Last updated: January 9, 2025

This Privacy Policy describes Retreats with Laura and its affiliates including Divinefem Healer (collectively “RWL”, “we”, “us” or “our”) commitment to protecting your privacy when collecting, using, and disclosing your information. RWL offers wellness services (the “Services”) through our website, www.retreatswithlaura.com (the “Website”). This Privacy Policy applies to all RWL Service and Website users (“You”). This Privacy Policy governs your access to the Services, regardless of how you access it. By using our Services, you consent to the collection, transfer, processing, storage, disclosure and other uses of data regarding our users (“User Data”) and materials, content, information, and User Data on our Website (the “Information”), as described in this Privacy Policy.

Herein, “RWL” designates the RWL Website and the information systems that support the Website.

Our Privacy Policy explains what Information we collect through the Website, why we collect it, and how we use that Information. It is our policy to respect the privacy of our Users regarding any Information that we may collect while they are using our Services.

1) Terms of the Policy

a) It is RWL policy to comply with the privacy legislation within our jurisdiction. This Privacy Policy covers all activities subject to the provisions of Canada’s federal and Ontario’s provincial privacy laws, and other international jurisdictions not otherwise specifically addressed by this Policy. The Website and Services are available to be viewed internationally, and we endeavour to ensure compliance with all applicable privacy legislation in your jurisdiction. RWL provides its services to the international markets, and ensures its compliance with all applicable privacy legislation, including but not limited to, the secure storage of user data, disclosing the collection and use of its user data, and only using its users’ data for purposes associated with or ancillary to the Services.

b) The rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. You may contact our Privacy Officer for more information on this Policy at retreatswithlaura@gmail.com.

c) RWL does not knowingly collect personally identifiable information from any person under the age of 18. In the case we discover that an individual under 18 has provided us with personal information, we immediately delete this from our storage systems. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at retreatswithlaura@gmail.com so that we may remove your child’s personal information.

d) In order to help RWL maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the information you provided to RWL.

2) Consent

RWL will always seek your consent before or at the time that we collect, use or disclose your Personal Information, unless required or authorized by law. Your consent may be expressed, implied or given through an authorized representative. By accessing or using our Website and/or App, you consent to the collection, use and disclosure of your personal information as outlined in the Privacy Policy.

If you have consented to a third party to release your information, your information may be collected by RWL from that third party, such as payment or credit card processing. RWL may also utilize the services of third parties and may receive personal information collected by those third parties during the performance of the Services.

You may withdraw part or all of your consent at any time with reasonable written notice, subject to legal, contractual or other restrictions. Withdraw of consent may impact our ability to provide you with the same access to or use of our Services. You may also withdraw all or part of your consent by opting out to receive our promotional push notifications and emails from us. Once you opt out, you may still receive non-promotional emails such as information about your account updates or our ongoing business relations.

All e-mails sent by us will be in compliance with the Canadian Anti-Spam Legislation (“CASL”), including clearly stating who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us. Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.

3) Collection

We may collect personal information when you provide it to us, including your interaction with us and your access and use our Service. We try to limit the collection of personal information to only what is reasonable and necessary to provide our service and to develop, assess, and improve our service. We only collect personal information if non-identifying information is not sufficient for this purpose.

We may collect the following categories of personal information about you:

a) Identifiers, which may include your name, address, email address, telephone number;

b) Commercial information, which may include payment, banking or other financial information;

c) Internet or network activity, which may include your operating system type and version, web server type and version;

d) Mobile device information, which may include your mobile phone number, mobile country code, information about your mobile device screen size, date and time of mobile device use and other mobile device-related information;

e) Geolocation information, which may include geographical information derived from your IP address, MAC address or device GPS;

f) Audio, visual or electronic information, which may include screen-sharing views or any data contained in files uploaded, emailed or otherwise provided by you;

g) Information from third parties (where you have authorized it); and

h) Other information, which may include the contents of your communications with us, whether through email, social media, telephone or otherwise, and inferences we may make from other personal information we collect.

4) Personal Information

a) The personal information RWL collects depends on how you interact with the Website. You can visit our Website without creating an account. In such case, some Information may still be collected, as detailed herein at Section 3 and when you input information, including your name, email address, and any other personal information, to the Website, through our Contact page or otherwise.

b) RWL may collect personal information through the following means:

i) Directly from You/the User;

ii) Through a User Account;

iii) Electronic Devices;

iv) Third Party Sources;

5) Use and Disclosure

Your Personal Information may be used for purposes including but not limited to:

i) As required to provide the Services;

ii) Processing Refunds;

iii) Administering Promotions;

iv) Protecting against fraud or error;

v) Communicating with you to fulfill requests and ensure satisfaction;

vi) Fulfilling the terms of a warranty or agreement; or

vii) Facilitating a refund or reimbursement;

RWL is the sole and exclusive owner of the data it collects from Users and will not sell, share, lease, or otherwise distribute or disclose such data in any way other than as disclosed by this Policy. Personal Information may be collected through multiple pages on the Website.

RWL uses appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information. Such measures will vary depending on the sensitivity, amount, format, nature and storage of the personal information and will involve, as applicable, physical, organizational and electronic security measures, including premises security, restricted file access, technological safeguards including security software and firewalls to prevent unauthorized computer access, and password and security policies. In communicating with us, you should be aware that e-mail is not a fully secure medium.

6) Cookies

To ensure that the Website is optimized for ease of use, we or our service provider(s) may use Cookies to collect standard information about your language preferences, when you visit the Site, your browser type and version, and other similar information. You are not required to accept Cookies from the Website. You can reset your browser to notify you when it has received a Cookie or refuse to accept Cookies. However, if you refuse to accept Cookies, you may limit your viewing and/or not be able to access all features on the Website.

RWL or its hosting providers may collect traffic information and information about your visit in a log file on a server. Log file information may include, but is not limited to, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We or our hosting provider use this information to analyze trends, administer sites, track aggregations of users’ movements, and gather demographic information for aggregate use. IP addresses and other log file information are not connected to personally identifiable information.

RWL may collect geographic location from your mobile device or IP number to determine the nearest cook or shef or suggest specific App shipping offerings.

RWL reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside Websites so as to tailor advertising messages users see while visiting that social media Website. LCBI reserves the right to use these pixels in compliance with the policies of the various social media sites.

This Website is not designed to recognize “Do Not Track” requests from web browsers.

7) Authorized Disclosure and Use

a) RWL discloses Personal Information only to its employees, contractors and affiliated organizations and third parties that need to know that Personal Information to process it on LCBI’ behalf or to provide the Services, and that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations and third parties may be located outside of Canada and/or outside your jurisdiction. By using the Website and/or the Services, you consent to the disclosure of such information to them for purposes including but not limited to:

i) Providing the Services;

ii) Operating the Website;

iii) Sending marketing and promotional communications;

iv) Conducting feedback and User surveys;

b) RWL may also use your Personal Information, specifically your contact information, including but not limited to your name and email address, with your consent for the following purposes:

i) to send you the RWL newsletter;

ii) to inform you of RWL’ contests or surveys and provide associated notices and updates;

iii) to inform you of special offers from RWL and its partners and select third parties and to provide associated notices and updates; or

iv) to inform you of updates to the Website and Services;

c) Your Personal Information may also be used and disclosed:

i) to comply with valid legal proceedings;

ii) to respond to a complaint or dispute;

iii) during an emergency situation where health or safety is at risk;

iv) to protect the rights of LCBI;

v) to prevent fraud or abuse of LCBI or its Users;

vi) to protect the safety of any individual from injury or death;

vii) as required by our professional advisors;

viii) where the personal information is publicly available; or

ix) with your consent.

In such event, only the minimum amount of personal information required to fulfill the contemplated purpose will be disclosed.

d) Collected Information and Cookies may be used in aggregate form to assess how our customers use our Website, so that our partners may also understand how often people use our Services. Your consent will always be sought prior to Cookies being allowed from the Website.

e) When you contact RWL, we may keep a record of your communication to help solve any issues you might be facing and reserve the right to publish it without any way to identify its origin, to help us support other Customers.

f) If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your Personal Information may be transferred as part of that transaction. We will notify you via email and a notice on our Website of any change in control or use of your Personal Information. We will also notify you of choices you may have regarding the Personal Information we are storing which is subject to such change of control.

g) We may share aggregated, non-personally identifiable information publicly and with our partners, such as publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our Service. RWL will never disclose data which may personally identify You, outside the scope of the Services and the Terms of Use and this Privacy Policy, without your prior written consent.

h) You may change or withdraw your consent, or update your Personal Information at any time, subject to legal or contractual obligations and reasonable notice by contacting our Privacy Officer in writing to retreatswithlaura@gmail.com. RWL may terminate any Services to you immediately if you withdraw your consent to the collection of Personal Information. RWL may require that you provide to us sufficient information to identify yourself before we comply with any request regarding Personal Information stored by Divinefem Healer. RWL will use all reasonable efforts to respond to user requests in a timely manner.

8) Retention of Personal Information

a) You may change or update your privacy preferences by sending an email to retreatswithlaura @gmail.com. This includes:

i) Updating your personal information;

ii) Subscribing or unsubscribing to marketing and promotional communications.

b) RWL will retain your information for as long as needed to provide you the Services. Your information may also be retained in anonymized, aggregate form to comply with our contractual obligations to third parties. We use industry-standard encryption and security standards to protect your information. Once your User Account is closed, your Personal Information will be deleted automatically within 30 days. If you wish to cancel your account, you may request the account cancellation by contacting us at retreatswithlaura@gmail.com.

c) RWL may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will endeavour to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In the event that you request information for deletion which has been sold or otherwise transferred in anonymized, aggregate format to a third party, RWL shall endeavour to take such reasonable steps as it determines in its sole discretion are required to ensure the information is deleted by the third party in a timely manner.

d) RWL will make every reasonable effort to respond to a written request relating to your Personal Information within 30 days after receipt of such request.

e) If a specific purpose is stated on the Website for the collection of information from you, the information collected will only be stored and used for that stated purpose. Your information will not be used for any other purpose which is not stated explicitly on the Website.

f) Where RWL desires to transfer your personal information to a third party, we may do so if we first ascertain that the third party is subject to a written agreement requiring that the third party provide at least the same level of privacy protection as RWL and that the third party is acting in compliance with applicable privacy legislation. You may not hold us responsible if a third party to which we transfer such information processes it in a way contrary to any restrictions or representations, unless RWL knew or should have known that the third party would process it in such a contrary way and we have not taken reasonable steps to prevent or stop such processing.

g) RWL will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. We generally assume that information that you give to us is accurate. If information you give to us is inconsistent with other information you give to us or with information that is available in public records or from other sources that RWL is permitted by law or agreement to use, RWL will use reasonable efforts to make sure that the information we process is accurate.

h) RWL may refuse to provide access to information to the extent that disclosure is likely to interfere with the safeguarding of important countervailing public interests, such as national security; defense; or public security. Other reasons for denying or limiting access are:

i) Interference with execution or enforcement of the law, including the prevention, investigation or detection of offenses or the right to a fair trial;

ii) Interference with private causes of action, including the prevention, investigation, or detection of legal claims or the right to a fair trial;

iii) Disclosure of personal information pertaining to other individual(s) where such references cannot be redacted;

iv) Breaching a legal or other professional privilege or obligation;

v) Breaching the necessary confidentiality of future or ongoing negotiations, such as those involving the acquisition of publicly quoted companies;

vi) Prejudicing employee security investigations or grievance proceedings;

vii) Prejudicing the confidentiality that may be necessary for limited periods in connection with employee succession planning and corporate reorganizations;

viii) Prejudicing the confidentiality that may be necessary in connection with monitoring, inspection or regulatory functions connected with sound economic or financial management; or

ix) Other circumstances in which the burden or cost of providing access would be disproportionate or the legitimate rights or interests of others would be violated.

9) Third Party Applications

a) Our Privacy Policy does not apply to services offered by other companies or individuals, including sites that may be linked from our App. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

b) We may share your information with a third party application with your consent, for example for payment processing. RWL presently utilizes the services of third parties for payment processing. We accept no responsibility or liability in respect of any third party. Please refer to the privacy policies published on any third party sites which you may access through our site before submitting personal information to them.

10) Visitor GDPR Rights

If you are visiting this Website from within the European Union (“EU”), you are entitled to certain information and have certain rights under the General Data Protection Regulation of the EU which include the following:

• We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) We decide that the value in retaining the data is outweighed by the costs of retaining it.

• You have the right to request access to your data that we store and the rights to either rectify or erase your personal data.

• You have the right to seek restrictions on the processing of your data.

• You have the right to object to the processing of your data and the right to the portability of your data.

• To the extent that you provided consent to our processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.

We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.

For more information about your rights as a Website visitor from the EU and the GDPR, please see the European Commission Website here:

https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en.

11) Enforcement

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities to resolve any complaints regarding the transfer or storage of Personal Information that we cannot resolve with our Users directly.

12) Security

The security of your Personal Information is important to us. We follow the generally accepted standards held within our industry to protect the information submitted to us, both during transmission and once we receive it. We store our data on internal, external, and encrypted online servers, protected with firewalls, malware protection, and multiple backup points. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot and do not guarantee absolute security. Unless specific contractual arrangements are made with you, RWL may process your Personal Information on a server located outside your jurisdiction.

13) Updates

We reserve the right to modify this Privacy Policy at any time for any reason, effective upon posting an updated version through the Service. The date of the last update will be indicated at the top of this page. If the modifications are significant, we will notify you with commercially reasonable efforts via email or other reasonable means. It is important to regularly review this Privacy Policy, as your continued use of the Service after the date of an updated version constitutes your acceptance of the changes. If you do not agree with the updated Privacy Policy, your sole and exclusive remedy is to cease your access and use of the Service.

14) Privacy Officer

Should you have any questions about this policy, including any complaints, you may contact our Privacy Officer at retreatswithlaura@gmail.com.

15) Changes to This Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit approval. We will post any privacy policy changes on our websites and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep archived versions of this Privacy Policy for your review. By using the Website, you acknowledge and agree to this procedure.

16) Governing Law

This Privacy Policy is governed by the laws of the Province of Ontario and applicable laws of Canada and internationally and these laws apply to the use of the Services by You, notwithstanding your domicile, residency or physical location. The Services are intended for use only in jurisdictions where it may lawfully be offered for use.

17) Enforceability

If any term of this Privacy Policy is deemed invalid or unenforceable for any reason (including, but not limited to the exclusions and limitations set out above), then the invalid or unenforceable provision will be severed from this Privacy Policy and the remaining terms will continue to apply.

18) No Waiver

Failure of RWL to enforce any of the provisions set out in this Privacy Policy or failure to exercise any option to terminate shall not be construed as a waiver of such provisions and shall not affect the validity of this Privacy Policy or any part thereof, or the right thereafter to enforce each and every provision.

19) Agreement to Terms of Policy

By using the Website, the App, and/or providing any information to us, you accept and agree to the collection and use of your personal information for the purposes described hereinabove.