Privacy Policy

Introduction

When you use our services, you're trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information and that of your clients and prospective clients.

Our Privacy Policy explains how Absolute Engagement collects, uses, protects and discloses information about you, your clients and your prospective clients. The terms "Absolute Engagement," "we," "us," and "our" includes Absolute Engagement and our affiliates. We use the term "advisor" "user" "you," and "your" to mean any person using our platforms or attending related events, including any organization or person using the platforms on an organization's behalf. Absolute Engagement is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.

This Privacy Policy applies to the processing of information entered by yourself (on this site) or your clients or prospective clients (in response to a survey or poll) when participating in the Client Insights program or any other program that includes a poll or survey. This also includes any website, application, or services we offer or when you communicate with us. For information about choices that we offer under this policy, please see "Your Choices" below. For more information about the scope of our Privacy Policy, please see Section 4.

To make this Privacy Policy easier to understand, we have provided summaries at the beginning of each section. These summaries are not part of the official policy. Even though we have provided summaries, it is important for you to read the entire policy carefully.

The Bottom Line: WE DO NOT rent, sell, or otherwise disclose your personal information to third parties, except in the very limited circumstances set out below.

Any modifications to this Privacy Policy will be posted on our website, so please check the "last modified" date of the Privacy Policy periodically. This Privacy Policy was last modified on April 14, 2020.

1. Collection of Information

Summary: We collect information about you when you:
Sign up for or are enrolled in the Client Insights program or in any other program that includes a poll or survey through Absolute Engagement;
Request information from us;
Book a demo;
Register for our webinars;
Register for our blog;
Visit our Client Insights website; and
Communicate with us.

1.1 Information You Provide to Us

We collect information that you provide directly to us. For example, we collect information that you provide when you register for the Client Insights program or for any other program that includes a poll or survey, fill out a form, or communicate with us. The types of information that we may collect, and track includes your name, username, password, email address, postal address, phone number, payment method data, and any other information that you choose to provide. Section 2 explores how we will use the information that you provide to personalize our recommendations and other content for you.

2. Use of Information

Summary: We use information about you to:

• Operate, improve, promote, and protect Absolute Engagement and our programs;
• Communicate with you;
• Keep internal records;
• Improve our products and services;
• Periodically send promotional emails about new products, special offers, or other information that we think you may find interesting using the email address that you have provided; and
• Contact you from time to time for market research purposes by any means.

2.1 Operating Our Platform

We may use information about you for various purposes related to operating our programs, including to:

1. Provide, maintain, and improve the programs, including to process transactions, develop new products and services, and manage the performance of our Platform;
2. Monitor and analyze trends, usage, and activities in connection with our Platform;
3. Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of Absolute Engagement and others; to enforce compliance with our policies; and to comply with applicable laws and government requests;
4. Perform accounting and administrative tasks, and enforce or manage legal claims; and
5. Keep in contact with you regarding your progress and to notify you of relevant new products, services, and features offered by Absolute Engagement.

2.2 Communicating With You

We may use information about you for various purposes related to communicating with you, including to:

1. Respond to your comments, questions, and requests, and provide customer service;
2. Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others; to provide news and information that we think will be of interest to you; to conduct online surveys; and to otherwise communicate with you; and
3. Send you technical notices, updates, security alerts and support, and administrative messages.

2.3 Legal Basis for Processing

Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.

1. We process information about you in order to provide our services in accordance with our Terms of Conditions, for example, to allow you to participate in our Client Insights program or any other program that includes a poll or survey and to allow us to send you important service updates.
2. We process information about you where it is in our legitimate interest to do so and such interest is not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, and improving our Platform).
3. In some cases, we may have a legal obligation to collect information about you or may otherwise need the information to protect your vital interests or those of another person.
4. We may process information to comply with a legal requirement or to perform a contract.
5. We may process such data as credit card information for accounting purposes (invoicing and paying program fees).
6. We store, record, hold, refer to, and collect data of the nature referred to in Section 1.
7. We alter data if you give us permission to do so.

3. Sharing of Information

Summary: We do not share information about you in any way other than as described in this Privacy Policy. We may disclose information about you:

• to our third-party service providers who help us to operate or improve our Platform;
• with your permission to a program partner or enterprise when you are accessing this program through such partner or enterprise;
• to authorities to comply with legal obligations and to protect and defend our rights and property; and
• to an affiliate, financial institution, or successor entity as part of a corporate transaction.

3.1 Through Your Participation in Our Client Insights Program or in any other Program that includes a Poll or Survey

With your permission, we may share your Client Insights program results or the results of any other program that includes a poll or survey with a program partner or sponsor when you are accessing this program through such partner or sponsor. They will have access to a separate dashboard and can view your results as outlined in your program's terms and conditions. If you have specific questions about your program please contact us at [email protected].

Absolute Engagement reserves the right to aggregate data gathered through some programs and share that data to support the industry. In this case, no advisor or respondent -level data is ever shared.

3.2 Data Sharing With Our Service Providers

We may use service providers in connection with operating and improving the Platform to assist with certain functions, such as payment processing, email transmission, conducting follow up program surveys, data hosting, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations.

3.3 Following The Law And Protecting Absolute Engagement

We may access, preserve, and disclose information about you to third parties, including the content of messages if we believe disclosure is in accordance with or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms and Conditions or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Absolute Engagement or others.

3.4 Affiliate Sharing And Merger, Sale, Or Other Asset Transfers

If Absolute Engagement is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.

4. Additional Details

Summary:

• Absolute Engagement is based in Canada and governed by Canadian law. We will be processing, transferring, and storing information in North America;
• We use commercially reasonable efforts to protect your personal information and have implemented technical and organizational measures in line with industry best practices. We cannot guarantee these controls will provide absolute security;
• This Privacy Policy is periodically updated and does not apply to third parties; and
• Demonstration monitoring: Absolute Engagement may monitor and record your program demonstration session for quality assurance and staff training purposes. These recordings are voluntary, and you are not required to participate in them.

4.1 Transfer of Information

Given that the internet is a global environment, using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Personal information will be stored on servers hosted in North America. As such, your personal information may be subject to laws where the data protection and other laws may not be as comprehensive as those where you reside. Personal information may be disclosed in response to inquiries or requests from government authorities. Therefore, by browsing our website and communicating electronically with us, you acknowledge and agree to our processing of personal data in this way.

We have taken appropriate safeguards so that your information will remain protected in accordance with this Privacy Policy.

4.2 Security

We employ technical and organizational measures designed to appropriately protect your information that is under our control and that we process on your behalf from authorized access collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. We store all information that you provide to us on secure servers. We train employees regarding our data privacy policies and procedures and permit authorized employees to access information on a need-to-know basis, as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.

Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may do so by accessing the "Update My Profile" section of the myclientinsights.com site once you have logged in.

4.3 Safeguarding Data

Absolute Engagement takes all feasible and reasonable precautions to protect the personal information that we collect from you. Every staff member must sign a Confidentiality and Non-Disclosure Agreement wherein they agree not to improperly use and/or disclose any personal information about clients or other individuals who have contacted Absolute Engagement. Also, your personal information is retained in a secure database, which is only accessible by password and is protected using firewalls.

4.4 Data Retention

We retain certain information that we collect from you while you are a participant in our Client Insights program or any other program that includes a poll or survey, while on our website, and in certain cases where you have deleted your account, for the following reasons:

• To ensure that we do not communicate with you if you have asked us not to do so;
• To inform you about new products, services, and features offered by Absolute Engagement;
• To facilitate renewals of our programs;
• To provide accurate accounting information to you;
• To detect and prevent abuse of our website, illegal activities, and breaches of our Terms and Conditions;
• To comply with applicable legal, tax, or accounting requirements; and
• To establish, exercise, and defend legal claims.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it. If, after 3 years, you do not renew your program your personal information will be deleted from the program database. If you are not already a subscriber to our blog, you will be added to our subscription list and can unsubscribe and have your personal information deleted at any time.

4.5 Revisions to This Policy

We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version on our Platform at www.myclientinsights.com and revising the date referenced in the introduction section of this policy. If we make any material change to this policy, we will provide additional notice to you, such as by sending you an email or displaying a prominent notice on our Platform.

4.6 Links to Other Websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such sites, and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

4.7 How Do We Use, and Store Personal Information You Provide to Us When You Request Information or Register Online?

We will maintain your personal information in a secure database. We do not use the information in the database for any purpose other than facilitating your future orders or to permit us to notify you of services, webinars, and features offered by Absolute Engagement. We do not store your credit card numbers or expiry dates in our database, but they are stored in our PCI compliant payment processor's database to facilitate recurring program payments. Consequently, each time you choose to commence payment for a new program, your name and shipping address will be pulled from the database, but you will have to re-enter your credit card information to complete the order. Should you wish to have your credit card details purged from our payment processors database please contact us at [email protected].

4.8 Our Policy Regarding Sharing and Accessing Your Personal Information and Your Results.

Absolute Engagement does not sell, trade, or otherwise transfer the personal information you provide to third parties. We may allow authorized third-party service providers to access your personal information to perform services on our behalf. Our service providers are required to provide privacy protection comparable to ours and to limit their use of such information to provide services on our behalf. These service providers use servers based in North America and the personal information may be subject to disclosure in accordance with the applicable laws of these jurisdictions, which may create a different privacy regime from your country of residence.

Clients or prospective clients that have provided their names can request a copy of their survey or poll and that survey or poll is available, in .pdf format, on the advisor's dashboard. Respondents also have the right to have their data deleted. Data deletion requests can be sent to [email protected] and Absolute Engagement will anonymize or remove the completed survey. Advisors' data is retained under the program terms and conditions and can be corrected or removed by emailing us at the support email noted above.

5. Your Choices

Summary:

• You can review and change information about yourself in the ‘Update Your Profile' section of this website, but we may retain certain information; and
• You have the right to opt-out of receiving Absolute Engagement's promotional messages, but you may still receive other non-promotional communications.

5.1 Account Information

You may update or correct your profile in the myclientinsights.com site by editing your profile online or by sending a request to [email protected] as described in Section 6.

5.2 Opting Out Of Receiving Communications From Us

If you do not wish to receive communications from Absolute Engagement, you can opt-out of receiving such communications by either following the instructions in each such communication or by contacting support at Absolute Engagement at any time using the email noted below. It may take up to three days to process a request received by email or telephone, and one week to process a request received by mail. If you change your mind and would like to start receiving communications from us again, you can do so by emailing us at [email protected].

5.3 Cookies

This site does not use cookies, but to facilitate site access we do collect and store user IP addresses in our database. Users can have this data deleted by emailing the support email address noted above. Clients or prospective clients that are completing a Client Insights survey or any other program that includes a poll or survey will have their IP address recorded to facilitate completing the survey or poll. This data will be deleted no later than 90 days after the survey or poll results have been downloaded to the program dashboard.

5.5 Promotional Communications

You can control messages that you receive from Absolute Engagement and third parties by selecting the unsubscribe link in the message that you receive. If you opt-out, we may still send you non-promotional messages, such as those about your program or our ongoing business relations.

5.6 Anonymity

Respondents to our Client Insights survey or any other program that includes a poll or survey can elect to participate and provide feedback via our programs while remaining anonymous.

6. Data Rights

Summary:

• You have the right to exercise your data protection rights, including to request that Absolute Engagement delete, amend, or provide you access to your information; and
• You can complain to your local data protection authority about the use of your information.

We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to [email protected].

Rights that you may have, depending on the country in which you live, include:

• Accessing, correcting, updating, or requesting deletion of your information;
• Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information;
• Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the "unsubscribe" or "opt-out" link in the marketing emails we send you;
• Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect the processing of your information conducted in reliance on lawful processing grounds other than consent;
• Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority; and
• In the United Kingdom, your local data protection authority is the Information Commissioner's Office: www.ico.org.uk. We would ask that you contact us to give us the opportunity to review your complaint before you contact the ICO.

7. Contact Us

Summary:

Under data protection law, the controller of your information is Absolute Engagement. We do not have a dedicated Data Privacy Officer, but these duties are part of the responsibilities of the company President, Mike Reynolds. If you have questions about our policies, your personal information or your client data please contact Mike Reynolds directly:

Via email at [email protected]