This Privacy Policy explains how Looniewell Inc. (“Looniewell,” “we,” “us,” “our”) collects, uses, discloses, stores, and protects personal information in connection with the products and/or services we provide, including our website(s), portals, applications, and related services (collectively, the “Services”).

 

This Privacy Policy is intended to comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial legislation.

 

By accessing or using the Services, you acknowledge and consent to the practices described in this Privacy Policy.

 

1) Who We Are

Looniewell Inc. is a consulting firm specializing in Total Rewards solutions (compensation, benefits, and retirement). This Privacy Policy applies only to personal information collected through our Services.

 

Looniewell’s advisory and consulting services may be governed by separate privacy policies or contractual arrangements.

 

2) Key Definitions

• “Personal Information” means information about an identifiable individual, as defined under applicable Canadian privacy laws.

• “Client Organization” means an organization (e.g., your employer or association) that sponsors or provides access to the Services.

• “Vendors” means third parties that provide wellness-related products, services, or offers accessible through the Services.

 

3) What We Collect

We collect Personal Information depending on how you interact with the Services, including the following categories:

 

A. Information you provide directly

• Account and profile information (name, email address, phone number (if provided), username);

• Authentication credentials (stored securely or through a third-party identity provider);

• Eligibility and affiliation attributes (employee/participant identifier, Client Organization name, eligibility status, or similar access attributes;

• Communications and support requests; and

• Feedback and survey responses.

 

B. Information from Client Organization

A Client Organization may provide us with limited information to enable access and administer the Services, such as:

• Name and work contact information;

• Employee or participant identifier;

• Department or location (if applicable); and

• Eligibility and access status.

 

C. Usage and device information (automatic)

• IP address and approximate location;

• Device identifiers and browser type;

• Operating system and language settings;

• Log files and error reports; and

• Pages visited, time stamps, and referral URLs.

 

D. Vendor and offer interactions

• Records of viewed, clicked, or saved offers;

• Referral or redemption indicators;

• Limited confirmation data from Vendors where integrations exist.

 

E. Sensitive information

The Services is not intended to collect medical, diagnostic, or insurance-claim, or other sensitive health information. Please do not submit such information through the Services or support channels.

 

4) How We Use Personal Information

We use personal information for the following purposes:

 

Services delivery and operations

• to create and administer accounts and access;

• to verify eligibility and authenticate users;

• to provide Services features and respond to support requests;

• to monitor, maintain, debug, and improve the Services.

 

Communications

• to send service-related communications;

• to provide security and administrative notices;

• to send promotional or marketing communications only where permitted by law and consistent with your preferences (see Section 6).

 

Analytics and improvement

• to understand usage trends, improve user experience, and develop new features;

• to generate aggregated insights (e.g., feature adoption), including reporting to Client Organizations as described below.

 

Security and compliance

• to protect against fraud, misuse, and security incidents;

• to comply with legal obligations, enforce our Terms of Service, and protect our rights.

 

5) When We Disclose Personal Information

We do not sell Personal Information. We disclose Personal Information only as described below:

 

A. Service providers (processors)

We may share Personal Information with third-party service providers that help us operate the Services, such as:

• cloud hosting and infrastructure providers,

• email delivery providers,

• analytics and logging providers,

• customer support tools,

• security and fraud prevention services.

These service providers are contractually required to safeguard Personal Information and use it only for authorized purposes.

 

B. Client Organizations (sponsors)

We may share limited information with that Client Organization for legitimate administration purposes, such as:

• account/access status (e.g., invitation delivered, activated, deactivated),

• support and operational information needed to manage access,

• aggregated and/or de-identified analytics about Services usage and engagement.

 

We do not share your individual Vendor purchase details or sensitive data with your Client Organization unless:

• you explicitly direct us to do so,

• it is necessary to deliver a specific requested feature (and clearly disclosed), or

• required by law.

We are not responsible for how Client Organizations handle information once lawfully disclosed.

 

C. Vendors

When you interact with Vendors, the Vendors may collect Personal Information directly from you under their own terms and privacy policy. We may disclose limited referral or eligibility information to facilitate the Vendor interaction where applicable and disclosed.

Looniewell does not control Vendor data practices.

 

D. Legal and business disclosures

We may disclose Personal Information:

• to comply with legal obligations;

• to respond to lawful requests;

• to protect the rights, safety, and security of users, the Services, and Looniewell; and

• in connection with a business transaction (e.g., merger, acquisition, financing, reorganization, or sale of assets), subject to appropriate confidentiality protections.

 

6) Preferences, and Electronic Communications

 

Service messages

Service-related messages are necessary for our Services operation and cannot be opted out of.

 

Optional marketing messages

You may opt out of promotional messages at any time using provided unsubscribe mechanisms or by contacting us.

Withdrawal of marketing consent does not affect service communications that are necessary for our Services operation.

 

7) Cookies and Similar Technologies

We use cookies and similar technologies to:

• keep you logged in (where applicable),

• store preferences,

• analyze usage and improve the Services,

• enhance security.

You can manage cookies through your browser settings. Some Services features may not function properly if cookies are disabled.

 

8) Where We Store And Process Your Personal Information

Your Personal Information will be stored and/or processed in Canada where we or our service providers operate. For Québec residents, this means it is possible that your Personal Information could be communicated outside Québec. We hosts Personal Information in Canada, where your access to the Services is facilitated by a Client Organization, they may choose the hosting location that your account may be connected to.

We require service providers to implement appropriate safeguards.

 

9) Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. Safeguards may include access controls, encryption in transit, logging/monitoring, and least-privilege permissions.

Despite safeguards, absolute security cannot be guaranteed.

 

10) Retention

We retain Personal Information only as long as necessary for the purposes described in this Privacy Policy, including:

• service delivery;

• legal and accounting compliance;

• dispute resolution; and

• contract enforcement.

Retention periods may vary based on the type of information and the relationship with your Client Organization. Where appropriate, we de-identify or securely destroy information.

 

11) Your Rights and Choices

Subject to applicable law, you may:

• request access to your Personal Information;

• request correction of inaccurate or incomplete Personal Information;

• withdraw consent (where processing is based on consent);

• request information about how Personal Information is used and disclosed.

 

How to submit a request: contact privacyofficer@looniewell.com. We may need to verify your identity before fulfilling requests.

If you access the Services through a Client Organization, certain requests may need to be coordinated with that organization (e.g., eligibility records maintained by the employer).

 

12) Third-Party Links

The Services may contain links to third-party sites, services or offers, including those provided by Vendors.  These links are provided for convenience only.

Important: Looniewell does not control, endorse, or assume any responsibility for the content, privacy practices, or security of any third-party sites. Your interactions with third parties are solely between you and the third party, and any Personal Information you provide will be governed by the third party’s own privacy policies and terms of service.

We strongly encourage you to review the third party’s privacy policy before providing Personal Information and exercise caution when clicking links or providing information to external sites.

Where personal information is shared with Vendors through the Services (e.g., referral or redemption information), it is limited and only as necessary to facilitate the interaction. Looniewell is not responsible for how Vendors handle such information once shared.

 

13) Children’s Privacy

The Services is intended for use by employees and other authorized participants of Client Organizations and is not directed to individuals under sixteen (16) years of age.

We do not knowingly collect, use, or disclose Personal Information from children under sixteen (16). If we become aware that we have collected Personal Information from a child without appropriate consent, we will take reasonable steps to delete or de-identify such information as soon as practicable.

 

14) Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on the Looniewell website and update the “Last Updated” date above. Material changes may be communicated through the Looniewell website or via email.

Your continued use of the Services after updates means you accept the revised Privacy Policy.

 

15) Contact Information

Looniewell’s Privacy Officer is responsible for compliance with this policy. You may contact us regarding privacy matters at:

Attention: Looniewell Privacy Officer

Mail: Looniewell Inc. – 10520 Yonge Street, Suite 274 - Unit 35B, Richmond Hill, ON L4C 3C7

Email: privacyofficer@looniewell.com  

 

16) Policy Review

This policy will be reviewed at least annually, or upon significant changes occur in applicable laws, regulatory requirements, technology, Looniewell’s business or clients’ needs.

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Last Updated: June 24, 2026