This privacy policy (this “Policy”) describes the practices of Benefit Plan Administrators Ltd and its corporate affiliates (“People”, “we”, “us”, “our”) with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct and access your personal information provided to us from you as a user of (a) the website operated at and such other locations as made available from time to time (the “LiUNAcare mHealth Portal”), (b) any front-end software provided by us (for greater certainty, excluding third party software that may interact with the LiUNAcare mHealth Portal or the Service, as defined below), including a health assessment tool (the “Assessment Tool”) that interacts or interfaces with the LiUNAcare mHealth Portal (the “Software”), and (c) the services we provide through the LiUNAcare mHealth Portal and/or the Software (collectively, the “Service”). It also describes the choices available to you regarding our use of your your personal information and how you can access and update this information. This Policy is incorporated by reference to the general Terms of Use for People located at, and forms an integral part of it. All capitalized terms not otherwise defined herein have the meaning provided in People’s Terms of Use.

1. Introduction and General Concepts

We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for processing your personal information.

  1. Personal Information

    For the purposes of this Policy, “personal information” means any information about an identifiable individual, including but not limited to an individual’s name, home address, telephone number, gender, but excludes any business contact information that is processed solely for the purpose of communicating with that person in relation to their employment or profession, any information that is anonymous or unidentifiable such as web browsing information or aggregate information, and any other information otherwise exempted pursuant to the applicable laws of Canada and other applicable jurisdictions.

    We will only process your personal information in accordance with this Policy, applicable laws and our ordinary business practices. This Policy only covers our processing of personal information.

  2. Information about Minors

    The LiUNAcare mHealth Portal, Software, and Service is intended solely for the Covered Individuals, their Covered Spouses and Minor Dependents (each as defined in the Terms of Use). When Covered Individuals provide access to the LiUNAcare mHealth Portal, Software, and Service to their Minor Dependents, Covered Individuals acknowledge that they hereby consent and are deemed to have consented on behalf of their Minor Dependents to the collection, use, and disclosure of such Minor Dependent’s personal information in accordance with this Policy to the extent such Minor Dependent is not able to provide such consent.

  3. Third party personal information

    We do not knowingly collect personal information about any third parties from you and you agree to not provide us with any such third party personal information for any reason.

  4. Privacy Officer

    We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.

  5. Other Websites

    Our LiUNAcare mHealth Portal, Software or Service may contain links or direct you to other third party’s websites, software, service providers or Internet resources (the “Other Providers”) that may interact with the LiUNAcare mHealth Portal, Software or Service which are provided for your convenience, benefit and information. When you access any Other Provider, you are contacting another website, software, service provider or Internet resource. We have no responsibility or liability for, or control over, those Other Providers or their processing of your personal information. We encourage you to read the privacy policies of the Other Providers to learn how they process your personal information.

2. Collection of Personal Information

When you use our LiUNAcare mHealth Portal, Software or Service, we may collect the following personal information from you:

  • demographic information such as gender, age,
  • contact information such as name, email address
  • unique identifiers such as user name, password;
  • name of employer;
  • information collected in the health assessment
  • any other personal information provided to us with your consent, express or implied in accordance to the applicable laws, for our collection;
  • any other personal information required or permitted in accordance to the applicable laws for our collection.

To ensure our LiUNAcare mHealth Portal, Software or Service is optimized for your use and for future communications between us and you, we or our service provider (s) may save your user data in the form of cookies and use such cookies to collect standard Internet log information about how and when you use our LiUNAcare mHealth Portal. This information may include but, not be limited to, your IP address and location data, weblogs, time, date, your language preferences, browser used, referring web addresses, other communication data, searches conducted, pages visited. You can manage your cookie preferences, but please note that if you refuse to allow cookies certain features of our LiUNAcare mHealth Portal, Software or Service may not be available for your use.

3. Use and Disclosure of Personal Information

We may use and disclose your personal information for the following purposes as part of our Service through LiUNAcare mHealth Portal or Software (the “Purposes”):

  • To verify eligibility and authenticate the identity of you (and your spouse/partner/eligible dependents where applicable);
  • To assess and evaluate your health status via the Assessment Tool (the “Health Assessment”);
  • To ensure that the LiUNAcare mHealth Portal, Software or Service is optimized for your use;
  • To communicate with you to provide you services, contacts, materials and/or recommendations for your needs as identified by your Health Assessment or you through phone, email, or the LiUNAcare mHealth Portal;
  • To share your personal information with our employees, contractors, consultants and any other third parties such as web hosting providers, (“Third Party Processors”) who require such information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the LiUNAcare mHealth Portal, Software or Service for your use;
  • As otherwise required or permitted by law.

We will only process your personal information for the Purpose(s) for which we intend to process such information. Otherwise, we will not process your personal information without your consent.

4. Your Consent

We will process your personal information only with your knowledge and consent, except where required or permitted by applicable laws. By using our LiUNAcare mHealth Portal, Software, or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified at the time of collection.

If you do not consent to the processing of your personal information in accordance with this Policy, please do not provide any personal information to us.

You may notify us at any time that you wish to withdraw or change your consent to our processing of your personal information, subject to legal restrictions and reasonable notice by (i) changing your privacy preferences to the extent such functionality is made available through the LiUNAcare mHealth Portal, Software or Service, (ii) deleting your account with the LiUNAcare mHealth Portal, Software or Service and stopping use of the People Care Portal, Software or Service, (iii) opting out of the use of your personal information such as unsubscribing to any newsletter or mailing list subscription that we provide through the LiUNAcare mHealth Portal. However, upon your withdrawal or change to your consent, we may not be able to provide you with access to the LiUNAcare mHealth Portal, Software, or Service.

5. Data Sovereignty

Your personal information collected by us will be processed and stored in Canada.

6. Security of Personal Information

The security of your personal information is important to us. We follow and employ generally accepted industry standards as appropriate to the sensitivity of your personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so we cannot guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

7. Requests for Access to and Correction of Personal Information

Applicable Privacy Laws allow, to varying degrees, individuals the right to access, and request the correction of errors or omissions in, his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:

  • identification of personal information under our custody or control;
  • information about how personal information under our control may be or has been used by us; and
  • the names of any individuals and organizations to which the individual’s personal information has been disclosed.

We will respond to requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

8. Retention of Your Information

We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.

9. Updates or Changes to Privacy Policy

We may update this Policy to reflect changes to our information practices. If we make any material changes we will either (a) notify you by email (sent to the e-mail address specified in your account), or (b) provide a notice on the LiUNAcare mHealth Portal or otherwise through the Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Any change to this Privacy Policy will become effective on the date so indicated, and will apply to information collected from the date of the posting of the revised privacy policy and to existing information held by us. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this privacy policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Service signifies your acceptance of any changes to this Policy.

10. Contact Information of Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy to our Privacy Officer by emailing at

If you are not satisfied with our Privacy Officer’s response to their question or concern you may be able to make a complaint under applicable privacy laws. Our Privacy Officer can provide you with the contact information to make such a complaint.

11. Changes to Privacy Policy

Privacy laws continue to evolve and, as a result, this Policy may be changed by us from time to time at our full discretion without any prior notice or liability to you or any other person. The processing of your personal information by us will be governed by the version of this Policy in effect at that time.

End of Privacy Policy (Last Updated: June 13, 2019).