Foresters Go Privacy Notice and Consent to Collection, Use and Disclosure of Personal Information

This Privacy Notice and Consent to Collection, Use and Disclosure of Personal Information (as amended from time to time, the “Privacy Notice”) describes the policies and procedures on the collection, use and disclosure of personal information obtained through your access to and use of the Foresters Go mobile app and website and services available on them (“Foresters Go”).

Foresters Go is provided by The Independent Order of Foresters and its subsidiaries (“Foresters”, “we”, “us” or “our”). Our international head office is at 789 Don Mills Road, Toronto, Ontario, Canada M3C 1T9. The Independent Order of Foresters is the controller of your personal information. Foresters Go is operated by dacadoo AG, Othmarstrasse 8, 8008 Zurich, Switzerland (“dacadoo”).

Your use of Foresters Go is governed by the Terms of Use and, if applicable, relevant App Store and Google Play Store rules. This Privacy Notice explains how Foresters Go processes your personal information and for what purposes.

The Foresters Go web application may use essential cookies for functionality. For more information on how we use cookies, please read our Cookie Policy.

Lawfulness of processing

Your personal information will be processed by Foresters and Foresters Go as outlined in this Privacy Notice and as permitted or required by applicable law. Depending on which laws apply, this will generally be on the basis of consent or our legitimate business interests. Where processing is on the basis of consent, you can always revoke your consent by contacting us as outlined below.

For Canada/US members: You will be required to agree to this Privacy Notice before using Foresters Go. By accessing or using Foresters Go, you agree to accept and be bound by the current version of this Privacy Notice. If you do not agree to the current version of this Privacy Notice, you are not authorized to continue accessing or using Foresters Go.

For UK members: By accessing or using Foresters Go, you confirm you have read and understood the current version of this Privacy Notice.

We may make changes to this Privacy Notice at any time at our discretion and as required by applicable laws. If we make material changes, we will notify by you by means of a prominent notice.

What is Personal Information

“Personal information” as used throughout this Privacy Notice means any information relating to an identified or identifiable individual. This includes any data that identifies you directly or indirectly, or that could be used to identify, locate, contact or track your behavior or your preferences. For instance, some information may not be personal on its own but may become personal information if associated with other information or if the sum of the information allows us to identify individuals. Personal information may also include special categories of personal information (also known as sensitive information). Special categories of personal information may include details in respect to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (for the purposes of uniquely identifying a natural person), geolocation information, health data and sexual orientation data.

Which Personal Information is Collected

When you create or reconfigure your Foresters Go account, you will be required to provide us with certain personal information such as your name, username, password, personal contact details (address, telephone number, location and e-mail address), membership status with Foresters, age, date of birth, sex at birth, height and weight. This information is used to help us manage and administer Foresters Go and your Foresters Go account.

When you use certain features or services provided by Foresters Go, you may choose to provide Foresters Go with additional personal information including, with your consent, special categories of data (collectively the “Data). It is optional for you to provide this additional information but providing it will enable us to provide you with a more personalized and interactive experience. In particular, we use this Data to provide you with a Foresters Go Health Score. Your Health Score is a number between 0 and 1,000 generated by dacadoo). Additionally, the Data will enable Foresters Go to provide you with various information about your health, wellbeing and similar information that may be of interest to you and to enable you to participate in Challenges (see description of Challenges in the Terms of Use). The provision of Data to calculate your Health Score is optional.

This optional additional personal information may include:

• information which you instruct wearable device operators or mobile app providers to provide to us if you connect your Foresters Go account with a third-party application or device such as a device that tracks and measures your activity level.
• information related to your health, health concerns or family history
• details about your lifestyle and activities (including underlying GPS and geolocation data)
• Information about your Foresters membership activities (such as Granting completion for rewarding purposes) (together with the required personal information, collectively the “Data”).

Where providing certain Data is optional, and you choose not to share personal information, some features of Foresters Go that use such Data may not work for you, or we may not be able to provide the Foresters Go app or be prevented from complying with our legal obligations.

How Your Personal Information is Collected

We collect Data that you provide to us directly, through Foresters.com or MyForesters.com websites, through Foresters Go, or through third party devices or apps you connect with your account. We also collect information about your interactions within Foresters Go (e.g., interactions with coach Aida, and social, workout and goal interactions,) as part of our continuous effort to improve the user experience. If applicable, you may also be asked to provide additional information by our service providers as required. If you are an employee of Foresters you authorize the collection, use and sharing of your Data, as outlined in this Privacy Notice and as maintained by Foresters, for purposes of determining eligibility for, registering for and use of Foresters Go.

How Your Personal Information May Be Used

Your Data may be used for the following purposes and where applicable, in reliance on the following legal bases:

Purposes:

• Special Categories of Personal Data: To calculate your Health Score via the Foresters Go app.
• The provision, management, oversight and general administration of your Foresters Go account.
• To determine your eligibility for Foresters Go and other incentives and rewards.
• To track and monitor usage of the Foresters Go app and website in order to enhance, monitor and measure member engagement to support Foresters fraternal purpose.
• To provide you with the products, services, promotions, newsletters and information you request through Foresters Go, and respond to correspondence, queries or requests that we receive from you.
• Administer your Foresters membership and for research, statistical and data analysis purposes and the development, marketing, and administration of Foresters member benefits.
• Customize and personalize your use of Foresters Go.
• Respond to user inquiries and support requests.
• Contact you with surveys, legal notices and other information that are relevant to your use of Foresters Go, including but not limited to sending communications such as e-mails and reminders.
• Maintain and administer Foresters Go and related incentives and rewards (including those provided by third-party service providers), perform business analyses, and gather insights to improve the quality of our business, Foresters Go and other products and services we offer.
• Improve the content and operation of services and compile statistics for research, analytical and marketing purposes.
• Receive, review and store technical data (including crash reports) retrieved from the devices you are using to access Foresters Go.
• Protect the legal rights, property, safety, and security of Foresters Go, its users, dacadoo and Foresters, employees, directors and agents.
• Enforce our Terms of Use or any other terms and conditions, including the investigation of a potential violation of them.
• Detect, prevent or otherwise address fraud, security or technical issues or other misuse (or for risk management purposes, such as member verification).
• Satisfy any applicable law, regulation, legal process or governmental request.
• In connection with a potential asset or stock acquisition of Foresters, providing reasonable diligence material to a third party or meeting any disclosure obligations as required by law.
• As otherwise described to you at the point of collection or pursuant to your consent, or as required or permitted by applicable law or required or recommended by any government authority (including a privacy regulator or commissioner).

Legal Bases:

• For our legitimate business interest in managing our business including legal, administrative and management purposes, and to ensure the provision of a safe and secure IT system, provided our interest are not overridden by your interest.
• For us to comply with any legal or regulatory obligations. Where applicable law requires us to do so, we will seek your consent to the processing of your Data for direct marketing purposes. You may withdraw this consent at any time.

Your Privacy Rights

Please note that you may have a right to object to the processing of your personal data where that processing is carried out for our legitimate interest (please note that we may not be able to fulfil this request in all instances) or for direct marketing.

Members in Canada/US: When using Foresters Go you consent to the collection, transfer, modification, storage, disclosure and other uses of the Data as described in this Privacy Notice.

Members in Canada/US: You authorize us to de-identify your Data and subsequently to copy, process, use, publicly disclose and distribute the Data in anonymized form for academic and statistical purposes. Such anonymized Data shall no longer be considered as personal information.

Members in Canada/US: We may also use your Data to notify you of products, services or upcoming events and activities relating to Foresters Go or Foresters generally which we think may be of interest to you. If you do not wish to receive such notifications you may switch them off by updating your E-mail Preferences in the My Profile section of MyForesters.

Foresters Go, Foresters and dacadoo will not sell your Data or profile or otherwise make available Data to third parties without the user’s consent, unless as permitted under this Privacy Notice or as otherwise permitted or required by law. We may use the Data to contact users with respect to all matters related to the user’s activity, including but not limited to sending motivational e-mails and reminders. Your use of Foresters Go will not impact your insurance products with Foresters and we will not use the Data for purposes of determining underwriting risk or claims assessment.

As noted in the purposes for processing above, Foresters may rely on your consent to process certain special categories of personal information in connection with the calculation of your Health Score. If we do so, we will provide you with full details of the Data processed and the reasons for the processing. You can withdraw your consent at any time and we will inform you how you can do that. You should be aware that withholding your consent will never have an impact on your employment or engagement with us or otherwise negatively affect you.

We may de-identify your Data and subsequently to copy, process, use, publicly disclose and distribute the Data in anonymized form for academic and statistical purposes. Such anonymized Data shall no longer be considered as personal information.

We may also use your Data to notify you of products, services or upcoming events and activities relating to Foresters Go or Foresters generally which we think may be of interest to you and where required by applicable law, where you have opted-in to receive such communications. You may opt-out of such communications by using the contact information below or by clicking unsubscribe available on the bottom of all Foresters communications.

How Your Personal Information is Protected

Foresters Go uses reasonable industry standards to provide a secure website and mobile application. Foresters Go uses physical, electronic and procedural safeguards to protect your Data, including firewalls, access control, individual passwords and encryption and authentication technology. Foresters Go also takes all other necessary and adequate administrative, organizational, technical, personnel and physical measures to safeguard the same against unauthorized or unlawful processing and use, accidental loss or destruction or damage, theft, disclosure or modification and to ensure its integrity.

We restrict access to your Data to those employees or other parties who need access to such Data in order to provide the Foresters Go services. Data transported over an open network, such as the Internet or email, may be accessible to anybody. We cannot guarantee, and are not responsible for, the confidentiality of any communication or information transmitted via such open networks. When disclosing Data via an open network, you should consider that it is potentially accessible to others, and consequently, may be collected and used by others without your consent. Data may be lost during transmission or may be accessed by unauthorized parties. We do not accept any liability for direct or indirect losses as regards the security of the Data during its transfer via Internet.

International Transfers of Your Personal Information

Foresters Go collects and stores your Data in data centers in Switzerland and the European Union. Your Data may also be collected, stored, processed and transferred in and to Canada. Please note that privacy laws in such jurisdictions may differ from those of your jurisdiction. All data storage and/or transfers are covered under an appropriate legal transfer mechanism to ensure it is protected in line with applicable data protection laws e.g., entering into data transfer agreements with the recipient.

How Data is Shared

The Data you provide to and is accessible via Foresters Go may be shared with other users and/or third parties, including our service providers who assist with Foresters Go operations (e.g. Apple Health for Apple watch companion app). Foresters Go will display the names and profile photo of all registered users. For all other data, you control and decide which Data shall be accessible to other users. You can change the privacy settings of your account at any time to control who will be able to see which Data. The only types of Data that may be shared with other users are the following: Health Score, workouts (including underlying GPS and geolocation data), photos (workout, profile and profile background photos) and achievements gained. Data such as weight, age or blood pressure, are not shared or accessible to other users.

You may choose the following types of sharing options:

• Public: All users registered will be able to see your Health Score, the workouts, photos and achievements.
• Groups: Foresters will assign users to groups for the administration of Foresters Go. For example, all users from a specific Foresters Region may be assigned to a unique group. You will be assigned to groups, which will contain fellow Foresters members with whom you are friends on Foresters Go, and other users with whom you are not yet friends on Foresters Go. If you select the Groups option, all group members, friends or not, will be able to see your Health Score, workouts, photos and achievements.
• Friends: Your friends/connections on Foresters Go will be able to see your Health Score, photos, workouts and achievements.
• None: Only you, as the user of your account, will be able to see your Health Score, photos, workouts and achievements.

According to our default settings, all your Friends will be able to see the above-mentioned Data. You can change the privacy settings of your account at any time after your registration. To change privacy settings within the app please click Setting>Platform>Privacy and Security Settings.

Your personal information may be shared or disclosed by Foresters Go as follows:

• Foresters Go may share Data with service providers under contract with us or dacadoo and who only process your Data as instructed by us. Your Data is transferred securely.
• Foresters Go may share your Data, other than your health data, with Foresters for its reasonable business purposes, including as necessary to administer your Foresters membership and to allow Foresters to provide administrative support in respect of Foresters Go, as well as for research and analysis purposes and the development, marketing, and administration of Foresters member benefits.
• Foresters Go is designed to encourage engagement through various forms of incentives including friendly competition. Voluntary participation in programs including, but not limited to, Challenges or Public Challenges may result in your name, status in the challenge, awards won or other information being shared publicly about your participation in that activity with other Foresters Go users.
• We may disclose your Data to third parties in order to protect the legal rights, safety, and security of Foresters Go and Foresters, employees, directors and producers, and the users of our products and services; enforce our Terms of Use; to prevent fraud or other misuse (or for risk management purposes); and to comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
• If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger, acquisition or business transfer, or in the event of bankruptcy, we may transfer your information to the purchaser(s) or acquirer(s) as part of those transaction(s).
• We may also share your Data with third parties in other circumstances when you consent to such sharing (including when you post information to a public area of Foresters Go, such as a chat room, discussion board, forum, blog, or other community tool) and otherwise as required or permitted by applicable law.
• Personal testimonials of satisfied Foresters Go users may also be displayed on Foresters.com or in e-mail campaigns, newsletters , social media and other marketing communications in addition to other endorsements. With your consent, your testimonial may be posted along with your name.

How Long Your Personal Information is Retained

Your Data on Foresters Go is retained for as long as you have a Foresters Go account. You can deactivate and delete your account at any time by following the instructions provided on MyForesters. For a period of 30 days thereafter, you may recover your account, after which time, your account and all related Data permanently deleted from Foresters Go systems. You acknowledge that any content posted by you and activity or challenge details on Foresters Go cannot be recovered after the deletion of your account. We, or our service providers, will otherwise only retain your Data for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice, or required by applicable laws or regulations.

Your Rights

Depending on where you reside, you may request details of personal information or Data that we hold and/or process about you. You may ask us for a copy of your Data. If you believe that any personal information or Data we are holding on you is incorrect or incomplete, please contact us as soon as possible and we will correct any personal information or Data that is found to be incorrect. Where required or permitted by law, you may request the deletion of your Data or a temporary restriction of processing in certain circumstances, and you have the right to receive your Data in a structured, commonly used and machine-readable format or have your Data transferred to another data controller if technically feasible. Where applicable by law, the right to data portability only applies to information that you have given us and if we are processing information based on your consent.

You may have a right not to be subject to decisions based solely on automated processing (including profiling) which produce legal effects concerning you or similarly significantly affects you.

You may also have the right to lodge a complaint about the processing of your Data with your local data protection authority.

Your rights are subject to limitations under applicable laws and as necessary (a) to satisfy any applicable law, regulation, legal process or governmental request; and (b) in connection with any legal proceedings (including prospective legal proceedings), obtaining legal advice or otherwise establishing exercising or defending legal rights.

In some circumstances exercising some of these rights will mean we are unable to continue providing our services and may therefore result in the cancellation of your Foresters Go account.

Updates to this Privacy Notice

We may revise this Privacy Notice from time to time. The most current version is always available on Foresters Go https://www.foresters.com/en-ca/member-benefits/foresters-go/Privacy. For UK, please see https://www.foresters.com/en-gb/member-benefits/foresters-go/Privacy. The revised Privacy Notice shall become effective from the date of publication on Foresters Go. Should these changes be substantial, we will provide you with notice and, where required by applicable law, obtain your consent.

Contact Information

If you have any questions or concerns about how we process your Data or about our Privacy Notice, or if you wish to withdraw your consent at any time, you may contact us in any of the following ways:

Foresters Chief Privacy Officer
789 Don Mills Road
Toronto, Ontario
Canada M3C 1T9
Email: privacy@foresters.com

Foresters UK Data Protection Officer
Foresters House
2 Cromwell Avenue
Bromley, United Kingdom BR2 9BF
E-mail: data.protection@foresters.co.uk

or

Foresters Go Customer Service
789 Don Mills Road
Toronto, Ontario
Canada M3C 1T9

This Privacy Notice is intended only to address our processing of your Data when using Foresters Go. You can obtain our full privacy policy on the Foresters website (For Canada and US Privacy policy and for UK Privacy policy ).