The words and phrases used in this Policy have the same meaning as in Key Legal Terms of Use.

Key Legal (“Key Legal”, “we”, “us”) uses a number of safeguards to protect the privacy of users of the Key Legal Platform and the confidentiality of their Personal Information including Personal Information (collectively referred to together in this Privacy Policy as “Information”). When discussing Legal Services, Information typically refers to Personal Legal Information (“PLI”), and when discussing Informational Services, Information typically refers to information that is not specifically about you or your legal matter, such as information in questions you would be comfortable asking of an expert during the call-in portion of a radio broadcast on legal-related matters. PLI is not required for Informational services, and we advise you to not to submit PLI in the course of accessing Informational Services.

The agreement between Key Legal and legal professionals providing services through the Key Legal Platform, (Key Legal Legal Professional Services Agreement) and the Terms of Use for the Key Legal Platform explain the services that Key Legal provides to Authorized Legal Professionals and to clients respectively. The agreement between Key Legal and Non-Legal Professional Providers providing services through the Key Legal Platform, explain the services that Key Legal provides to Authorized Non-Legal Professional Providers.

This Privacy Policy (“Policy”) summarizes how Key Legal collects, uses, discloses, retains, disposes of, destroys and protects Information as well as Data (information that does not identify an individual) in the course of providing our services. We are committed to complying with this Policy and with applicable Provincial and Federal privacy legislation.

Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Legal professionals or Authorized Non-Legal professional Providers. Authorized Legal professionals and Authorized Non-Legal professional Providers are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use and retain in the course of providing services through the Key Legal Platform. Please feel free to ask any Authorized Legal professional or Authorized Non-Legal professional Provider to whom you are referred if you have questions about how he or she will treat your Information.

Collecting and using Information

Key Legal collects and uses Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes. For example, we do not record the audio or video portions of interactions between Clients and Authorized Legal professionals and between Clients and Authorized Non-Legal professional Providers through the Key Legal Platform.

As mentioned, Authorized Legal professionals and Authorized Non-Legal professional Providers are responsible for their collection, use, disclosure, retention, destruction and protection of Information. As a result, the following description is an overview only of the use generally made of Information for the purpose of providing services through the Key Legal Platform. A particular Authorized Legal professional or Authorized Non-Legal professional Providers may or may not choose to collect or use Information as described below in connection with a particular interaction with a Client.

Legal Services

Authorized Legal professionals and Authorized Non-Legal professional Providers may collect Information about you or any dependents when you provide it during a Legal Services consultation (e.g., verbally (ie. during a phone call, Zoom meeting) or in texts), by viewing the Information that you have entered or uploaded to the Key Legal Platform and/or by creating or compiling Information in the Key Legal Platform. Information that will be available to Authorized Legal professionals and Authorized Non-Legal professional Providers includes: the details that you provide in your consultation request; information you’ve entered or uploaded to profiles and other records; information created during earlier interactions through the Key Legal Platform with other Authorized Legal professionals and/or Authorized Non-Legal professional Providers; the name, email address, phone number, date of loss, information about your legal matter, and date of birth and province/territory that you provided when you registered. Authorized Legal professionals and Authorized Non-Legal professional Providers use Information to provide you with Legal Services and/or Informational Services and, as with any legal services provider, must comply with the privacy legislation and client record-keeping obligations to which they are subject. Authorized Legal professionals and Authorized Non-Legal professional Providers may create Information or notes about your interaction with them through the Key Legal Platform. They may export or print copies of your Information that they collect.

Informational Services

Authorized Legal professionals and Authorized Non-Legal professional Providers collect and use Information that you provide in the course of obtaining Informational Services, by viewing the information that you have entered or uploaded to the Key Legal Platform and by creating or compiling Information in the Key Legal Platform. The Information that they collect and use includes: the details that you provide in your request for Informational Services and any information that you provided to register to use the Key Legal Platform (name, date of birth and place of residence) to confirm your eligibility to receive Informational Services. Authorized Legal professionals and Authorized Non-Legal professional Providers are bound to comply with privacy legislation applicable to providers of Informational Services.

Provision of the Key Legal Platform

·       We collect and use your Information to register you, create your User Account, authenticate you when you log in and personalize your experience while using the Key Legal Platform. We confirm your eligibility to use the Key Legal Platform for Legal Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.

·       You may choose to enter or upload and store your Information in the Key Legal Platform

·       When seeking Legal Services, you may also choose to enter or upload and store Information about individuals for whom you have the legal authority to make decisions regarding their care and for whom you have created a profile by providing their first and last name, and date of birth (each a "Registered Dependent"). We use their date of birth where applicable and your assertion of their relationship with you to confirm your eligibility to obtain Legal Services for them, and their eligibility to receive Legal Services.

·       We use Information that you enter, or upload, or which is created as part of an interaction with an Authorized Legal professional or Authorized Non-Legal professional Provider to make it available to you when you access your User Account.

·       We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.

·       We may use Information to help us create, develop, operate, deliver, support and improve the Key Legal Platform, its content and advertising provided to you through it (Key Legal’s and third parties’) unless you have decided not to receive such advertising.

Clients eligible for Legal Services:

·       To request Legal Services, you select the subject area of your legal concern and provide us with basic information about your matter, such as the date of loss and a general overview of the issue. We facilitate your disclosure to the Authorized Legal professional or Authorized Non-Legal professional Provider of that information, to determine whether your request is eligible. We do not identify you, or, if applicable, the Registered Dependent for whom you’re seeking the Legal Services. Once the Authorized Legal professional or Authorized Non-Legal professional Provider confirms that your request is eligible, we identify the Authorized Legal professional or Authorized Non-Legal professional Provider to you. The Key Legal Platform presents to the Authorized Legal professional or Authorized Non-Legal professional Provider the Information you provided in your consultation request, your name and, if applicable, the name of the Registered Dependent for whom you’re seeking the consultation. Unless you have elected to withhold access to information held in the Key Legal Platform about you or any Registered Dependent, the Authorized Legal professional or Authorized Non-Legal professional Provider will be able to view it too.

·       We use Information that you enter to provide you with services that you request us to perform on your behalf.

·       We use your Information to call, text or email you to notify you about services that you request. For example, we notify you about the status of your consultation.

·       We may collect location data through the use of GPS technology and your IP address where applicable to services you have requested, e.g., ensuring you are connected to an Authorized Legal professional or Authorized Non-Legal professional Provider that is licensed or authorized to provide such services in the jurisdiction where you are located. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.

Clients eligible for Informational Services:

·       When you request Informational Services, you select any topics for which you are seeking education. On your behalf, we present the information that you provide to an Authorized Legal professional or Authorized Non-Legal professional Provider to determine whether your request is eligible for Informational Services. We do not identify you. Once the Authorized Legal professional or Authorized Non-Legal professional Provider confirms that your request is eligible, we identify the Authorized Legal professional or Authorized Non-Legal professional Provider to you. The Key Legal Platform presents to the Authorized Legal professional or Authorized Non-Legal professional Providers the Information you provided in your request for Informational Services and your name.

·       We use your Information to call, text or email you to notify you about services that you request, for example, about the status of your request for Informational Services.

·       We may collect location data through the use of GPS technology and your IP address to support you in receiving services, e.g., ensuring you are connected to an Authorized Legal professional or Authorized Non-Legal professional Provider who is authorized to provide such services in the jurisdiction where you are located. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.

Communicating with you

·       Updates and marketing. From time to time, we may send you service announcements, including policy updates and updates to our Terms of Use and software and keep you posted on our latest products and any upcoming events that may be of interest to you or apply to you. You may opt-out of receiving non-essential communications by contacting us at: feedback@keylegal.ca. Service announcements including updates to our policies and Terms of Use and software are not considered non-essential communications.  For clarity, for every new consultation you request through Key Legal, you agree to the Terms of Use as posted on our website at the time of your booking, regardless of whether or not you received a communication from us regarding updates to our Terms of Use.

·       Customer support. If you email, call, write to us or complete a ‘contact us’ form on the Key Legal Platform, we will collect the name and contact information that you provide to us and will use it to respond to you.

We only permit our Personnel to access Information to the extent necessary to perform their designated functions. We require them to protect the Information and maintain its confidentiality by complying with our policies, procedures and applicable law.

Disclosing Information

We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Legal professionals or Authorized Non-Legal professional Providers, and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Key Legal’s legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person. We may use or disclose your email address, but never PLI, information to market a product or service, either directly, or through a service provider or partner that performs services on our behalf.

We may disclose Information for the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.

Retaining and disposing of Information

Unless we otherwise give you notice, we will retain your Information on the Key Legal Platform on your behalf until such times as you or we terminate your User Account or Profile. On termination, you will have an opportunity to print or make copies of your Information subject to the following. To ensure that Authorized Legal professionals and Authorized Non-Legal professional Providers may exercise any authority they have to withhold Information they compile in connection with Legal Services from clients under the law, you will be required to request any access you would like to notes made by an Authorized Legal professional or an Authorized Non-Legal professional Provider about your consultation from the Authorized Legal professional or Authorized Non-Legal professional Provider. Key Legal is not the custodian of Information held on the Key Legal Platform; rather it holds Information on behalf of Clients or Authorized Legal professionals and Authorized Non-Legal professional Providers. On termination of your User Account, once you have been given the opportunity to print or make copies of your Information, we will delete the Information associated with your User Account, except Information that an Authorized Legal professional or Authorized Non-Legal professional Provider advises us he or she requires in connection with a consultation or Informational Services the Authorized Legal professional or Authorized Non-Legal professional Provider provided. In such circumstances, Key Legal will destroy the Information when the Authorized Legal professional or Authorized Non-Legal professional Provider has obtained a copy or terminates his/her account with Key Legal.

Accessing and correcting Information

Legal Services

You can access your Information or that of your Registered Dependents to check that it is accurate, complete, and up to date by contacting help@keylegal.ca.

You may update and edit any of your Information except Information an Authorized Legal professional or Authorized Non-Legal professional Provider has viewed or created Information during a Legal Services consultation when you log in to your User Account. Contact the Authorized Legal professional or Authorized Non-Legal professional Provider who provided the Legal Services to access or request the correction of Information in their notes on the Key Legal Platform or that they hold in their records.

Informational Services

You can access Information you provided in your request(s) for Informational Services by emailing help@keylegal.ca.

Your choices

The Key Legal Platform offers you functionality and choices for protecting your privacy which include:

·       You may enable two-factor authentication on your account to help ensure that only you can access your account. If you do, in addition to entering your password to log in to your account to access the Key Legal Platform, we will send a code to your mobile number, which you will need to enter. This added security prevents anyone else from accessing your Key Legal account unless they have access to your log in information and your mobile phone.

·       You may choose whether to use audio, chat, or video for interactions with Authorized Legal professionals and Authorized Non-Legal professional Providers.

·       When seeking Legal Services, you may withhold Information, e.g., consultation information and records from Authorized Legal professionals and/or Authorized Non-Legal professional Providers. Please be aware that Authorized Legal professionals and Authorized Non-Legal professional Providers may be unable to provide you with Legal Services as a result. They will advise you of the implications of your choice.

·       When seeking Informational Services, any previous Information collected e.g., consultation information and records, will not be accessible by the Authorized Legal professional or Authorized Non-Legal professional Provider providing the services unless you specifically elect to provide access.

·       You may choose whether to receive communications by email, call or SMS.

·       Please contact us directly at help@keylegal.ca for assistance with using the privacy functionality or with any questions about using the Key Legal Platform. Additionally, you may contact us at any time to: stop receiving e-mails or other correspondence from us, seek assistance with viewing and correcting Information, and close your User Account. To protect privacy, we may request information to verify your identity when you contact us.

Safeguarding Information

Key Legal takes the security of your information seriously. We store your information in electronic format, using computer systems with restricted access and housed in facilities using security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Key Legal Personnel are obligated to protect Information by adhering to our policies, practices and applicable laws.

You also play an important role in protecting your privacy and the confidentiality of your Information. For example:

·       Create a strong and unique password for your User Account, and update it periodically.

·       Do not share your User Account or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.

·       Log out of your User Account once you are finished using it, especially if you share your Device with anyone else.

·       Have a strong and unique password on your Device, too.

·       Choose a quiet, private location from which to receive services from Authorized Legal professionals and Authorized Non-Legal professional Providers.

Collecting, using and sharing Data

Key Legal de-identifies Information on behalf of Authorized Legal professionals and Authorized Non-Legal professional Providers. Under their agreement with Key Legal, Authorized Legal professionals and Authorized Non-Legal professional Providers permit Key Legal to collect and use the resulting de-identified data for purposes that include: quality control activities designed to ensure use of the Key Legal Platform in compliance with the Key Legal Legal professional Services Agreement, Authorized Non-Legal professional Provider Agreements,  and the Terms of Use; improving the Key Legal Platform and more generally, the use of client-initiated legal services (through an understanding of usage and utilization patterns by Clients and Authorized Legal professionals and Authorized Non-Legal professional Providers); conducting academic research and designing surveys (to be posted and completed at the discretion of Users). We will not use Data to re-identify individuals.

Cookies and similar technologies

The Key Legal Platform, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. We use these technologies to better understand User behaviour, analyze trends, administer, personalize and improve the experience of using the Key Legal Platform. You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, the Key Legal Platform might not function correctly. At times, we may use third parties such as ad exchanges and data companies to serve our advertisements on the Key Legal Platform. These companies may also use cookies and other technologies to report certain information about your visits to the Key Legal Platform and other websites (such as web pages you visit from and your response to ads on the Key Legal Platform) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Key Legal Platform. By using the Key Legal Platform and not turning off cookies, you are consenting to their use for the purposes described in this Policy. To learn more about advertising on electronic sites and opting-out of receiving ads, you can visit the Digital Advertising Alliance website at www.aboutads.info/choices/ or the Digital Advertising Alliance of Canada website at www.youradchoices.ca/choices.

Links and third party websites and applications

The Key Legal Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.

Policy changes

We publish the current version of our Policy at www.keylegal.ca/privacy-policy/. We reserve the right to amend our Policy at any time. Check back often to ensure you are aware of our current practices for collecting, using, disclosing, retaining, destroying and protecting Information.

Contact Us

If you have any questions, concerns or suggestions about our privacy practices, please contact us at: help@keylegal.ca.  Please include your name and contact information if you’d like us to respond to you.

Definitions

·       “Authorized Legal professional” means a legal professional who is registered to practice law in a Province or Territory of Canada, meets Key Legal’s other criteria, and is permitted to provide Legal Services and/or Informational Services through the Key Legal Platform.

·       “Authorized Non-Legal professional Provider” means an independent, regulated legal professional (such as a paralegal or immigration consultant) registered to provide legal services within their scope of practice, in accordance with their regulatory body, in a Province or Territory of Canada, meets Key Legal’s other criteria, and is permitted to provide Legal Services and/or Informational Services through the Key Legal Platform.

·       “Client” means an individual who has requested a consultation in accordance with our Terms of Use is thereby eligible to receive Legal Services and/or Informational Services through the Key Legal Platform.