PARK LAWN CORPORATION

PRIVACY POLICY - CANADA

Introduction

Park Lawn Corporation and each of its subsidiaries (collectively, "Park Lawn", “we”, “us”, “our”) are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy explains our privacy practices, as well as the choices you can make about the way your personal information is collected, used and disclosed by Park Lawn. 

Privacy Policy Effective for Canada

It is Park Lawn's policy to comply with the privacy legislation in each of the jurisdictions in which we operate. Sometimes the privacy legislation and/or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of federal and provincial privacy laws in Canada, as applicable. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. For greater certainty, this Privacy Policy does not vary or amend any contractual obligations that may otherwise be specifically set out in an agreement with Park Lawn. 

This Privacy Policy describes how we collect, use, and disclose personal information about the individuals with whom we interact, including those who access or use our websites and other online and mobile services (collectively, the “Services”). 

What Is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than an individual's business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities.

What Personal Information Do We Collect?

Park Lawn is focused on offering funeral, cremation and cemetery services and merchandise. As such, Park Lawn may collect, use, and disclose different types of personal information in respect of the individuals with whom we interact, including:

• contact information, such as name, email and mailing addresses, and phone number;
• payment information, such as your credit card number, expiry date and CVV;
• the content you submit through the Services, such as obituaries, and comments that you may leave on our websites, including any images and video tributes; 
• browsing information, such as information collected through cookies, your IP address, MAC address, or other device identifier, your device type or mobile carrier, standard server log information, the kind of browser or computer you use, pages and content that you visit on our Services, what you click on, likes/dislikes, behaviors, comments, profile data, the province, state and country from which you access the Services, date and time of your visit, and web pages you linked to our Services from; and 
• recruitment and job application information, such as name, address, phone number, education, experience, references, and other information provided in a resume.

How Do We Collect Personal Information? 

We may collect your personal information directly from you when you interact with us. 

We may also collect information related to your visit to our websites, including, for example, the IP address and domain used to access our websites, any page within our websites that is viewed by that IP address, the website you came from to access one of our websites, the amount of time that you visited a particular webpage, the type and version of your browser, and what country you are from. 

In addition, we use technologies in connection with our websites, such as cookies, beacons, tags, and scripts. A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. Subject to jurisdictions where consent is required, the “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, or how to disable cookies altogether. If you reject cookies (after accepting them if applicable), you may not be able to participate in certain activities or receive a promotion tailored to you. We do not control and do not guarantee the effectiveness of browser-based tools for managing cookies. 

We may use Google Analytics and other analytics providers to evaluate use of our websites and other online and mobile services to evaluate user demographics and usages. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.

Park Lawn also uses Meta Pixel to evaluate use of the Services for our internal purposes such as evaluating user demographics and Google ReCaptcha to prevent spam regarding website inquiries. Meta’s services are governed by its own privacy policy and Google’s services are governed by its privacy policy.

Do Not Track (“DNT”): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals and therefore Park Lawn and the Services do not recognize DNT.

Why Do We Collect, Use and Disclose Personal Information? 

Generally

Park Lawn collects, uses and discloses personal information to enable us to manage, maintain, and develop our operations and conduct our business, including, for example:

• to be able to provide our products and services, and otherwise interact with you; 
• to process transactions and fulfill orders;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for products and services; and (ii) work to improve our products and services; 
• to send you promotional and other marketing materials that we think might be of interest to you; 
• to respond to your inquiries, and comply with your requests;
• to verify your identity and authority;
• to consider you for an employment position or to respond to an employment inquiry;
• to analyze and monitor the performance of our websites and apps, and other related purposes (e.g. determine the popularity of certain online content, better understand your online activity, and assists us in improving our online presence);
• to protect the rights and property of Park Lawn or any third party, including: (i) to protect Park Lawn against error, fraud, theft, and damage to our property; and (ii) during emergency situations or where necessary to protect the safety of a person or group of persons;.
• to enable us to comply with, and as permitted by, applicable laws or regulations, including valid legal processes (such as search warrants, subpoenas or court orders); and
• any other reasonable purpose to which you consent.

Web Broadcasting

In addition, in the course of conducting our business, we may broadcast funeral services online, if requested to do so by a client family. All Park Lawn locations are equipped with cameras to be used for web broadcasting services. These cameras are generally in the service area. Where in use, cameras are intended to provide friends and family who are unable to attend a service in-person to be included in the service online. Recorded images are routinely destroyed and not shared with third parties (unless there is suspicion of an unlawful act, in which case they may be used in an investigation and/or turned over to the police or other appropriate government agency or authority). 

This is not meant to suggest that all individuals visiting our facilities or property will in fact be filmed. Rather, it is meant to bring to your attention that such filming and broadcasting may occur and may result in the collection of personal information from you (including your image, likeness or voice). 

Third Party Service Providers

We may disclose your personal information to our contractors, consultants, affiliates, and other parties who require such information to assist us with managing our relationship with you, including: (i) third parties that provide services to us; and (ii) third parties whose services we use to conduct our business, including third parties who may offer us marketing services; information technology-related services (including hosting services), payment processing services, fraud prevention services, data analytics services, human resources and recruitment services, death care merchandise and services, flower delivery services and other tribute memorial gifts and services.

Transactions Involving Park Lawn

Your personal information may be disclosed or transferred to another party during the course of the grant of a security interest in Park Lawn's assets, or the sale of, all or a part of Park Lawn through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, bankruptcy or restructuring, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Links to Third Party Websites

Our websites and this Privacy Policy may contain links to other websites that may be subject to less stringent privacy standards. If you click on a link to such a third-party website, a third party may also place a cookie on your hard drive. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Park Lawn is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information. 

Cross-border Transfer of your Personal Information

We have operations in Canada and the United States and may use third party service providers who may have operations in Canada and the U.S. As a result, your personal information may potentially be: (i) collected, used, processed, transferred, stored and/or disclosed in any province, territory or state in any of the foregoing countries; and (ii) accessible to the law enforcement and national security authorities of those jurisdictions. 

Your Consent Is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so or as otherwise permitted by applicable law. Depending on the circumstances (including the sensitivity of the personal information), your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.  For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements. 

How Is Your Personal Information Protected?

Park Lawn endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. 

Unfortunately, we cannot guarantee complete security: for example, unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of your personal information at any time. Park Lawn is not responsible for circumvention of any safeguards that we maintain. 

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control. 

How Long is your Personal Information Retained?

We endeavour to retain personal information that we collect, access, or process only as long as necessary for the fulfillment of the purposes for which it was collected, unless otherwise authorized or required by law. 

Choice/Opt-Out

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy. 

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes. 

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Additional Privacy Rights

You can ask us whether we have any personal information about you. If we have any of your personal information, you can, subject to applicable law, also ask us: (i) how we use such information; (ii) whether we have disclosed such information; (iii) to see such information; and/or (iv) to dispose of such information.  To do so, please contact our Privacy Officer. Any such request must be in writing.

When making any of the requests described above, we may request specific information from you to enable us to: (i) confirm your identity and your right to make the request; as well as (ii) search for and provide you with the information that you seek. To the extent permitted by law, we may charge you a fee to attend to your request; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer. 

Your rights, as described under this section of our Privacy Policy, are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. Similarly, there are instances where applicable law or regulatory requirements allow or require us to refuse to dispose of your personal information. In the event that we cannot satisfy your request to access or dispose of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns? 

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the federal Office of the Privacy Commissioner of Canada or the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows: 

Park Lawn Corporation

16801 Greenspoint Park Drive

Suite #376

Houston, Texas 77060

Attn: Chief Strategy Officer and General Counsel

or

Park Lawn Corporation

2 St. Clair Ave. E., Suite 705

Toronto, ON M4T 2T5

Attn: Chief Strategy Officer and General Counsel

E-mail: legal@plcorp.com

Revisions to this Privacy Policy

Park Lawn from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website, and we encourage you to refer back to it on a regular basis.   

This Privacy Policy was last updated on February 5, 2024. 

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word "including" is used, it shall mean "including without limitation".

This Privacy Policy does not create or confer upon any individual, any rights, or impose upon Park Lawn any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and any applicable federal, state, and provincial privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.