A TRICK OF LIGHT PRIVACY POLICY

We, at A Trick of Light (“ATOL”) are dedicated to maintaining both a high standard of privacy and a high standard of data protection in all of our activities. This policy is based on the standard required by the Personal Information Protection and Electronic Documents Act (PIPEDA). We welcome your comments and suggestions.

1. What is Personal Information?

Personal information is information about an identifiable individual.  This, however, does not include information, which is anonymous, i.e., where the identifying data fields are removed.  Personal health information is identifying information of a person’s health matters including that person’s substitute decision-maker, donation of body parts or bodily substance, physical and mental health, provision of health care (including the name of the individual who provides health care to the person). We do not intentionally collect personal information through Pyxis nor communicate directly with customers. If you believe that we may have collected Personal Information from someone or communicated directly with them, please contact us.

2. Accountability

You may contact our privacy officer at privacy@atol.caAll contractors and other third parties with whom we have a contractual arrangement and with whom we share personal data are contractually obligated to ensure that their practices meet our standards and are fully compliant with PIPEDA and other applicable privacy legislation.

3. Purpose

This policy applies only to the Software and to our website (www.atrickoflight.ca). It does not cover the practices of other organizations or their websites, including those you may access through the links provided on our website or through the Software. We encourage you to read the privacy policies of all websites you visit, especially if you provide any personal information and/or personal health information. Our mobile version enables you to share the test information and any other relevant information with your health care providers or any other third party with whom you decide to share your information through our mobile application (the “Software”).  All personal information that you may provide to us is voluntary and you are, at not time, required or obliged to provide any information.  However, please note that for security purposes and to improve our Software as well as to determine user insight into the use of our Software we may collect some information from your device which includes error reporting and general usage statistics and we may collect information about the device make/model/ID, OS version, app name, app version, and time stamps. Further, personal information may be gathered from you and be used in the following situations:If you visit our website, the web server logs IP addresses and associated information relating to the requests made; and If you make an inquiry or complaint, apply for a job, or visit the premises. Finally, regardless as to how and from whom we collected information, we will not sell nor share your personal information to any organization for any purpose unless you explicitly consent to it.  All the personal information that you provide to us will, at all times, be your information and you will be, at all times, remain and be the custodian and controller of your personal information.  We will never share your personal information with anyone unless you explicitly direct and authorize us to do so.  
4. Consent
We, pursuant to the Purpose, do not require any of your personal information including your personal health information other than as set out above for security reasons.  Therefore, any personal information and personal health information you share with us is completely voluntary.  Even after you have shared personal information with us you may withdraw consent for the further use of the personal information and personal health information at any time, by contacting our privacy office at privacy@atol.ca.  

5.Collection and Use

We collect personal information about you, from you, or from third parties you authorize us to collect such information from, only when you voluntarily provide it or authorize us to collect it.  Typically, we will seek consent for the use or disclosure of your personal information at the time of collection.  You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.  If you wish to withdraw your consent at any time, please contact us using the contact information provided in the “Contact Us” section of this Privacy Policy.  We will inform you of the implications of withdrawing consent. We will not, as a condition of the provision of the service, require you to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided and collected. The personal information we may collect in the course of you using, accessing, and/or receiving our Services may include, but is not limited to, the following: Mobile Your mobile exercises, games, questionnaires, statistics such as time, number of mistakes and accuracy, test results (e.g., your score, date test was taken, number of times taken), account information (e.g., username, password, email address, contact details, referring doctor, home clinic, name, and credit card information),about me (e.g., birth date, height, weight, gender), medication information, other medical information, place of residence, application settings/preferences, changelogs, cookies or other passive tracking mechanisms, tools to collect information in order to facilitate your use of the Software, appointments set up, and any other information that you may voluntarily supply to us via your account. Mobile Data Exercises – there are exercises where we capture start and stops, use of the timer and metronome, use of messages feature, appointment requests and use of content. any other information that you may voluntarily supply to us either by synchronizing your information on the Software with our servers or via your Online Account. We use your personal information to: Provide you with personalized Services and a personalized experience; Provide you with timely and reliable services; Provide you with exceptional support; Do all the things necessary to administer the service; Research, develop, manage, protect, and improve the services; Advise you about new products and services that may be of interest to you; Develop and maintain our relationship with you and communicate with you; Bill you for our services; Collect outstanding debts; Investigate any breaches of our agreements and or actions that may or have caused damage to our Services; and Comply with legal requirements.

6. Disclosure of Personal Information and Personal Health Information

Your personal information and personal health information is only shared with third parties if you chose to do so by either sharing it directly with a Professional or by joining a group.  Therefore, once you have registered the clinic and you receive the registration link the relevant health care provider and his/her administrative and support staff will be able to see all the information and results. We do not use personal information and personal health information for marketing purposes, and do not share or disclose personal information and personal health information with other parties unless specifically stated in this policy. If you have not opted out of receiving marketing materials, we may also use (but will not disclose) your personal information to promote and market additional goods, services and special offers from us, including by means of direct marketing. You can choose not to allow us to use your personal information for direct marketing purposes by contacting us or by going to your account and selecting your communication preferences. We may collect and disclose aggregated non-personal information and non-personal health information from all users of the Software relating to, for example, game scoring, test scores, age, geographic location, and gender.  All such information will be stripped of all personal information so that it cannot be recompiled, and individual users identified. We collect and aggregate this kind of information in order to determine how the Software is being used, how it and other products and services can be improved, and to share the aggregated information to third parties so that they can use the information for improvements of their own products and services. We will share aggregate data if We believes it is necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.), or other legal requirements of any governmental authority; if We believe it would potentially mitigate Our liability in an actual or potential lawsuit; if We believe it is permitted by law or if doing so will not violate the law; or if We believe it is otherwise necessary to protect Our rights or property; or is necessary to protect the interests of other users of the Software. In the unlikely event that all or part of Our business is sold or acquired by a third party, we will transfer such information to the new business owner.We may share personal information with third parties engaged to assist us in providing the Services to you or to carry out one or more of the purposes described above (such as payment providers, will receive your credit card information, name, and contact details to manage the payment process).  These service providers are prohibited from using your personal information for any purpose other than to provide the required assistance and are required to: (i) protect any personal information collected by them on our behalf or disclosed to them by Us; and (ii) to comply with the general privacy principles described in this Privacy Policy.We reserve the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so.We also reserve the right to disclose or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of our company or of any of the business or assets or shares of our company or a division thereof in order for you to continue to receive the same products and services from the third party.

7. Accuracy and Retention

If you think we have information about you that is not accurate, you are encouraged to contact us at the address provided in section 10 of this policy and indicate the necessary changes.  We may require that you follow certain procedures that are utilized by us for the authentication and verification of your identity.  We retain information according to retention schedules, which depend on the purpose of the information and any legal or contractual requirements with which we might need to comply.  

8. Safeguards
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It is important that the information maintained by us on behalf of you is accurate, protected from interference by other parties, and treated in confidence by as few personnel as necessary.  We maintain state of the art firewall and antivirus protection on our servers, train our staff, and hire only responsible and capable contractors to manage our systems.  If you detect any anomalies that might lead you to believe there has been a security infraction or hacking of our system, we will be pleased to investigate.
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9.Access to Information
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The intention of this policy is to answer your questions about our privacy policy and practices.  Should you be interested in more detailed information about our procedures and practices, please contact us at privacy@atol.ca. Should you wish to access your own personal information, please write to our privacy office at privacy@atol.ca.  At the time of your request, we may need further information from you to verify your identity, before we can provide you with the personal information we hold. There may be instances when we will not be able to provide you with the personal information that you request. For example, if the personal information: Contains references to other persons; Has already been destroyed due to legal requirements or because we no longer needed it for our purposes; Is subject to solicitor-client or litigation privilege; and/or Cannot be disclosed for other legal reasons.

10 Feedback and Complaints
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We take privacy seriously and consider that our treatment of personal information is part of the service that we offer.  We appreciate hearing any comments that you may have about our policy, practices, and customer service.  Please contact us at privacy@atol.caIf you are interested in more information about the Personal Information Protection and Electronic Documents Act, the Office of the Privacy Commissioner of Canada has detailed information on their website at www.privcom.gc.ca.If you are interested in more information about the Personal Health Information Protection Act, the Information and Privacy Commissioner of Ontario has detailed information on their website at www.ipc.on.ca. If you want to contact the Office of the Privacy Commissioner of Canada:
Snail Mail
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Telephone Toll-free: 1-800-282-1376Phone: (819) 994-5444TDD/TTY: (819) 994-6591