Privacy Policy

Effective Date: September 5, 2026
Last Updated: September 5, 2026

1. INTRODUCTION

1.1 Commitment to Privacy

Clear Life Concepts Inc. (“Clear Life Concepts“, “we“, “us“, or “our“) respects your privacy and is committed to protecting personal information collected through our website, software platform, applications, and related services (collectively, the “Platform“).

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you:

• access or use the Platform;
• create an account;
• subscribe to our services;
• communicate with us;
• interact with our website;
• use our products and services.

1.2 Scope of This Policy

This Privacy Policy applies to:

• individual users;
• insurance advisors;
• agencies;
• firms;
• managing general agencies (MGAs);
• carriers;
• enterprise customers;
• administrators;
• website visitors;
• other individuals who interact with Clear Life Concepts.

1.3 Relationship to Terms of Service

This Privacy Policy forms part of the Clear Life Concepts Terms of Service Agreement.

By accessing or using the Platform, you acknowledge that you have reviewed and understood this Privacy Policy.

2. PRIVACY FRAMEWORK AND APPLICABLE LAWS

2.1 Canadian Privacy Compliance

Clear Life Concepts is committed to complying with applicable Canadian privacy legislation, including:

• the Personal Information Protection and Electronic Documents Act (“PIPEDA“);
• applicable provincial privacy legislation;
• other privacy requirements applicable to our operations.

2.2 Privacy Principles

Clear Life Concepts follows privacy principles including:

• accountability;
• transparency;
• meaningful consent;
• limiting collection;
• limiting use and disclosure;
• accuracy;
• safeguards;
• retention management;
• individual access rights.

3. DEFINITIONS

For purposes of this Privacy Policy:

3.1 “Personal Information”

Means information about an identifiable individual, as defined under applicable privacy laws.

Examples include:

• name;
• email address;
• contact information;
• account information;
• payment information;
• usage information;
• client information uploaded by Users.

3.2 “User”

Means an individual or organization accessing or using the Platform.

3.3 “Customer Data”

Means information uploaded, submitted, stored, or processed by Users through the Platform.

3.4 “Personal Information Controller”

Means the organization responsible for determining the purposes and means of collecting and using personal information.

3.5 “Service Provider”

Means a third party that processes information on behalf of Clear Life Concepts.

4. INFORMATION WE COLLECT

Clear Life Concepts collects information necessary to operate, maintain, improve, and secure the Platform.

The types of information collected depend on how you interact with us.

5. INFORMATION PROVIDED DIRECTLY BY USERS

5.1 Account Information

When creating an Account, we may collect:

• full name;
• business name;
• email address;
• telephone number;
• job title;
• professional information;
• account credentials;
• subscription details.

5.2 Billing Information

When purchasing a Subscription, we may collect:

• billing contact information;
• transaction information;
• Subscription plan;
• payment status;
• invoice information.

Payment card information is processed by third-party payment providers and is not stored directly by Clear Life Concepts.

5.3 Customer Data Uploaded to the Platform

Users may upload information through the Platform, including:

• client-related information;
• insurance planning information;
• documents;
• spreadsheets;
• images;
• logos;
• presentation materials;
• notes;
• reports.

Users are responsible for ensuring they have appropriate authority and consent to upload such information.

6. INFORMATION COLLECTED AUTOMATICALLY

When you use the Platform, we may automatically collect technical information, including:

• IP address;
• browser type;
• operating system;
• device information;
• login activity;
• usage activity;
• feature interactions;
• error reports;
• performance information.

This information helps us:

• maintain security;
• troubleshoot issues;
• improve performance;
• understand Platform usage.

7. WEBSITE INFORMATION

When you visit our website, we may collect:

• contact form submissions;
• newsletter preferences;
• inquiry information;
• communication history;
• website usage information.

8. HOW WE USE PERSONAL INFORMATION

Clear Life Concepts may use personal information for purposes including:

8.1 Providing the Platform

Including:

• creating accounts;
• authenticating users;
• providing access;
• processing subscriptions;
• delivering services.

8.2 Customer Support

Including:

• responding to questions;
• troubleshooting;
• assisting users;
• resolving technical issues.

8.3 Billing and Payments

Including:

• processing payments;
• issuing invoices;
• managing subscriptions;
• preventing fraud.

8.4 Platform Improvement

Including:

• improving functionality;
• developing features;
• analyzing usage trends;
• improving user experience.

8.5 Security

Including:

• detecting unauthorized access;
• preventing fraud;
• protecting Platform integrity.

8.6 Communications

Including:

• service notices;
• security notifications;
• product updates;
• marketing communications where consent has been provided.

9. CUSTOMER DATA AND INSURANCE CLIENT INFORMATION

9.1 Customer Data Ownership

Clear Life Concepts recognizes that Users and Enterprise Customers retain ownership of Customer Data submitted through the Platform.

Customer Data may include information relating to:

• advisors;
• organizations;
• insurance clients;
• prospective clients;
• business relationships;
• insurance planning activities.

Clear Life Concepts processes Customer Data only as necessary to provide, maintain, secure, and improve the Platform.

9.2 User Responsibility for Client Information

Users are responsible for ensuring that they have the legal authority to collect, use, and upload any personal information submitted through the Platform.

Before uploading client information, Users must ensure they have:

• obtained appropriate client consent where required;
• provided required privacy disclosures;
• complied with applicable privacy legislation;
• complied with professional and regulatory obligations.

Clear Life Concepts does not determine whether a User has obtained appropriate authorization from its clients.

9.3 Clear Life Concepts as Service Provider

In relation to Customer Data uploaded by Users, Clear Life Concepts generally acts as a service provider processing information on behalf of the User or Enterprise Customer.

The User or Enterprise Customer remains responsible for determining:

• the purpose for collecting client information;
• the legal basis for collecting information;
• appropriate client disclosures;
• regulatory obligations.

9.4 Enterprise Customer Responsibilities

Enterprise Customers are responsible for:

• ensuring authorized collection and use of employee and client information;
• managing User permissions;
• establishing appropriate privacy practices;
• ensuring compliance with applicable privacy requirements.

10. CONSENT

10.1 Meaningful Consent

Clear Life Concepts seeks meaningful consent before collecting, using, or disclosing personal information where required by applicable law.

Consent may be obtained through:

• Account creation;
• acceptance of this Privacy Policy;
• subscription purchase;
• website forms;
• communication preferences;
• other electronic methods.

10.2 Withdrawal of Consent

Where permitted by law, you may withdraw consent for certain uses of personal information.

Requests to withdraw consent may be sent to:

Email: legal@clearlifeconcepts.ca

Please note that withdrawal of consent may affect our ability to:

• provide certain Platform functionality;
• maintain your Account;
• process subscriptions;
• provide requested services.

10.3 Legal and Business Exceptions

Clear Life Concepts may collect, use, or disclose personal information without consent where permitted or required by law, including for:

• legal compliance;
• fraud prevention;
• security purposes;
• enforcement of agreements;
• protection of rights and property.

11. HOW WE DISCLOSE PERSONAL INFORMATION

Clear Life Concepts does not sell personal information.

We may disclose personal information in limited circumstances, including:

11.1 Service Providers

We may share information with trusted third-party providers that assist us with:

• hosting;
• payment processing;
• communications;
• security;
• infrastructure;
• technical operations.

These providers are permitted to process information only as necessary to provide their services.

11.2 Corporate Transactions

Personal information may be disclosed as part of:

• a merger;
• acquisition;
• financing;
• restructuring;
• sale of assets.

Where appropriate, reasonable safeguards will be implemented.

11.3 Legal Requirements

We may disclose information where required by:

• law;
• court order;
• regulatory authority;
• governmental request.

11.4 Protection of Rights

We may disclose information where reasonably necessary to:

• enforce agreements;
• protect users;
• investigate fraud;
• prevent security threats;
• protect our rights.

12. THIRD-PARTY SERVICE PROVIDERS

Clear Life Concepts relies on certain third-party providers to operate the Platform.

These providers may process personal information according to their own privacy practices.

Current providers may include:

12.1 Microsoft Azure

Clear Life Concepts uses Microsoft Azure infrastructure for Platform hosting and data storage.

Platform data is hosted using Microsoft Azure infrastructure located in Canada.

Microsoft may process information according to its applicable service terms and privacy commitments.

12.2 Stripe

Clear Life Concepts uses Stripe for payment processing.

Stripe may process:

• payment information;
• billing details;
• transaction information.

Clear Life Concepts does not store complete payment card information.

12.3 Twilio

Clear Life Concepts may use Twilio for communication-related services, including certain messaging or notification functionality.

Twilio may process information necessary to provide those services.

12.4 Third-Party Websites and Services

The Platform may reference or integrate with third-party services.

Clear Life Concepts is not responsible for:

• third-party privacy practices;
• third-party security measures;
• third-party content;
• third-party policies.

Users should review applicable third-party privacy policies.

13. INTERNATIONAL DATA PROCESSING

13.1 Canadian Hosting

Clear Life Concepts primarily hosts Platform data using Microsoft Azure Canada infrastructure.

13.2 Service Provider Processing

Certain service providers may process information outside Canada as part of providing their services.

Where information is processed outside Canada:

• applicable privacy protections continue to apply;
• service providers may be subject to the laws of their operating jurisdictions;
• appropriate contractual and security measures are considered.

13.3 Cross-Border Disclosure

You acknowledge that use of third-party technology providers may involve limited cross-border processing necessary to operate the Platform.

14. SECURITY SAFEGUARDS

14.1 Security Commitment

Clear Life Concepts implements reasonable administrative, technical, and organizational safeguards designed to protect personal information.

Safeguards may include:

• access controls;
• authentication requirements;
• secure hosting infrastructure;
• monitoring;
• internal security procedures;
• employee confidentiality obligations.

14.2 No Absolute Security Guarantee

Although Clear Life Concepts takes reasonable steps to protect information, no electronic system is completely secure.

Clear Life Concepts cannot guarantee that:

• unauthorized access will never occur;
• security measures cannot be bypassed;
• information will never be compromised.

14.3 User Security Responsibilities

Users are responsible for:

• maintaining secure passwords;
• protecting Account credentials;
• limiting access to authorized persons;
• using secure devices;
• promptly reporting suspected unauthorized activity.

15. DATA RETENTION

15.1 Retention Principles

Clear Life Concepts retains personal information only as long as reasonably necessary for:

• providing services;
• maintaining Accounts;
• fulfilling contractual obligations;
• meeting legal requirements;
• resolving disputes;
• enforcing agreements.

15.2 Account Data Retention

Following cancellation or termination:

• Customer Data may be retained for up to six (6) months;
• access may be restricted;
• information may be permanently deleted after the retention period.

15.3 Legal Retention Requirements

Certain information may be retained longer where required for:

• tax obligations;
• accounting purposes;
• legal claims;
• regulatory requirements;
• security investigations.

16. INDIVIDUAL PRIVACY RIGHTS

16.1 Access to Personal Information

Subject to applicable privacy laws, individuals may request access to personal information held by Clear Life Concepts.

An access request may include a request to:

• confirm whether we hold personal information about you;
• provide access to personal information;
• explain how information is used;
• explain how information has been disclosed where applicable.

Requests should be submitted to:

Email: legal@clearlifeconcepts.ca

16.2 Correction of Personal Information

Clear Life Concepts seeks to maintain accurate and complete personal information.

You may request correction of personal information if you believe information is:

• inaccurate;
• incomplete;
• outdated.

Where appropriate, we will update or correct information.

16.3 Account Information Updates

Users may update certain Account information directly through the Platform.

If information cannot be updated through the Platform, Users may contact:

Email: info@clearlifeconcepts.ca

16.4 Requests Relating to Customer Data

Where Clear Life Concepts processes Customer Data on behalf of an Enterprise Customer or User, requests relating to that information may need to be directed to the applicable User or Enterprise Customer.

This may include requests involving:

• insurance client information;
• employee information;
• organization-controlled data.

Clear Life Concepts will provide reasonable assistance where appropriate.

17. PRIVACY REQUEST PROCESS

17.1 Submitting a Request

Privacy requests should include sufficient information to allow us to:

• identify the requester;
• understand the request;
• locate relevant information;
• respond appropriately.

Requests may be submitted to:

Privacy Contact:
Clear Life Concepts Inc.
St. Jacobs, Ontario
N0B 2N0
Canada

Email:

legal@clearlifeconcepts.ca

17.2 Identity Verification

To protect personal information, Clear Life Concepts may require verification of identity before processing a request.

Verification may include:

• confirmation of Account information;
• additional identifying information;
• other reasonable verification steps.

17.3 Response Timeline

Clear Life Concepts will respond to privacy requests within the timelines required by applicable privacy legislation.

Where additional time is required, we may provide notice explaining the reason for the extension.

17.4 Reasonable Limitations

In certain circumstances, Clear Life Concepts may be unable to provide access or fulfill a request where permitted or required by law, including where:

• disclosure would reveal another individual’s personal information;
• disclosure is prohibited by law;
• information is protected by legal privilege;
• information relates to confidential business information.

18. MARKETING COMMUNICATIONS

18.1 Product and Service Communications

Clear Life Concepts may send communications relating to:

• Platform updates;
• security notifications;
• account information;
• billing;
• service announcements.

These communications are necessary for operating the Platform and cannot always be disabled.

18.2 Marketing Communications

With appropriate consent, Clear Life Concepts may send marketing communications regarding:

• new features;
• educational content;
• product announcements;
• events;
• company updates.

18.3 Managing Preferences

You may manage marketing preferences through:

• Account settings;
• unsubscribe options included in communications;
• contacting Clear Life Concepts.

18.4 Withdrawal of Marketing Consent

You may withdraw consent for marketing communications at any time.

Withdrawal of marketing consent does not affect:

• contractual communications;
• security notifications;
• billing notices;
• service-related communications.

19. COOKIES AND TRACKING TECHNOLOGIES

19.1 Use of Cookies

Clear Life Concepts may use cookies and similar technologies to improve Platform functionality and user experience.

Cookies are small data files stored on your device that help recognize your browser or remember preferences.

19.2 Types of Cookies

Cookies may be used for purposes including:

Essential Cookies

Required for:

• account authentication;
• security;
• Platform functionality.

These cookies may not be disabled without affecting Platform operation.

Functional Cookies

Used to:

• remember preferences;
• improve usability;
• personalize experiences.

Analytics Cookies

Used to understand:

• Platform usage;
• performance;
• feature engagement.

Marketing Cookies

Where applicable and with consent, may be used to:

• measure marketing effectiveness;
• understand website engagement.

19.3 Managing Cookies

You may control cookies through:

• browser settings;
• device settings;
• available Platform preferences.

Disabling cookies may affect Platform functionality.

19.4 Third-Party Analytics

Clear Life Concepts may use third-party analytics providers in the future to help understand website and Platform usage.

Such providers may collect information according to their own privacy policies.

20. CHILDREN’S PRIVACY

20.1 Age Requirement

The Platform is intended for individuals who are eighteen (18) years of age or older.

Clear Life Concepts does not knowingly collect personal information from children under eighteen (18).

20.2 Removal of Information

If we become aware that personal information has been collected from an individual under eighteen without appropriate authorization, we may take reasonable steps to remove that information.

21. PRIVACY AND SECURITY INCIDENTS

21.1 Incident Response

Clear Life Concepts maintains procedures designed to respond to privacy and security incidents.

If a security incident involving personal information occurs, we may:

• investigate the incident;
• contain and remediate risks;
• assess notification obligations;
• notify affected parties where required by law.

21.2 Notification

Where required under applicable privacy legislation, Clear Life Concepts will provide appropriate notifications to:

• affected individuals;
• regulatory authorities;
• other relevant parties.

21.3 User Responsibilities

Users are responsible for notifying their own clients or affected individuals where they act as the organization responsible for Customer Data.

22. EMPLOYEE AND REPRESENTATIVE ACCESS

22.1 Authorized Access Only

Clear Life Concepts limits access to personal information to individuals who require access to perform legitimate business functions.

Such individuals may include:

• employees;
• contractors;
• service providers;
• technical personnel.

22.2 Confidentiality Obligations

Individuals with access to personal information are required to maintain confidentiality and use information only for authorized purposes.

23. PRIVACY COMPLAINTS

23.1 Contacting Clear Life Concepts

If you have concerns about our privacy practices, please contact:

Clear Life Concepts Inc.
St. Jacobs, Ontario
N0B 2N0
Canada

Email:

legal@clearlifeconcepts.ca

23.2 Complaint Review

Clear Life Concepts will:

• review privacy concerns;
• investigate where appropriate;
• respond within a reasonable timeframe;
• take corrective action where necessary.

23.3 Regulatory Complaints

If you are not satisfied with our response, you may have the right to submit a complaint to the applicable privacy regulator, including:

Office of the Privacy Commissioner of Canada

or the applicable provincial privacy authority.

24. CHANGES TO THIS PRIVACY POLICY

24.1 Policy Updates

Clear Life Concepts may update this Privacy Policy from time to time to reflect:

• changes in our services;
• changes in technology;
• changes in legal requirements;
• improvements to privacy practices.

24.2 Notice of Material Changes

Where changes are material, Clear Life Concepts may provide notice through:

• email;
• Platform notifications;
• website announcements.

24.3 Continued Use

Your continued use of the Platform after an updated Privacy Policy becomes effective indicates acceptance of the revised Privacy Policy.

25. CONTACT INFORMATION

For questions, requests, or concerns regarding this Privacy Policy, contact:

Clear Life Concepts Inc.
St. Jacobs, Ontario
N0B 2N0
Canada

General Support:

info@clearlifeconcepts.ca

Privacy and Legal Notices:

legal@clearlifeconcepts.ca

END OF PRIVACY POLICY

Clear Life Concepts Inc.

Effective Date: [Insert Date]

Last Updated: [Insert Date]