Atuka Inc. (“Atuka”, “us”, “we”, “our”) is committed to protecting your privacy. We believe that your online privacy is important and we want you to be familiar with how we collect, use and disclose any personal information that individually identifies you.

This Privacy Policy explains how Atuka collects, uses, and discloses your personal information when you use our services and our website located at atuka.com (the “Site”) (collectively, the Site and services are hereinafter referred to as the “Services”).

We will only collect, use and disclose your personal information in accordance with this Privacy Policy. By using the Services, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services or supply your personal information to us.

What Personal Information Do We Collect?

Personal information means any information about an identifiable individual. The types of personal information that we may collect include, but are not limited to, your:

• name;
• home number;
• business address;
• e-mail address;
• bank account details for payment purposes; and
• personal information you give us that we did not request (such as personal information you voluntarily put into an email to us, in a comments box on our Site or through your use of the Services).

Purposes for Collecting Your Personal Information

Atuka may use your personal information for the following purposes:

• to provide you with our Services;
• to manage our relationship with you;
• to identify you in our system;
• to manage our business and operations;
• to market our Services to you;
• to pay you for goods or services;
• to respond to your questions that you send through the Site, by email, or by phone;
• if you have consented, to send you marketing e-mails related to our Services;
• to track communications with you;
• to improve the Site and help us develop new services, tools and features of the Site that meet your needs; and
• as otherwise permitted or required by law.

When Do We Collect Personal Information?

We may collect your personal information when you voluntarily provide it to us by using the Services. For example, we may ask you to provide personal information if you:

• send a question or comment to Atuka by email, phone or through our Site;
• communicate with Atuka representatives by phone or in-person;
• register to receive electronic communications; and
• otherwise voluntarily participate in features of our Site that ask for personal information.

We also collect your personal information through third parties and other publicly available sources, for example, through our business partners and other services.

Limiting Collection of Personal Information

We limit the collection of personal information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information in accordance with this Privacy Policy.

Use, Disclosure and Retention of Personal Information

Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable laws.

We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected and to comply with our legal obligations.

We may also use and disclose your personal information to third parties under the following limited circumstances:

• to service providers that help with Atuka’s operations and Services including, without limitation, customer service, accounting, monitoring and analyzing the Site’s activity, and operating and maintaining the Site. Such service providers may only use your personal information for the purposes described in this Privacy Policy;
• when necessary to protect the safety, property or other rights of Atuka, its representatives, and users of the Services, including to detect and protect against fraud;
• as needed, if such information is requested by law enforcement agencies that possess warrants or if we are requested to do so by law, regulation, court order, or by a government entity. We may also disclose your personal information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) cooperate in any legal investigation; or (iii) to protect our rights, privacy, safety or property. We may also disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with applicable law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Atuka or our users and customers; or (d) protect Atuka’s property rights;
• if we sell or transfer all or a portion of our business or assets to a third party; and
• for any other purpose to which you consent. However, we will not sell your personal information to advertisers or other third parties.

Data Processors in Other Countries

To provide you with the Services, we may use service providers, data processors and other third parties (collectively, “Third Parties”) to perform services on our behalf. These Third Parties may store, process and transfer personal information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, which may include the United States of America. As a result, personal information may be subject to access requests from governments, courts, or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on personal information which are equivalent to those that apply in Canada.

If you have questions regarding our policies and practices with respect to our use of Third Party service providers outside of Canada, including with respect to the collection, use, disclosure or storage of personal information by service providers outside of Canada for us or on our behalf, please contact us as set out below.

Links to Other Sites

The Site may contain links to other websites or Internet resources, including those belonging to sites that are independently owned and operated by third parties. When you click on one of those links you are contacting another website or Internet resource that may collect information about you voluntarily or through cookies or other technologies. We are not responsible for the privacy practices or the content of any sites owned and operated by any third parties. Other sites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy of each site you visit.

Electronic Communications

You may have also opted in to receive future promotional electronic communications from us. If you option to receive such communications, we may use the information to: communicate with you regarding our products, Services and promotions; provide you with other information that you request; and/or improve our product and service offerings. You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time. We provide an ongoing opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by contacting us by e-mail at privacy@atuka.com, or as otherwise described in our messages to you. If you decide to unsubscribe, we will only contact you thereafter: (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; and (iii) to receive Service related messages.

Cookies, Web Beacons and Other Similar Technology

As you interact with the Services, we may use automatic data collection technology and services that record and collect information that identifies your computer, IP address, type of browser and operating system; tracks your use of the Site; and collects certain other information about you and your browsing habits on our Site. This data collection technology may include cookies, web beacons and other similar devices on the Site to enhance functionality and navigation for our visitors.

A cookie is a small data file that is placed on the hard drive of your device so that your device will “remember” information when you visit a site. Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site. Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on the Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize the Site and improve your experience on the Site. We may also include web beacons in HTML-formatted email messages that we send to determine which e mail messages were opened.

Information tracked through these mechanisms includes, but is not limited to: (i) your IP address; (ii) your e-mail address; (iii) the type of web browser and operating system being used; (iv) the pages of the Site a user visits; and (v) other sites a user visited before visiting the Site.

You can reject or disable cookies by managing your browser settings and following the directions provided in your Internet provider’s help file. Please note that if you disable cookies, you may be unable to access some customized features on the Site.

Analytics

Our website employs Google Analytics, a service provided by Google, Inc., to analyze website traffic and understand how visitors engage with our site. This information is critical for us to improve your experience while navigating our pages.

Please note that Google Analytics collects data related to your device/browser, the pages you visit, and the time spent on those pages. However, this data is anonymized and used in aggregate form. We do not collect personal information such as your name, email address, or other sensitive data through Google Analytics.

Google’s ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can opt out of Google Analytics if you do not want your site activity to be available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity.

Browsing Information

We want to make your experience with Atuka as supportive and as customized as possible, and to do this, we, with the help of our Third Parties, may use cookies on your device to trace your online browsing habits on our Site. We and/or our Third Parties may then use the information collected from the cookies to provide you with suitable Atuka advertisements when you visit our Site and other websites, such as social media sites (for example, Facebook and Instagram), Google and Yahoo. If you do not want to receive this type of customized advertising, you may set your browser to block third party cookies or clear your cache after each use. Additionally, you can opt out using the Digital Advertising Alliance of Canada’s You Ad Choices tool, located at: https://youradchoices.ca/en/tools.

Security

To help protect the confidentiality of your personal information, Atuka employs adequate technological, physical and organizational security safeguards to protect your personal information against loss, theft, and unauthorized access. Any personal information you provide to us is exchanged on a secure server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

We also take reasonable steps to make Atuka’s employees, contractors and other representatives aware of the importance of maintaining the confidentiality of personal information so that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.

Individual Access and Accuracy of Personal Information

You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information that we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons as to why access is being denied, unless we are prohibited by law from doing so.

You may request to update and change your personal information at the contact information set forth below. We will endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete.

Changes to this Privacy Policy

This Privacy Policy may be amended or replaced by Atuka from time to time in Atuka’s sole discretion and without any prior notice to you. The collection, use and disclosure of your personal information by Atuka will be governed by the version of this Privacy Policy in effect at that time. We will post the most current version of our Privacy Policy on our Site and will indicate at the top of this page the date this Privacy Policy was last revised. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy. Your continuing access or use of the Site after any such changes constitutes your acceptance of the Privacy Policy as revised.

Your Consent to the Terms of this Privacy Policy

By using our Site and Services and providing us with your personal information, you agree that Atuka may collect your personal information and you voluntarily consent to the collection, use, disclosure and transfer of your personal information in accordance with the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Site or Services or provide us with any personal information. If you do not understand the nature, purpose and consequences of us collecting, using and disclosing your personal information, please do not use our Site or Services or provide us with any personal information, and contact us at the contact information set forth below so that we can address your questions or concerns.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified in this Privacy Policy at any time by contacting us at the contact information set forth below. If you refuse or withdraw your consent, you acknowledge that Atuka may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

Minors

Atuka only collects personal information from or relating to persons who indicate that they are of the age of majority in the province in which they reside (the “Age of Majority”). If we learn that we have inadvertently collected personal information from or relating to a person who is under the Age of Majority (“Minors”), we will delete that information from our systems. If you are a Minor do not submit or post any information via the Site, and do not communicate any personal information to us. If a Minor has already provided us with personal information, its parent or guardian may contact us at the contact information set forth below for the purpose of deleting this information, and we will promptly delete such information.

How to Contact Us

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:

• see your personal information that you have already sent us so that you can correct, update or
• delete it from our files;
• if your child under the Age of Majority has used the Site and sent us personal information, delete
• that personal information from our files;
• ask that we not send you electronic communications or otherwise contact you; or
• report any violation of this Privacy Policy,

Please contact our Privacy Officer at privacy@atuka.com and we will endeavour to respond to you as soon as possible.