Privacy Statement

Overview – Objectives

This privacy statement outlines how Arbor Memorial Inc. and its affiliates (collectively, “The Company”, “we”, or “us”) collects, uses and discloses personal information. This Privacy Statement applies to any personal information we collect or receive about you, from any source and in any form. Reference to “you” or “your” includes your personal representative and individuals such as family members on whose behalf you are acting when providing us with personal information or otherwise interacting with us about our products and services. In doing so, however, you must have the consent of those other individuals to our collection, use, and disclosure of their personal information in accordance with this Privacy Statement. This Privacy Statement also outlines how to request access to your personal information and how to exercise other rights you may have under applicable laws, and it outlines the choices you have regarding the collection, use and disclosure of your personal information.

 

Personal Information We Collect

The Company collects personal information for the reason for which it was collected or for a use consistent with that purpose. We collect personal information directly from you when you purchase or interact with us about a product or service that we offer or provide (for example, when you email us or contact us through our website or when you enter into certain contests or promotions with us) and we may collect personal information from a third party based on your consent or as otherwise permitted or required by law.

The personal information we collect about you includes but is not limited to:

• Contact information (for example, full name, number, email address, mailing address)
• Identifying information (for example, place and date of birth and social insurance number)
• Information about your family, friends, caregivers or legal representative (for example, name and contact information)
• Medical details (for example, pre-existing health conditions)
• Government ID (for example, licence, social insurance number)
• Proof of executorship (for example, last will and testament, power of attorney)
• Proof of death
• Surveillance (for example, surveillance cameras)
• Payment-related details (for example, billing address and other banking/credit card details)
• Information about the products and services which you have ordered, your interest in obtaining information about Arbor’s products and services (or the products or services of others)
• All documents provided in response to a job posting on our website and/or social networks such as resumes and cover letters, including any personal information that these documents may contain
• To the extent permitted under applicable law, usage information (for example, search terms used on website, pages visited, how many times a page was visited, and interactions with advertising on our website)
   

Why We Collect and How We Use Personal Information

The Company collects and uses personal information for purposes that include, but are not limited to:

• providing Arbor’s products and services to you and to others as directed by you, including making and administering your funeral and including assisting your personal representative, caregivers, family or friends,
• internal business purposes of the Company, developing, obtaining or providing products and/or services relating to contracts for internal business or legal purposes, and to design and execute marketing initiatives,
• informing you (including sending electronic messages) about the Company’s special memorial events, products and services and the products and services of the Company’s partners,
• responding to your questions and inquiries, and administering and improving our customer service, website and other services,
• processing and following up on applications received in response to our job postings on our website or elsewhere, and to communicate with applicants and candidates in this regard
• preparing a funeral notice or obituary and displaying the funeral notice or obituary on the Company’s website,
• providing a funeral notice or obituary to newspapers for print publication,
• creating a memorial-oriented online space comprised of the deceased’s obituary and accompanying photograph(s) for others to share condolences and other content,
• managing and undertaking funeral arrangements and other memorial services,
• advising you about funeral arrangements,
• arranging or administering an annuity or insurance contract for you;
• at your direction, to post and publish your content,
• assisting in the preparation of documentation required in connection with the administration of an individual’s estate, preparing a historic record about you and your family,
• advising your family and friends about counselling and related services, and special memorial events to be held by the Company,
• to enter you into and to administer promotions, contests, sweepstakes, and surveys,
• additional purposes which are required or permitted by law, or that are identified at or before the time that the information is collected, or if already collected used by the Company for different purposes, at or before the time it is used for the additional purposes.
   

Cookies, Website Information and Advertising

To the extent permitted under applicable law, Arbor may use persistent anonymous cookies to collect information about your browsing history on our website. We may use that information to customize your experience on our website and to deliver our advertisements. Where required by law, we will deactivate such tools by default and ask your permission to activate them. You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

From time to time, we collect certain information relating to visits and use of our websites, including but not limited to Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the website, the pages you visit on our website visited, the time spent on each page, and the time and date of each visit. We may share this information once it is anonymized in accordance with applicable law with our affiliates or other third party companies, for example to provide them with an indication of the amount of interest in our website for advertising purposes and to help us make technical improvements.

 

How we Share Personal Information?

If the Company uses the services of another organization that requires access to your personal information, the Company obtains assurances that the third-party will use a level of protection equal to that provided by the Company and will not hold, use or disclose the information for any other purpose except for the purposes discussed in this statement or permitted by law. Some service providers may be located outside of Canada where personal information may be subject to the laws of those jurisdictions. Those laws may require disclosure of your personal information to authorities in that country. For more information about the Company’s affiliates which may have access to your personal information under the Company’s control or policies and practices regarding service providers outside of Canada, contact our Chief Privacy Officer using the contact information in the “Contact Information” section below.

We may also disclose personal information to law enforcement or other government entities to protect our property and/or the safety of our employees, customers, or any other person, enforce or defend our rights, prevent unlawful activity, or where otherwise required or permitted by applicable law.

 

Notification of Collection Purposes and Consent

The Company will typically obtain your consent for the collection, use, or disclosure of your personal information at the time that we collect, and in the case where such information had already been collected for different purposes, prior to using or disclosing it for new purposes, except where permitted or required by law. Depending on the circumstances and the type of information required, consent can be express or implied. The form of consent that we seek, including whether it is express or implied, will largely be determined by assessing the sensitivity of the personal information and the reasonable expectations you might have in the circumstances. You can withdraw or vary your consent at any time. Where feasible or required by applicable law, we will generally accommodate requests to withdraw or vary consent – subject to legal or contractual restrictions. The Company will generally attempt to give effect to any such withdrawal or variation on 30 days’ notice, and the Company will, if it has not already done so, advise you of the implications of the withdrawal or variation.

If you no longer want to receive marketing-related e-mails from us, you may opt-out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Information” section below.

We will endeavour to promptly respond to your opt-out request, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.

 

Access to Personal Information and Accuracy

You may request access to the personal information the Company holds about you by using the contact information in the “Contact Information” section below, and we will provide you with any such personal information to the extent required by applicable laws. We will not charge any costs for you to access your personal information in our records without first providing you with an estimate of the approximate costs, if any. The Company uses reasonable efforts to ensure that your personal information is accurate, complete and up to date as necessary for the purposes for which such information was collected by the Company, however you may ask to correct any information that is incomplete or incorrect. If you successfully demonstrate that the personal information we hold is inaccurate or incomplete, we will amend the personal information as required. When appropriate, the Company will transmit the amended information to any parties to whom the Company sent the original information.

 

Retention Period and Destruction of Information

Subject to our use of certain foreign third-party service providers as discussed above, we will keep your personal information in Canada. The Company will retain your personal information for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law, after which the Company will destroy the personal information or anonymize it to use it for serious and legitimate purposes.

 

Safeguards

The Company has adopted physical, organizational, contractual and technological safeguards designed to help protect your personal information against loss or theft, and unauthorized access, disclosure, copying, use or modification, e.g., limiting access on a "need-to-know" basis, restricted access and passwords, and where appropriate, requiring you to provide identification in any communication with the Company about your personal information to protect your personal information under its control. The Company's staff are made aware, through training programs, of the importance of maintaining confidentiality of your personal information. The Company conducts periodic internal and independent audits of its security safeguards. The Company cannot, however, guarantee that its safeguards will always be effective. A breach of security safeguards can result in such risks as phishing and identity theft. In such cases, we act with an aim to mitigate the risks and to inform you where there is a real risk of significant harm or of serious injury (subject to certain exceptions under applicable law), or as otherwise required by law. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Information” section below.

Privacy-related Comments, Questions, Concerns, or Complaints

If you have any comments, questions, concerns or complaints about your personal information or the Company's privacy practices, please contact the Chief Privacy Officer in writing, including your name and contact information and a brief description of your complaint. The Chief Privacy Officer will investigate your complaint, and will generally respond to you within 30 days of receipt of your complaint (or such other timeline permitted or required by law) with any action proposed to be taken by the Company including any amendment to its privacy policies and practices.

 

Contact Information

All privacy related communications should be directed to the Chief Privacy Officer at cpo@arbormemorial.com or to 2 Jane Street, Toronto, Ontario M6S 4W8 – attention: Chief Privacy Officer.

Updated March 17th, 2023