To help measure and improve the effectiveness of such email communications, or to determine whether messages have been opened and links clicked on, such third parties may place Cookies on the devices of these users.
    5. You may refuse to accept Cookies by activating or adjusting the appropriate setting of your Internet browser to reject the setting of all or some Cookies or alert you when a Cookie is placed on your device. However, if you refuse to accept Cookies or use your browser settings to block all Cookies, you may be unable to access or use this Site or the websites of Third-Party Affiliates or related functionalities (in whole or part). If you want to remove previously stored Cookies, you can manually delete these Cookies at any time. However, this will not prevent this Site or the websites of Third-Party Affiliates from placing further Cookies on your device unless you adjust your Internet browser setting so that it will refuse Cookies. Unless you have adjusted your browser setting so that it will refuse Cookies, our website and the websites of Third-Party Affiliates will issue Cookies when you direct your browser to them.
    6. If you have any questions regarding this Cookie policy, please contact our Privacy Officer via email to [email protected] or via our Contact Us page.
    7. Use of Personal Information. We and Third-Party Affiliates use your personal information for our business purposes, such as to process transactions you request, protect against fraud, or to respond to court orders or legal investigations, for our marketing purposes in order to offer products and services to you, for joint marketing with Third-Party Affiliates, to process the transaction that you are requesting, for us and Third-Party Affiliates to market to you, and otherwise to generate revenues for our business. Without limiting the generality of the foregoing, the following is a list of some of the ways we use, process, and share your personal information:
       1. to provide, manage, maintain, support, and improve this Site and the websites of Third-Party Affiliates, including the content thereof and the products and services offered to you;
       2. to establish, maintain and manage our relationship with you in order for us and third parties to provide you with the products and services that you have requested, including to facilitate or otherwise assist you in obtaining a loan, credit card, or other product or service from a Third-Party Affiliate;
       3. to comply with your requests (e.g., if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
       4. to enable you to connect with Third-Party Affiliates in order to receive more information about their products and services as well as the ability to purchase them and determine whether you are “pre-qualified” or “pre-approved” to be transferred to Third-Party Affiliates in order to enquire about purchasing their products and services;
       5. to provide required data sets to third parties for the purposes of processing your application for their products and services and Third-Party Affiliates to provide products and services to you;
       6. to conduct credit checks to verify your credit score and confirm your financial situation and your initial and ongoing eligibility for certain products and services, and to verify information you provide to ensure it is valid;
       7. to manage information provided by you on this Site, monitor Site performance, and obtain usage metrics for internal decision-making purposes for this Site, track and log user actions taken on this Site, and generate system-specific data, such as the creation of course progress records, access logs, site or group memberships, and activity events;
       8. to personalize your experiences with us and Third-Party Affiliates (including remembering your interests and preferences, customizing product and service offerings, and reviewing products and services you are interested in so that we may understand your requirements and improve our product and service offerings), facilitate your interactions with Third-Party Affiliates, track and categorize your activity and interests (including by identifying the different devices you use), and enrich your experience on this Site and the websites of Third-Party Affiliates;
       9. to understand how you use this Site and the websites of Third-Party Affiliates and how to improve them, compile and aggregate information collected by way of this Site, and develop and use knowledge management systems that contain personal information about you;
       10. to manage and administer the business of Company and Third-Party Affiliates, including to protect you against error, operate and improve lawful business activities, maintain programs, accounts, and records, conduct research, determine your satisfaction with products and services, and detect and prevent fraud or misuse of any of the foregoing;
       11. to communicate with you regarding products and services you may be interested in (including to notify you of products and services that we or Third-Party Affiliates think you may like), to send you marketing and advertising communications and customize the marketing and advertising that we show you, to respond to your requests and enquiries, to provide you with material and information regarding products and services, to inform you of offers and promotions, for the purposes of marketing, re-marketing, advertising, and cross-selling to you by us and third parties, and to sell your information to third parties;
       12. to defend or protect us, you, and third parties (including Third-Party Affiliates) from harm or in legal proceedings, protect our and our Third-Party Affiliates’ rights, protect our and our Third-Party Affiliates’ security and property, respond to court orders, lawsuits, subpoenas, and government requests, address legal and regulatory compliance, and notify you of product or service or safety issues; and
       13. to take such actions and do such things as permitted or required by applicable law, including Privacy Law, or for purposes for which you otherwise provide your consent.
       If we plan to Handle your personal information for a purpose not previously identified, either in this Privacy Policy or separately, we will advise you of that purpose prior to any such Handling, and we will provide you with an opportunity to withdraw or refuse your consent to such Handling.
    8. Consent to Credit Checks. You acknowledge and agree that, in order for us or third parties to process your application or any transactions requested by you in connection with this Site, we or third parties may need to conduct a credit check on you to verify your credit score. By providing us with your personal information, you provide your consent and agreement to any and all such credit checks.
    9. Aggregated Data. In this Privacy Policy, “aggregated data” means information or data that arises from the compilation, combination, or analysis of personal information or other information and is anonymized. We may use your personal information to create aggregated data, including for the purposes of managing, maintaining, and developing this Site and our business operations, including identifying the demographics of our clients, creating and selling benchmarks, reports, summary metrics, and predictive algorithms, and developing new or improving our existing products and services.
    10. Customer Service. You may use this Site to communicate with us and Third-Party Affiliates for customer support and services. If you do so, you may be asked for personal information. We and Third-Party Affiliates use this information to respond to and communicate with you about your questions and comments.
    11. Site Features. We offer visitors to this Site various features for their information and enjoyment, including links to third-party websites and questionnaires or decision funnels which we may change from time to time. We may ask you to submit personal information so we can provide you with these features and send you communications about our products, services, and promotions.
    12. Customer Satisfaction Surveys. When you purchase products or services from us, we may ask you to complete a customer satisfaction survey. If you choose to do so, you may provide personal information together with your comments. Providing any of this personal information is optional. We use this personal information to improve our products and services, and to enhance your customer experience with us.
    13. Commercial Electronic Messages. You may be able to use this Site to sign up on to receive commercial electronic messages (such as newsletters and promotional emails) from us, including new ideas, special offers and event information. To sign up, we may ask you for personal information. We use this personal information to send you commercial electronic messages about our products and services in accordance with Canada’s Anti-Spam Legislation (CASL). You can choose at any time not to receive marketing emails from us by clicking on the unsubscribe link within our marketing emails. There is no charge for you to unsubscribe.
    14. Sharing of Personal Information. We may share the personal information collected about you to third parties in the following cases:
        1. when you click on the buttons and links on this Site in order to link, transfer, or direct you to Third-Party Affiliates, as requested by you;
        2. when you click on the buttons and links on this Site in order to process your requests and submissions on questionnaires and conduct credit checks, and to administer or service your objective to obtain a product or service with Third-Party Affiliates;
        3. with Third-Party Affiliates and other third parties (including lenders and dealerships and third-party processors and storers and purchasers of personal information), including for the purposes of providing you with products and services of third parties, responding to your requests and enquiries, providing you with material and information regarding products and services of third parties, marketing, re-marketing, advertising, and cross-selling to you by us and third parties, and to sell your information to third parties;
        4. where you have instructed us to disclose your personal information to a third party for a designated purpose;
        5. where we are required or authorized to do so by applicable law or by order of a court of competent jurisdiction;
        6. to regulatory or governmental authorities, as required by applicable law;
        7. where you provide your consent; or
        8. where permitted or required by applicable law.
        We may process, store, and transfer your personal information to another Canadian province or to a foreign country with different privacy laws that may or may not be as comprehensive as Canadian law. By submitting your personal information, you consent to this transfer, storage, or processing. Where applicable, we will take steps to require that such third parties treat your personal information in accordance with this Privacy Policy and use, process, and share it only for the purposes for which it was collected or otherwise in accordance with Privacy Law. There are instances where we may Handle your personal information without your consent, including to comply with a subpoena or court order or to comply with the rules of court regarding the production of records. If we plan to share, disclose, or transfer your personal information to a third party for a purpose not previously identified, either in this Privacy Policy or separately, we will advise you of that purpose prior to any such sharing, disclosure, or transfer, and we will provide you with an opportunity to withdraw or refuse your consent to such sharing, disclosure, or transfer.
    15. Security and Fraud. Company takes the security of your personal information seriously. Following industry standards, we take reasonable steps to help protect the confidentiality and security of personal information you share with us. We have implemented reasonable physical, organizational, administrative, procedural, and technological security measures and safeguards to safeguard and protect the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, including computer safeguards (such are firewalls and secured files), secured buildings, and Secure Sockets Layer (SSL) technology to protect the transmission over the internet of your payment card data. You can check the security of your connection by looking at the URL line of your browser. When accessing a secure website, the first characters of the site address change from “http” to “https.” If you are using a web browser or firewall that does not permit communications through secure websites, you will not be able to make purchases on our site. HOWEVER, GIVEN THAT ELECTRONICALLY SUBMITTED DATA IS NOT ONE HUNDRED PERCENT (100%) SECURE, WE MAKE NO WARRANTIES AS TO THE SECURITY OF ANY SUCH PERSONAL INFORMATION THAT YOU SUBMIT BY WAY OF THE INTERNET, INCLUDING BY EMAIL, WHICH YOU DO AT YOUR OWN RISK. We encourage you to take steps to help protect the confidentiality and security of your personal information, including the following:
        1. if you have a user account, reviewing your account periodically and immediately reporting any unexpected activity or unrecognized information;
        2. installing the latest security updates and anti-virus software on your computer to help prevent malware and viruses;
        3. using strong and complex passwords (i.e., with a minimum of seven alphanumeric case-sensitive characters);
        4. not using the same password on more than one website;
        5. not sharing your password with others;
        6. password-protecting your computer and mobile device; and
        7. signing out or logging off of website sessions so that your session is closed, especially when using a public computer.
    16. Links and Third-Party Affiliate Websites. For your convenience, Company and this Site offer links from and to third-party websites, including website owned and operated by Third-Party Affiliates. When you click on these links, they will direct you away from this Site. Once you leave this Site or are redirected to a third-party website, you and your personal information are no longer governed by this Privacy Policy. YOU ACKNOWLEDGE AND AGREE THAT COMPANY WILL NOT BE RESPONSIBLE FOR AND EXPRESSLY DISCLAIMS ANY AND ALL LIABILITY FOR THE HANDLING OF PERSONAL INFORMATION BY THIRD PARTIES WHEN YOU LINK TO THEIR WEBSITES, INCLUDING THOSE OF THIRD-PARTY AFFILIATES, AND WE ENCOURAGE YOU TO READ THEIR PRIVACY STATEMENTS AND POLICIES BEFORE PROVIDING ANY PERSONAL INFORMATION.
    17. Third Party Affiliates. Company or this Site may transfer your personal information to Third-Party Affiliates to support this Site and administer or provide related products, services, or information to you. In general, Third-Party Affiliates will Handle your information only to the extent necessary for them to perform their obligations in connection with this Site, including to allow them to provide you with related products and services you requested. Third-Party Affiliates have their own privacy policies governing the personal information we are required to provide to them for your purchase-related transactions or for marketing purposes. We recommend that you read their privacy policies so you understand the manner in which your personal information will be Handled by them. In particular, please note that certain Third-Party Affiliates may be located in or have facilities that are located in a jurisdiction outside Canada. As a result, your personal information may be Handled outside Canada. If you elect to proceed with a transaction that involves a Third-Party Affiliate, your personal information may become subject to the laws of the jurisdiction in which that Third-Party Affiliate or its facilities are located, and contractual or other measures we may use to protect your personal information will be subject to the legal requirements of the foreign jurisdictions (such as the United States, Europe (including the United Kingdom or Russia), or Asia (including China or India)) where your personal information may be transferred or otherwise Handled, including lawful requirements to disclose information to government authorities in those foreign jurisdictions. For example, if your personal information is shared with a Third-Party Affiliate located in the United States, your personal information may be subject to disclosure under United States legislation, including the Patriot Act.
    18. Your Rights. Your principal rights under Privacy Law include the right to access, the right to rectification, the right to erasure, the right to object to processing, the right to data portability, the right to complain to a supervisory authority, and the right to withdraw consent. You have the right to confirm whether we process your personal information and, where we do, access to the personal information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal information concerned and the recipients of the personal information. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal information. The access to your personal information is supposed to be free, but it may be subject to a reasonable fee for its transcription, reproduction, or transmission. Should a reasonable fee be asked, you will be informed prior to the transcription, reproduction, or transmission of your personal information. In some circumstances you have the right to the deletion of your personal information without undue delay, including where the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise Handled, you withdraw consent to consent-based Handling, you object to the Handling under certain rules of applicable data protection law, the Handling is for direct marketing purposes, and the personal information has been unlawfully Handled. However, there are exclusions of the right to deletion. The general exclusions include where Handling is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise, or defense of legal claims. You can exercise your rights by contacting our Privacy Officer via email to [email protected] or via our Contact Us page.
    19. Accessing and Correcting your Information. It is important that the personal information that Company holds about you is accurate and current. Please keep us informed if your personal data changes. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may contact our Privacy Officer via email to [email protected] or via our Contact Us page to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance. We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We will provide access to your personal information, subject to exceptions set out in applicable Privacy Law. Examples of such exceptions include information protected by solicitor-client privilege, information that is part of a formal dispute resolution process, information that is about another individual that would reveal their personal information or confidential commercial information, and information that is prohibitively expensive to provide. If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer via email to [email protected] or via our Contact Us page.
    20. Governing Law. This Privacy Policy and the interpretation, validity, effect, and enforcement of this Privacy Policy, and any and all disputes arising out of or in connection with this Privacy Policy, will be governed by the laws of the Province of Alberta and the federal laws of Canada applicable therein without giving effect to any principles of conflicts of law. For greater certainty, these laws apply notwithstanding your domicile, residency, or physical location, or the location of any office of Company or any of its affiliates or any Company personnel with whom you may communicate or deal.
    21. Choice of Forum for Disputes. You hereby unconditionally and irrevocably consent and agree to submit to the exclusive jurisdiction of the courts of the Province of Alberta in any action or proceeding in connection with this Privacy Policy and waive any objection relating to improper venue or forum non conveniens to the conduct of any proceeding in any such court.
    22. Jury Trial Waiver. You acknowledge and agree that, to the maximum extent permitted by applicable law, you waive the right to a trial by jury in respect of any and all disputes arising from or in connection with this Privacy Policy.
    23. Admissibility. A printed version of this Privacy Policy and of any notice given in electronic form will be admissible in judicial proceedings based upon or relating to this Privacy Policy to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.
    24. Contacting Us. If you have any questions about this Privacy Policy or to revoke your consent to our collection, use, processing, or sharing of your personal information, you may contact our Privacy Officer via email sent to [email protected] or via our Contact Us page.

    Beach Life Network Inc.
    [email protected]

PRIVACY POLICY - USA

INTRODUCTION

We take user privacy seriously and want you to be informed. This Privacy Policy, which is incorporated into our Terms of Service, outlines the privacy practices of Beach Life Network Inc. (“Company,” “us,” “we,” or “our”) in connection with your (“you” or “your”) access to or use of our Website https://bankbeach.com, and related services (collectively with the Website, the “Service”). By accessing or using our Service, you acknowledge that you have read, understood, and agree to be bound by our terms, including this Privacy Policy.

WHO ARE WE?

We provide you with information and access to third parties (“Affiliate Marketing Providers”) who provide affiliate marketing services. After you submit a request for information (a “Request”) on the Website, or call the phone number on the Website, you may be contacted by phone, email, or text by one or more Affiliate Marketing Providers.

Generally, we collect information related to our Service, such as through your submission of a Request or other form on our Website and any feedback, including reviews or social media comments, you provide about the Service. This means we generally collect personal identifying information when you knowingly provide it to us, such as by filling out an online form so we can contact you, or providing us with documentation about your business for us to review in conjunction with the Services we will provide to you.

Like most websites, we also collect routine device and other data through the Website, and we use data to deliver advertisements that may be of interest to you.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy outlines how we collect, use, and disclose information of users, both online and offline. Please also see our separate Terms of Service, which incorporate by reference this Privacy Policy and include definitions applicable to this Privacy Policy.

Unless otherwise expressly stated, this Privacy Policy does not apply to any third-party practices, websites, or services—including those of any Affiliate Marketing Provider. Each third party will have its own privacy practices and policies, which you should review before using them.

HOW DO WE COLLECT AND USE INFORMATION?

The personal information we collect through our Website, affiliates, or service providers may be acquired through the following means:

Information you provide when you submit a Request or other webforms on our Website. This encompasses data you furnish when creating an online account, subscribing to our e-newsletters or other communications, seeking information from us, engaging with customer support, reporting issues with our Website or Service, or engaging in other forms of communication with us.

• >Records and copies of your correspondence, including email addresses, if you reach out to us.
• >Your survey responses, which we or our service providers might request for research purposes.
• >Your search queries conducted on our Website.
• >Interactions with customer service/support.
• >Information from third-party websites and mobile applications (e.g., websites sharing information with us or advertising partners about online activities).
• >Data from suppliers (e.g., companies providing consumer demographics and other data).
• >Data acquired from mobile applications (parent, subsidiary, and affiliate brands).
• >Joint marketing partners.
• >Online advertising companies.
• >Social media companies.
• >Other service providers.

Like many companies, we also collect internet and device information, such as from cookies and other automated technologies, when you browse our website or interact with our advertisements on other sites or social media platforms.

We collect all of this information for our business purposes, namely, to provide and improve our Service. Part of this includes compliance with applicable laws, such as responding to legal requests, enforcing this Privacy Policy and our rights, and protecting others and our Service. We may also use information for short-term, transient use for an interaction with you and to personalize your experience and communications. We use information for security purposes and to protect against harmful activity. Further, we may use information for debugging for functionality, auditing interactions, and internal research. Moreover, we may use information as otherwise instructed by you and with your consent.

In addition, we collect information for commercial purposes, meaning to market our goods and services. For example, we collect device and other data to better target advertisements and other content in an effort to create a more personally relevant experience.

We use information for the same reasons that we collect it. For example, we use information for business purposes, such as running our website and sending you communications about your request and Affiliate Marketing Providers, as well as commercial purposes, such as advertising to you after you leave our website. We also use information for the reasons that we disclose it, as outlined below.

More specifically, we collect the following information for the referenced purposes.

Category	Examples of Data Collected	Collection Point	Purpose for Collection and Use
Identifiers	Contact Information, such as name, telephone number, street address, and email address.	We collect this information when you provide it, such as when you complete a form on the Website. We may also collect data from third parties, such as lead generation companies who have provided your information to us as a small business that may be interested in our Services.	We collect and use data for all business purposes, such as providing and improving our Services, your information to Affiliate Marketing Providers, responding to communications, and for security and auditing purposes. We may also collect and use your contact information to market our offerings to you, such as through emails.
Commercial Data	Financial, such as name, information about your creditors and debt, and so forth. Inferences, such as creating a profile relating to consumer preferences and trends.	We collect this information when you provide it, such as when you submit a Request. We may also collect information from third parties to help with responding to your requests, processing transactions, and improving offerings. We collect and use data for all business purposes, such as providing and improving our services, connecting you with Affiliate Marketing Providers, responding to communications, and for security and auditing purposes.	We may also use inference information to market offerings of interest to you.
Personal Background	Protected Class, such as sex or age.	We collect this information when you provide it, such as when you submit a Request.	We collect and use data for all business purposes, such as to connect you with Affiliate Marketing Providers, respond to communications, and for security and auditing purposes.
Device Data	Internet and Network Data, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. See below for more information about cookies and other tracking technologies. Geolocation, such as general location from an IP address.	We collect this data through cookies and other automated technologies. For example, like many companies, we automatically gather information about your device, such as your IP address, browser type, and operating system. For more information on these practices, see below.	We collect and use data for all business purposes, such as providing and improving our services and for security and auditing purposes. We may also use device data to market offerings of interest to you.
Sensitive Data	In addition to categories described above, we may collect the following: Identification Information, such as your Social Security Number, business EIN, driver’s license information, date of birth, other tax information, employee information, and financial information necessary to assess your debt.	We collect sensitive information only when you expressly provide it to us. For more information on these practices, see below. We only collect and use sensitive data for the business purposes outlined, such as to connect you with Affiliate Marketing Providers.
Other Personalized Data	Employment, such as employee data necessary to connect you with Affiliate Marketing Providers. Other Information, such as communications to us.	We may collect this information if you provide it, such as if you apply for a job or send us a message or documents.	We collect and use data for business purposes, such as reviewing and preparing forms and providing and improving the Service.
Other Non-Personalized Data	Public information Aggregate information De-identified data Pseudonymized data	We may collect this information at any time, from public, third party, and other sources.	For example, we may share a public review that you posted about us or use aggregate data for our analytics. We may collect and use this data for any business or commercial purposes. The information will either be public data or not identify individual users.

WHEN DO WE DISCLOSE INFORMATION?

As part of our business, we disclose information as follows and for the outlined purposes, which include business purposes to provide and improve the Service and comply with legal and contractual obligations, as well as commercial purposes, such as to market our business.

Affiliate Marketing Providers. If you submit a Request, we may share your personal information with Affiliate Marketing Providers so that they can contact you about your marketing options and possible opportunities.

Affiliated Entities; Merger or Sale. We may share information with affiliated companies that are related to us under a common ownership where they comply with this Privacy Policy. Such disclosure is for our business purposes, including to provide and improve our offers. Further, we may share information as part of a sale, merger, acquisition, or other change in control or entity status, either in whole or in part. We reserve the right to transfer or assign your information as part of any such transaction or investigation.

Service Providers and Contractors. We share information with our own service providers as needed to provide and improve the Service. Service providers only use your information for a contracted-business purpose. Such disclosure is for our business purposes, in particular to provide you with the Service. We may likewise share information with “contractors” that are not service providers but to whom we disclose information for a business purpose. Such disclosure is for the business purpose of providing you with information or services that you have requested or considered.

For example, if you utilize any “live chat” feature on our website, your chat transcripts may be monitored in real time by and/or shared with our third-party service providers, such as our customer service agents and customer management software.

Cookies/Device Data. For more information about our use of cookies and other technologies, see below. Such disclosure is for our business purposes, in particular to provide you with the Service, as well as commercial purposes, such as to market to consumers that may be interested in our Service or related offers. Company may also contract with third-party advertising companies to serve ads on our behalf. These companies may use cookies or other measures to collect non-identifier information.

Legal Process and Protection. We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, law enforcement inquiries, legal processes, subpoenas, and court orders. We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions or security incidents that may cause harm to us, the Service, or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of this Privacy Policy, our terms, or any legal rights.

Consent. We may disclose information as requested or consented to by you. Such disclosure may be for any business or commercial purpose as described to you.

HOW DO WE USE COOKIES AND SIMILAR TECHNOLOGIES?

As with many companies, we may use cookies, pixels, gifs, web beacons, log files, and/or similar technologies to automatically collect certain information when you use the Service or interact with our digital media content, such as when you visit our website. This allows us to track individual users, determine when content is accessed, and customize user experiences. For example, unless you have opted out of cookies or changed your cookie settings in your internet browser, your browser automatically sends us certain device, browser, internet connection, and general geolocation information and certain internet activity information. For instance, we may collect your mobile device identifier or MAC address, ISP carrier information, date and time you access the Service, the pages you visit, and whether you click on ads. You can change your cookie settings in your internet browser and use settings on your device to manage your privacy controls. For more information and ways to opt out, see https://www.allaboutcookies.org/, and learn how to disable these tools by opting-out of third-party cookies and mobile device ID practices.

As part of our practices, we may use third-party advertising companies to display ads tailored to your individual interests based on your online activity and to provide ad-related services such as analytics and market research. Third parties, in turn, may use a cookie, web beacon, or other similar technology to collect information. To opt-out of cross-device linking, visit www.aboutads.info/choices or perform a global opt-out on each browser and device.

In particular, we may use Google cookies and tools, such as Google Analytics and in certain cases Google Maps, for analytics and advertising and to improve the user experience, and your information may be shared with Google; for more information, visit the Google Cookie Policy, Google Analytics Opt-Out Browser Add-On, or Ads Settings. We may also use Meta and other cookies for the purposes stated above, and your information from cookies may be shared with Meta; for more information visit the Meta/Facebook Cookie Policy.

Please note that there are different types of cookies and related technologies, including session (temporary cookies that last for a browser session) and persistent (cookies that remain on a user’s device for a specified period of time) cookies, which may be placed by us or third parties, including the following:

• Essential Cookies (sometimes called Strictly Necessary Cookies): these are automatically placed on your computer or device when you access our website. They are necessary to facilitate the operation of the Website and delivery of its content to your device. We use Essential Cookies to identify you as a unique use of the Website and to authenticate your login credentials.
• Functional/Preference Cookies: these are used to remember your preferences and various settings for viewing the Website and improve overall functionality. Certain aspects of the Website may not work properly or at all absent these functional cookies.
• Analytics/Performance Cookies: These cookies allow us to measure how you and other users are interacting with the website. We view the resulting performance statistics (or “analytics”) and may make changes to the Services based on them.
• Targeting/Advertising Cookies: These cookies track your activity on and off the Website and are used to identify visitors between different websites on the internet. Personal information collected through targeting cookies may be used to build a profile of user interests and deliver personalized advertising to such user.

DO WE SELL OR SHARE INFORMATION?

Yes. As stated in our Terms of Service, we are lead generators and we may earn commissions or other fees when we pass on your information to a third-party Affiliate Marketing Provider with which you later do business. Under some privacy legislation, this constitutes a sale of personal information.

Company participates in targeted ads, also called interest-based or online behavioral advertising, which may include cross-context behavioral advertising. Under some privacy legislation, this may constitute “selling” or “sharing” of personal information, such as for business purposes (e.g., providing our Service) and commercial purposes (e.g., other marketing).

To opt out of these practices, contact us as outlined below and see our Do Not Sell or Share My Personal Information link.

HOW DO WE PROTECT AND TRANSFER INFORMATION?

Consistent with others in our industry, we take efforts to employ technical, administrative, and physical security measures for personal information, taking into account reasonable security procedures and accessible technology. However, no system can be completely secure; and we cannot promise, and you should not expect, that your personal information will always remain secure. Your provision of personal information is at your own risk. The safety and security of your information also depends on you. Take steps to safeguard your passwords and other data and notify us as soon as possible if you believe your account security has been breached.

If you are visiting the Service from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Service, you authorize and specifically consent to the transfer of personal data to the United States and its storage and use as specified in this Privacy Policy.

HOW LONG DO WE RETAIN INFORMATION?

We retain personal information for the length of time necessary to fulfill the purposes outlined in this Privacy Policy, unless a different retention period is requested by you or required or permitted by law. For example, we will retain your personal information for as long as it is needed to provide you with the Service or fulfill a legal or contractual obligation. We may also aggregate, deidentify, or anonymize personal information as applicable for use in analytics, such as to analyze trends over periods of time without specifically identifying you.

We use the following criteria to determine how long we retain personal information: (a) our relationship with you, such as if there is an open contract or account or a pending transaction or request; (b) legal obligations to retain personal information for certain purposes, such as to maintain transaction records; and (c) other obligations or considerations relating to the retention of data, such as contract requirements, litigation holds, investigations, or statutes of limitation.

WHAT ARE YOUR PRIVACY RIGHTS?

We value consumer privacy rights and strive to provide flexibility with how your personal data is used and shared. If you want to make a privacy request or have any questions, please contact us through our Contact Form or email [email protected] with your name and email address or other identifier used in connection with our Service so that we can verify your request. If an authorized agent is making a request on your behalf, the agent should provide its name and contact information, such as an email address, in addition to your information. There may be situations where we cannot grant your request; for example, if you make a request and we cannot verify your identity, or if you request deletion of data that we have a legal obligation to keep. Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

Applicable privacy laws have different requirements and depend on various factors, such as where you live and how much revenue or data is at issue. Generally, we adhere to the following set of privacy rights to the extent applicable and subject to any limitations authorized by law.

• Access. You can access and obtain your data and ask us for certain information, including: the categories of personal information collected and used; the categories of the sources of data; the business or commercial purposes for collecting, selling, or sharing data; the categories of third parties to whom data is disclosed; and the specific pieces of personal information collected. You also have a similar right to data portability (the ability to export, back up, and transfer data).
• Amend. You can amend, correct, or rectify your data if it is inaccurate.
• Delete. You can have your data deleted subject to certain legal limitations.
• Limit. You can limit the processing of your data, in particular the use of automated decision making, such as profiling. We will also respond to recognized global opt-out preference signals where we can verify the request. For more information, see below.
• Opt-Out. You have the right to opt-out of certain data practices. For example, you can unsubscribe from marketing communications by following the opt-out instructions in each message or by contacting us as outlined in this Privacy Policy (please note that we may still send non-marketing messages, and that consent to receiving marketing communications is not mandatory to use the Service). You may also opt out of the “sale” or “sharing” or your personal information to the extent applicable. Please see our Do Not Sell or Share My Personal Information link. You may opt out of the use of automated decision-making technology if applicable. We will also respond to recognized global opt-out preference signals where we can verify the request. For more information, see below.
• Complaints. You have the right to make certain complaints, including for privacy concerns. We value your feedback and seek the opportunity to work with you on any issues. You have the right to no discrimination for asserting your privacy rights.
• Specific State Laws. Several states have enacted privacy laws that may apply to you, depending on the circumstances. For example, the California Consumer Privacy Act (“CCPA”), updated by the California Privacy Rights Act (“CPRA”), governs certain California-related conduct. Under California’s “Shine the Light” law, California residents may also request certain information regarding Company sharing personal information with third parties for their direct marketing purposes. Further, if you are a California resident under the age of 18, California Business & Professions Code Section 22581 permits you to request and obtain removal of content you have publicly posted. Please note that such a request does not ensure complete or comprehensive removal of public content.
• European Laws. Generally, residents of the European Economic Area (“EEA”) have the right to access your own information that we hold; to ask that your information be corrected, updated, or erased; and the right to object to, or request that we restrict, certain processing of your information. Our legal basis for collecting and using your personal data is your consent, the fulfillment of our obligations pursuant to the contract created between you and Company, or where the collection and use is in our legitimate interests and does not violate your data protection interests or fundamental rights. You may withdraw your consent to our collection and use of your personal data. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information used in reliance on lawful processing grounds other than consent.
• Other Laws. If certain other privacy laws apply to you that provide you with additional rights, please contact us to make a request, as we strive to comply with all privacy rights.

DO WE COLLECT INFORMATION ABOUT CHILDREN?

No, we do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected such information, we will delete it from our database. We have no such information to use or to disclose to third parties or to otherwise report, including under the Children’s Online Privacy Protection Act (“COPPA”). We do not have actual knowledge of selling or sharing the personal information of consumers under the age of 16.

HOW DO WE USE OR DISCLOSE SENSITIVE INFORMATION?

We do not generally use or disclose “sensitive” personal information, nor do we use sensitive information for purposes other than those specified in the CPRA, which provides for the following uses without additional disclosures where the information is reasonably necessary and proportionate to the use: (a) to perform certain services, such as verifying information or for analytics; (b) to verify or maintain the quality or safety of our Service; (c) to perform services or provide goods reasonably expected; (d) for short-term use where there is no disclosure or profiling; and (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety.

DO WE OFFER FINANCIAL INCENTIVES FOR YOUR DATA?

No, we do not currently offer any financial incentives for your data.

DO WE RESPOND TO DNT SIGNALS OR GPC?

No, our Service does not currently respond to DNT, short for Do Not Track, requests. DNT is a feature that, when enabled, sends a signal to websites to request that your browsing not be tracked.

"GPC” is short for Global Privacy Control settings in your browser or extension. We recognize GPC signals. This means that if your browser has GPC enabled, our website will automatically recognize your GPC signal and opt you out of the sale of your personal information, if any. For more information about GPC, please click here: https://globalprivacycontrol.org/.

HOW DO WE UPDATE THIS PRIVACY POLICY?

We will update this Privacy Policy when our privacy practices change or as otherwise required or permitted by law. Each time you use the Service, the current version of this Privacy Policy will apply. Unless we receive your express consent, any revised Privacy Policy will apply only to information collected after the effective date of the revised Privacy Policy.

HOW CAN YOU CONTACT US?

Please contact us with any questions or concerns! We can be reached at:

Beach Life Network Inc.
850 New Burton Road PMB 2018, Suite 201
Dover, Delaware 19904

Last Updated: April 29, 2024