Privacy Policy

Last Modified: December 19th 2023

ARTICLE 1: OUR APPROACH TO PRIVACY
This policy covers any mobile application, product, service and website developed by Contrivity Solutions including LumiGuide, Simple Flashlight, Simple SOS, Simple Morse & Simple Compass. LumiGuide is a mobile application developed by Contrivity Solutions Inc., designed to provide users with a versatile set of features aimed at enhancing personal safety, navigation, and emergency preparedness. The application offers a range of functions, including a flashlight with adjustable brightness, strobe effects, SOS signalling using Morse code, screen light, compass, location sharing, battery optimization, Morse code features, and more.LumiGuide offers both free and paid versions, with additional functionalities and services available to users who subscribe to the paid version. The paid version requires users to create an account, providing information such as name, email address, and cell phone number. Certain features, like SOS records, location services, and emergency contacts, are specifically tailored for the safety and security of users, aligning with the application's commitment to privacy and data protection.This privacy policy outlines how LumiGuide collects, uses, and protects the personal information of its users, ensuring transparency and compliance with relevant privacy laws and regulations, including PIPEDA, GDPR, HIPAA, Saskatchewan, Canadian, European, and American laws.

1.01 Contrivity Solutions Inc. (“we,” “our,” or “us”) is committed to safeguarding your privacy. This policy outlines how we collect, store, process, transfer, share, and use data that identifies or is associated with you (“personal information”) and information regarding our use of cookies and similar technologies through the use of our mobile application Lumiguide (the “Service”).
1.02 We are an application and software development tech company, available via our Website ([www.contrivity.ca]) and email support@contrivity.ca.
1.03 This policy applies to the Service.
1.04 By accessing or using the Service, you acknowledge and consent to the practices described herein.

ARTICLE 2: SUMMARY
2.01
We collect information you provide, voluntarily share, and automatically gather for user experience enhancement.
2.02 Personal information may come from subscribers, other websites we operate, and third parties. Technical information is used for Service operation, optimization, analytics, content promotion, and user experience enhancement. We may contact you with relevant information.
2.03 We do not disclose personal information except as described herein. Published information may be accessed and used by others.
2.04 All information is stored securely. International transfers comply with safeguards. You can exercise your rights by contacting us.
2.05 For detailed terms, read the full Privacy Policy below.

ARTICLE 3: DETAILED TERMS
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
3.01 Information you give to us:
We collect personal information when you submit information directly or correspond with us, including:NameEmail AddressCell Phone NumberLocation Data
Use of Information:Registering to use our Website and subscribing to the ServiceParticipating in discussion boards, forums, competitions, promotions, or surveysReporting problems with our Website or using specific features of the ServiceEnhancing user experience through location-based features
3.02 Information we receive from other sources: Personal information may come from subscribers, other websites, and third parties. This includes:Verification OTP codes sent via email for emergency contacts
Use of Information:Verifying identity and obtaining explicit consent for adding emergency contacts
3.03 Table 1: Outlines categories of personal information, how we use it, and the legal basis for processing.

3.03 Table 1: Categories of Personal Information and Uses
Category of Personal Information / Purpose of Processing / Legal Basis for Processing
- Name / User identification / Consent
- Email Address / Communication / Consent
- Cell Phone Number / Communication / Consent
- Location Data / User experience / Consent  

Personal Information Collected Automatically (Table 2): Categories of automatically collected information, usage, legal basis, and retention periods.

3.03 Table 2: Automatically Collected Information
Category of Information / Purpose of Processing / Legal Basis for Processing / Retention Period
- IP Address / Service optimization, security, and user experience / Legitimate interests / 30 days
- Device Information / Service optimization, troubleshooting, and analytics /Legitimate interests / 30 days
- Usage Information / Analyzing user behavior, improving the Service /Legitimate interests / 30 days
- Cookies and Similar Technologies / Enhancing user experience and monitoring / Consent (can be withdrawn) / Varies

ARTICLE 4: DISCLOSURE OF YOUR PERSONAL INFORMATION
4.01
We do not sell or rent personal information for direct marketing. We may share information with group members, service providers, technical providers, credit reference agencies, payment processors, and third parties in business transactions.
4.02 Personal information may be disclosed in response to lawful requests, legal obligations, or to protect rights and safety.

ARTICLE 5: MARKETING AND ADVERTISING
5.01
From time to time, we may contact you with relevant information about the Service and other products. Most messages will be sent electronically. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.
5.02 If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can also change your marketing preferences at any time by changing your preferences on the bottom of our emails or by following the unsubscribe link at the bottom of our emails.
ARTICLE 6: REFERRAL PROGRAM
6.01
We operate a referral program. Contact details are stored to track the success of our referral service.
6.02 Where you provide us with names and email addresses of such individuals as set out above, you will obtain the prior consent of those individuals and provide them with the information as to how we handle their personal information as described in this privacy policy.
ARTICLE 7: YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
7.01
In accordance with privacy law, you have rights like access, rectification, erasure, restriction, and objection.
7.02 To exercise these rights, contact us at [support@contrivity.ca]. We will respond within 30 days.

ARTICLE 8: COOKIES AND SIMILAR TECHNOLOGIES
8.01
Our Service uses cookies to enhance user experience, monitor, and improve our Website and services.
8.02 We use the following types of cookies:Strictly necessary cookiesAnalytical/performance cookiesFunctionality cookiesTargeting cookies
8.03 Please note that third parties may also use cookies.
8.04 We may partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests.
8.05 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
8.06 Social Media: Our Website includes social media features, such as Facebook Like button and widgets such as the Share button. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted on our site or by a third party, and your interactions with these features are governed by the privacy policy of the company providing it.
ARTICLE 9: USE OF LOCATION SERVICES
9.01
Our Service uses location services to enhance user experience, particularly for maps and location-based features within the app.
9.02 By using our Service, you consent to the collection and processing of your location data for these purposes.
9.03 Location data is utilized for features such as mapping trails, providing location-specific content, and enhancing the overall functionality of the app.
9.04 You have the option to disable location services on your device; however, this may limit the functionality of certain features within the app.
ARTICLE 10: LINKS TO THIRD-PARTY SITES
10.01
The Service may contain links to third-party websites. We are not responsible for their privacy policies.
10.02 Some pages on our Website may use framing techniques. Be aware that you provide personal information to these third parties and not us.
ARTICLE 11: USE OF SERVICES BY MINORS
11.01
The Service is not directed at persons under 16. If a child provides personal information, contact us.
ARTICLE 12: YOUR CANADIAN PRIVACY RIGHTS
12.01
The Personal Information Protection and Electronic Documents Act Schedule 1 Clause 4.9 permits Canadian residents that are users of our Service, that have provided their personal information to us, to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at support@contrivity.ca
ARTICLE 13: NOTICE TO YOU
13.01
If we need to provide you with information about something, we will select the best way to contact you, usually via email or by placing a notice on our Website.
ARTICLE 14: CONTACTING US
14.01
For any questions, comments, or requests regarding this privacy policy, contact our Data Protection Officer, Ben Levesque, at support@contrivity.ca  
ARTICLE 15: CHANGES TO THIS PRIVACY POLICY
15.01
Changes to this privacy policy are effective when posted on this page.