A Safer Walk Privacy Policy

Effective Date: July 19, 2022

1856137 Alberta Ltd. d/b/a A Safer Walk, together with our affiliates and partners, (collectively, “A
Safer Walk” “us”, “we”) respect your privacy and collect, use or disclose your personal information
only in accordance with this Privacy Policy (the “Privacy Policy”) and federal and provincial privacy
legislation applicable to us.

This Privacy Policy describes how we collect personal information of users (“you”) through our
mobile application A Safer Walk, our website asaferwalk.com and the features, tools, materials or
services made available on these platforms (collectively, the “Services”) as well as how we use and
disclose that personal information.

Providing us with your personal information is always your choice. By accessing our Services or
providing your personal information (or that of an individual for whom you act as parent or legal
guardian) to us, you are expressly consenting , on your own behalf or on behalf of such individual, to
the collection, use and disclosure of your or their personal information in accordance with the terms
and conditions in this Privacy Policy.


Information You Provide to Us Directly
We may collect certain personal information that you provide when you use our Services, such as
when you (1) create an account; (2) send questions or comments to us; (3) fill out surveys; (4)
transmit user content to us; or (5) otherwise communicate with us. The types of personal information
that the we might collect from you include, without limitation:
• name (including parent/guardian name);
• date of birth;
• gender identity;
• photo ID;
• photographs;
• mailing address;
• phone number;
• e-mail address;
• driver’s license number;
• organization ID number (such as student ID or staff ID);
• location;

• personal health information;
• criminal history;
• username, password and other login information; and
• other contact or identifying information; about you or an individual for whom you act as parent or legal guardian.
You are not required to provide us with such information, but certain features of the Services will not
be accessible or available, absent the provision of the requested information.

Information Automatically Collected
We also may receive and store certain technical and non-personal information about you and your
device(s) automatically when you access or use the Services. This information may include:
• Technical Information. We may collect technical information associated with your activity
on the Services, which may include information related to your browser and operating
system, IP address (the Internet address of your computer) unique device identifiers, and
other information such as your device type. We use such information for diagnostic and
statistical purposes and to administer the Services.
• Usage Information. We may collect information to better understand customer traffic
patterns and usage of the Services. This may include the webpage that you were visiting
before accessing the Services, the pages or features of the Services that you browsed, and
information about which part of the Services you visit and how much time you spend there.
This information is used to analyze and improve the Serivces and to provide our users with a
better user experience.
• User Preferences. We may collect information about your preferences to make your use of
the Services more productive through the use of cookies. For more information about
cookies, see the “Cookies, Beacons and Other Technologies” section below.

We do not rent, sell or lease your personal information to third parties.
We use and disclose your personal information for the purposes for which it was collected, as well
as other purposes for which you have given consent, or as otherwise required or permitted by law.
This includes, but is not limited to, the following purposes:

• Operating and administering the Services. We may use your personal information in
accordance with the uses described in our Terms of Use. This includes administration of any
user account you may have for the Services.

• Marketing. In accordance with anti-spam laws, we may obtain your consent in order to send
you commercial electronic messages. We do not share email addresses or other contact
information with third parties without your permission.

• Notifications. We will ask you if you wish to receive notifications about services that you
request. If you agree, we will send you email or text messages to notify you about the status
of your requests.

• Responding to inquiries. We may use your personal information to respond to any inquiries from you.
• Informing of policy changes. We may use your personal information to contact you
regarding changes to our Terms of Use or Privacy Policy.
• Delivering satisfactory service. Your information helps us to more effectively respond to
your customer service requests and support needs. We may also contact you through
surveys to conduct research about your opinion on certain matters related to our services.
• Maintaining security and regulatory requirements. We may share your personal
information with government agencies to fulfill legal, reporting, and regulatory requirements
and we may release your information when we believe release is appropriate to comply with
the law, to enforce our policies, or to protect or defend our legal rights or to protect the safety
and security of other users.
• In the event of a sale or merger. In the event of sale, transfer, merger, reorganization,
dissolution, or similar event we may transfer your information to one or more third parties as
part of that transaction, including during the negotiation of an actual or contemplated
transaction, but we only provide as much information as is needed for the purposes of the
transaction. If we sell our organization or merge with another party, you hereby consent to
the transfer of your personal information and all information you provide to us, to our
successor for the same purposes as set out in this Privacy Policy.
• Engaging in activities related to the above.

We may send your personal information to our service providers, suppliers, our legal and financial
representatives who help us provide services to you and to help us complete the above-noted
purposes and tasks so long as those parties agree to keep your information confidential and to
handle such information in compliance with applicable privacy laws. All such third parties are made
aware of the confidential nature of your personal information. Your personal information will be
shared with these third parties on a “need to know” basis only and we limit the information shared to
what is needed for the specific task being performed or fulfilled.

As described above, we may use cookies, web beacons, pixels, session replays, screen captures,
and other similar technologies to collect information and personalize your experience with the

Cookies are small web files that a website transfers to your device’s hard drive through your web
browser that enables the website’s system to recognize your browser and remember certain
information. We may use first party cookies to make the Services function properly, improve the
Services, recognize you when you return to our Services, keep you logged in while browsing,
remember the information your previously provided, and to provide a secure browsing experience.
We may also use third party analytics providers to compile aggregate data about site traffic and site
interaction and to collect information about your computer and internet connection, including your IP
address, operating system, and browser type.

If you are uncomfortable with the use of cookies, you can disable cookies on your computer by
changing the settings in the preferences or options menu in your browser. However, please be
aware that if you do delete and block all cookies, some parts of the Services may not work. To find
out more about cookies, including to see what cookies have been set and how to manage and delete
them, visit https://www.allaboutcookies.org/ .


Web beacons, also known as web bugs, pixel tags or clear GIFs, are small graphics with a unique
identifier that may be included on the webpages to deliver or communicate with cookies, in order to
track and measure the performance of the websites and related services, monitor how many web
visitors use the websites, and to monitor the effectiveness of our advertising. Unlike cookies, which
are stored on the user’s hard drive, web beacons are typically embedded invisibly on webpages (or
in an email). We may also use (or our third-party suppliers may use) automated technologies
together with personal information that we have collected about you to tailor and deliver ads and
content to you when you are on the websites.

Please be aware that, as part of the Services, we may use your personal information to render
decisions based exclusively on automated processing, such as decisions regarding eligibility to
participate in the Services. If you have a request regarding this, please contact us at
info(at)asaferwalk.com .

We have implemented and maintain reasonable and appropriate security measures, procedures and
practices to protect against the loss and unauthorized access, use, modification, destruction or
disclosure of your personal information while it is in our custody or under our control. We use
physical, organizational and technological industry-standard security safeguards appropriate to the
sensitivity of personal information and other data collected, used or disclosed.

The safety and security of your information also depends on you. Where we have given you (or
where you have chosen) a password for access to certain parts of the Services, you are responsible
for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of personal information via the internet is not completely secure.
Although we do our best to protect your personal information, we cannot guarantee the security of
your personal information transmitted to the Services or over any public network. Any transmission
of personal information is at your own risk. Without prejudice to any mandatory legal obligations to
which we may be subject, we are not responsible for circumvention of any privacy settings or
security measures on the Services.

Retention and Storage
We retain your personal information for only as long as is needed to fulfill the purposes for which it
was collected, or for as long as necessary to comply with applicable laws, whichever is longer.
Personal information that is no longer required is destroyed, erased or anonymized. Your consent to
our collection, use and disclosure of your personal information for such purposes remains valid after
the termination of our relationship with you.

Please note that your personal information may be accessed, transferred, disclosed, stored and
processed in Canada, the United States and any other country where the we or our affiliates, service
providers, supplier, representatives or agents are located or where their cloud computing
infrastructures may be hosted.

Children under the Age of 13
We are committed to protecting the privacy of minors. Our Services are not intended for children
under 13 years of age. No one under age 13 may provide any information on the Services. We do
not collect personally identifiable information from any person we actually know is under 13 years old
without parental consent.

If you are under 13 years old, do not:

• use or provide any personal information on our Services,
• register for our Services, or
• provide any personal information about yourself to us, including your name, address,
telephone number, email address, or any screen name or user name you may use.
If we learn we have collected or received personal information from a child under 13 years old
without verification of parental consent, we will delete that information. If you believe we might have
any personal information from or about a child under 13 years old, please contact us at
info(at)asaferwalk.com .

Individuals Located Outside Canada
Your personal information will be processed in accordance with this policy and in compliance with
Canadian federal and provincial privacy law.

Third Party Links
The Website may contain links to other websites operated by third parties. Please note that this
Privacy Policy applies only to the personal information that we collect or receive from third parties
with your consent and we cannot be responsible for personal information that third parties may
collect, disclose, store and use, including through their websites. You should always read the privacy
policy of each website you visit carefully.

We make commercially reasonable efforts to keep your personal information complete, up-to-date
and accurate. Should you wish to access, update, correct or delete your personal information, or
express any concerns regarding our use of your personal information, please contact our Privacy
Officer at the contact information set forth below. We ask that you provide us with the name, address
and email address that you previously provided to us, a brief description of under what
circumstances you provided your personal information to us, and the purpose of your request. If you
are unsure as to whether we are holding any personal information that belongs to you, you may also
contact our Privacy Officer for confirmation.

We will make reasonable efforts to respond to your request as soon as practicable, or in any event,
in compliance with applicable laws. In order to protect your privacy and security, we will take steps to
verify your identity before granting access or making any changes to the personal information that
we maintain.
If you are a resident of Quebec, you have certain additional rights under applicable data protection
laws. These may include the rights (i) to restrict dissemination of your personal information or to
have your personal information de-indexed from search results (the right to be forgotten); (ii) to be
informed when your personal information was used to render a decision based exclusively on
automated processing and to request further information about the automated decision-making; and
(iii) to data portability. If you have a request regarding these rights please contact us at
info(at)asaferwalk.com . We will consider and act upon any request in accordance with applicable data
protection laws. 

You may, at any time, withdraw your consent to our collection, use and disclosure of your personal
information, subject to reasonable notice and any legal or contractual restrictions. Should you

choose to withdraw your consent, we may be unable to provide, or continue to provide, services that
can only be provided if we receive appropriate and required personal information.

Where applicable, we will seek your express consent to contact you, including by way of commercial
electronic messages, which may include email or SMS text messages. You can unsubscribe at any
time from receiving commercial electronic messages by following the instructions in the message or
by contacting us at info(at)asaferwalk.com .

Even if you have opted out of receiving marketing communications from us, please be aware that we
may still contact you for other purposes. For example, we may contact you to provide
communications you have consented to receive, regarding the services we provide to you, or if you
contact us with an inquiry.

We may update this Privacy Policy from time to time for any reason whatsoever. We encourage you
to periodically review this Privacy Policy in order to stay informed of how we are protecting your
personal information. Each time this Privacy Policy is amended, the “Last Updated” date at the
beginning of the Privacy Policy will be revised. If we make any material or substantive changes in
this Privacy Policy, we will notify you by posting a clear and conspicuous notice of these changes on
the Series and in this Privacy Policy and sending you an email to the last email we have on file. Any
changes that are made to this Privacy Policy will apply to both any Personal Information that we hold
prior to the date of the amended Privacy Policy and any Personal Information that we collect on or
after such date.

All matters relating to your access or use of the Services shall be governed by the laws of the
Province of Alberta and the laws of Canada applicable therein, without regard to principles of
conflicts of law. You agree and hereby submit to the exclusive jurisdiction of the courts of the
Province of Alberta with respect to all matters relating to your access and use of the Services, as
well as any dispute that may arise therefrom.

If there are any questions regarding this privacy policy you may contact our Privacy Officer by
emailing info(at)asaferwalk.com .