Last Updated: October 8th, 2014
1. Customer Privacy Policy
Attune Aging Strategies and Solutions Inc. (“Attune”) knows that you care about how your Personal Information (see definition in paragraph 3) is used and shared. This policy describes how we treat your information. We are committed to the important goal of protecting your privacy and personally identifiable information. This Privacy Policyis applicable to any and all services provided on attuneactiveaging.com or attuneactiveaging.ca (the “Website Service”) and any other domain name that may be operated and/or owned by Attune. By using or accessing the Website Service, you agree to the terms of this Privacy Policy.
2. Our Commitment to Privacy
Attune is committed to controlling the collection, use and disclosure of the Personal Information (see definition in paragraph 3) provided by its customers.
3. What is Personal Information?
“Personal Information” is personally identifiable information such as your name, residential address and e-mail address and includes information about your product and service inquiries and usage of the Website Service, your payment method, your credit card information.
Personal Information is collected by Attune only when you specifically and knowingly choose to provide it to us such as when you provide your credit card information to purchase a product through the Website Service or write an email to us containing Personal Information.
Publicly available information, such as a public directory listing of your name, address, telephone number and electronic address, is not considered Personal Information.
4. Collection and Use of Personal Information
Attune collects and uses your Personal Information solely for the purpose of processing your purchase of products or services via the Website Service and in order to respond to your questions concerning Attune, our products and services.
With your prior consent we will use your Personal Information to send you emails concerning updates to the Website Service, information on new products and services, our marketing campaign materials, about promotional offers, free materials, event invitations, and our newsletter. You always have the option, however, to tell us not toshare your Personal Information or to exclude you from offers for other products or services or to remove you from our mailing list.
Unless you provide prior and specific authorization to release your Personal Information, or release is required or permitted by law, Attune will not sell, lease or trade your Personal Information to other third parties.
Anonymous or “non-personal” information gathered by Attune through our Website Service may be used for technical, research and analytical purposes. Information collected through surveys, existing files and public archives may be used by Attune to analyze our markets and to develop or enhance service offerings.
We will seek your prior consent to the collection, use and disclosure of the information as required by applicable privacy legislation. Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of information about you. You may also withdraw your consent to any further collection, use or disclosure of information about you at any time by giving us reasonable notice. If our intended disclosures or uses of information change, we will notify you accordingly.
In certain circumstances, if you refuse to provide or withdraw your consent to the collection, use or disclosure of Personal Information, you may not be able to use the Website Service.
We do disclose your Personal Information in order to comply with the law, to enforce our Conditions of Use and other agreements, and to protect the rights, property, or safety of Attune, our users, or others, which may include for the purposes of fraud protection and credit-risk reduction.
Except as stated in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent.
5. Disclosure
To enable us to more efficiently provide the products and services you have requested from us, Attune may share your Personal Information with selected third parties who are acting on our behalf as our agents, suppliers or service providers. Such third party service providers are provided only with such information as is necessary in the circumstances. Information provided to third parties may be used only for the purpose stipulated and is subject to strict terms of confidentiality.
If we purchase a business to which you provided your Personal Information, your Personal Information will remain subject to the Privacy Policy applicable to your Personal Information. If Attune were to sell or contemplate a sale of its business or assets, then your Personal Information would be disclosed as a part of the sale or the due diligence concerning the sale.
6. Use of Cookies
Attune uses a browser feature called a cookie to collect information anonymously and track user patterns on our Website Service. A cookie is a small text file that is placed on your hard disk by a website. “Cookies” contain a unique identification number that identifies your browser, but not you, to our computers each time you visit our Website Service.Cookies tell us which pages of our Website Service are visited and by how many people.The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on our Website Service.
7. Accuracy
Attune will try to ensure that information about you is accurate, complete and up-to-date. However, please inform Attune of any change of name, address or other information. In the event you have questions about the accuracy of factual information we have collected about you, you will have access to that information in order to verify and update it. If we have disclosed inaccurate information about you to a third party, we will be pleased to contact the third party in order to correct the information.
8. Security
Attune is committed to protecting your privacy. Security measures, such as locked filing cabinets, restricted access or the use of passwords and encryption have been adopted to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Our employees have been trained to respect your privacy at all times and those employees with access to your Personal Information shall use your Personal Information strictly in accordance with our Privacy Policy and the laws applicable to each specific business.
9. Access
If you have any questions about the collection, use or disclosure of your Personal Information or if you simply want to know whether we have any of your Personal Information on file, you may contact us. Except in limited circumstances, as specifically provided by applicable privacy legislation, Attune can tell you whether they hold Personal Information about you, the source of the information, allow you access to your Personal Information and find an account of the use that has been made or is being made of the information and the third parties to which it has been disclosed.
Attune will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation. If Attune refuses access to you, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. Attune will respond to your requests for access in accordance with applicable privacy legislation.
10. Questions or Concerns
If you have any questions or concerns about the Personal Information about you held by Attune or about the compliance by Attune with our Privacy Policy, please contact us at the address listed in the Conditions of Use for the Website Service.
Attune has procedures in place to receive and respond to complaints or inquiries about its handling of Personal Information. They will describe the complaint procedures to anyone who makes inquiries or lodges complaints.
If you are not satisfied with the response from us after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
11. When is this Privacy Policy in force? Will the Privacy Policy ever change?
The foregoing policies are effective as of the “Last Update” date stated above. Attune reserves the right to change this policy at any time with reasonable notice to users posted on the Website Service of the existence of a new Privacy Policy. Your continued use of the Website Service following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.
12. Contact Us
If you have any questions about this Privacy Policy, the practices of Attune or this Website Service, please contact our Privacy Officer at info@attuneactiveaging.com and indicate “Privacy” in the email subject line.
13. Ten Principles of Fair Information Practices
(1) Accountability. Attune is responsible for the Personal Information under its control and shall designate one or more individuals who shall be accountable for the company’s compliance with the procedures and principles set out in our Privacy Policy.
(2) Identifying Purpose. Attune will identify the purpose for which Personal Information is collected at or before the time the information is collected. The purposes for which information is collected, used or disclosed by Attune must be those that a reasonable person would consider are appropriate in the circumstances.
(3) Consent. The knowledge and consent of the individual are required for the collection, use or disclosure of Personal Information, except where consent is notrequired by privacy legislation, for example, where the collection, use or disclosure of Personal Information is solely for journalistic, artistic or literary purposes.
(4) Limiting Collection. Attune shall limit the collection of Personal Information to that which is necessary for the purposes identified by the company. Personal Information shall be collected by fair and lawful means.
(5) Limiting Use. Disclosure and Retention. Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information shall be retained only as long as necessary for the fulfillment of the purposes for which it was collected.
(6) Accuracy. Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
(7) Safeguards. Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.
(8) Openness. Attune shall make readily available to its customers and employees specific information about its policies and practices relating to the management of Personal Information.
(9) Individual Access. Upon request, an individual shall be informed of the existence, use and disclosure of his or her Personal Information and shall be given access to that information except where Attune is permitted or required by law not to disclose Personal Information to the individual customer or employee. An individual customer or employee shall be able to challenge the accuracy and completeness of the information disclosed to him or her and have it amended as appropriate.
(10) Challenging Compliance. An individual customer or employee shall be able to address a challenge concerning compliance with the principles in our Privacy Policy to Attune.
