Sonderly

SONDERLY™ Privacy Policy

Your Privacy Rights

SONDERLY recognizes the importance of privacy and the sensitivity of personal information. We take seriously our obligation to keep your personal information confidential and we protect it with physical, electronic and procedural safeguards. In order to comply with applicable privacy legislation and to instil confidence in individuals, such as users of our services and others that that engage with us, that the personal information they entrust to us is safe, we have developed this Privacy Policy.

SONDERLY identifies the purposes of collecting particular personal information before or when the information is collected. Identifying the purposes of collecting personal information allows SONDERLY to determine the information that it needs to collect. SONDERLY only collects information necessary for an identified purpose.

SONDERLY is responsible for personal information in its possession, custody, or control, including information that has been transferred to a third party for processing. SONDERLY uses contractual or other means to provide a comparable level of protection while a third party is processing this information or acting as a service provider to SONDERLY. SONDERLY has implemented policies and practices to give effect to this policy, including:

(a) implementing procedures to protect personal information;
(b) establishing procedures to receive and respond to complaints and inquiries;
(c) training staff and communicating to staff information about SONDERLY’s privacy policies and practices; and
(d) developing information to explain SONDERLY’s privacy policies and procedures.

SONDERLY personnel are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered.

SONDERLY also takes measures to ensure the integrity of this information is maintained and to prevent it being lost or destroyed.

“Personal Information” means information about an identifiable individual but does not include business contact information, such as the name, title, business address or telephone number of an employee of a business. SONDERLY only collects, uses, discloses, and retains personal information for purposes that a reasonable person would consider appropriate in the circumstances.

This policy does not apply to Personal Information about employees or other
temporary or permanent staff, consultants, volunteers or other individuals
assigned to or affiliated with us or to any information which is not Personal
Information as defined in or interpreted under applicable law.

Information that you disclose in your public profile, in forum posts, comments, tracker or other public portions online or otherwise becomes public information.

Why Does SONDERLY Collect Personal Information From You?

SONDERLY collects personal information from you so that we can provide you with a range of services and activities, which may include:

(a) responding to requests for and providing services, training and information to individuals;
(b) keeping you and members of the public informed about SONDERLY activities, including programs and services;
and for
(c) planning, research, and statistical purposes; and
(d) meeting legal and regulatory requirements.

How Do We Collect Your Personal Information

We collect information only by lawful and fair means and not indiscriminately. We may collect personal information directly from you when you contact us for information, services, training and events. We may occasionally collect information about you from other sources.

Consent

Consent for the collection, use and/or disclosure of personal information may be obtained orally or in writing and may be expressly given or implied. If you ask us to provide services or training to you we will require your written consent to the collection of your personal information. In some cases your written consent may consist of checking a box online to give us your consent. By signing up to create a SONDERLY account you agree to SONDERLY’s Terms of Use and this Privacy Policy. In other cases where we connect personal information we may also ask for your written consent. We may from time to time also ask you to give your written consent to the use and disclosure of specific personal information. In determining how we obtain your consent, we will take into account the sensitivity of your personal information that we are collecting, using and/or disclosing. We will use and disclose your personal information only in accordance with this policy.

If You Do Not Consent
The choice to provide us with personal information is always up to you. Upon request, we will explain your options of refusing or withdrawing consent to the collection, use and disclosure of your personal information and will record and respect your written choices. However, your decision to withhold particular details may limit or determine our ability to provide our services to you. In many cases your consent to the collection of your personal information will be a condition of the provision of our services to you. If you refuse or withdraw your consent, the consequence may be that we can no longer provide you with services, information or otherwise engage with you. There may also be overriding legal requirement that prevent or limit the effect of your refusal or withdrawal of consent.

Disclosure of Your Personal Information

Under certain circumstances we may disclose your personal information without your consent:

• when we in good faith believe the law requires or authorizes us to do so;
• when the services that you have expressly requested from us require us to give your information to third parties, your consent will be implied unless you tell us otherwise; and
• if the information is already publicly known.

We never make information associated with persons who use our services available to third parties in any form, except as set out in this document or unless we have your prior consent. Personal information provided to third party service providers (such as accountants, computer back-up services, or archival file storage) with whom we have contractual arrangements will have comparable levels of protection to the internal protection which SONDERLY maintains for personal information.

Is My Personal Information Secure?

We take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information, depending on its type and sensitivity, are:

• premises security;
• restricted access to personal information;
• deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
• internal password and security policies; and
• where necessary or appropriate, by requiring third parties to sign a confidentiality agreement.

As we are responsible for any personal information under our control, including personal information that we may transfer to a third party for processing, we will use contractual or other means to provide a comparable level of privacy protection when personal information is being processed by a third party on our behalf.

Some of the service providers that process or handle Personal Information on our
behalf are located outside of Canada. As a result, your Personal Information may
be transferred, stored and/or processed outside Canada in connection with the

purposes described in this privacy policy. Contractual or other measures we may
use to protect your Personal Information are subject to the legal requirements of
the foreign jurisdictions where your Personal Information may be transferred,
stored or processed, for example lawful requirements to disclose information to
government authorities in those countries.

Updating Your Information

Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If any of the information changes, or if you should become aware that the personal information which we have is incorrect, please inform us so that we can make the necessary changes.

Access to Your Personal Information

Upon written request, we will confirm the existence, use and disclosure of your personal information. You may request access to your personal information at any time. Please provide sufficient information in your request to enable SONDERLY to provide an accurate account of your personal information. Depending on the nature and complexity of the request, you may be required to pay a fee before your request can be processed.

Can I be Denied Access to My Personal Information?

Your rights to access your personal information are not absolute. We may deny access when:

• information relates to existing or anticipated legal proceedings against you
• granting you access would have an unreasonable impact on other people’s privacy;
• to do so would prejudice negotiations with you;
• to protect our rights and property; and
• the request is frivolous or vexatious.

If we deny your request for access, or refuse a request to correct information, we will explain why.

How Long Do You Keep My Personal Information?

Personal information will be retained as long as services are provided and, thereafter, for as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law. There may, however, be circumstances where SONDERLY may not be able to completely remove your personal information, including as a result of data backup procedures or document retention policies. In these circumstances such information will continue to be held securely pursuant to this Privacy Policy.

Web Site

Our Web site, https://sonderly.io/, may contain links to other sites which are not governed by this Privacy Policy. While no specific personal information is retained with respect to any visitor to this website, we may monitor traffic patterns, site usage and related site information to optimise our web service. In the continuing development of this website we may provide aggregated information to third parties, but these statistics do not contain any identifiable personal information. Personal information will not be posted on any of our digital channels.

Use of Cookies

Sonderly uses cookies and other tracking technologies for performance analytics and marketing purposes. By using the SONDERLY learning platform, you agree to this use. SONDERLY may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time by telling the Web server that you have returned to a specific page. For example, if you personalize pages or register with SONDERLY for services, a cookie helps the website to recall your specific information on subsequent visits. This simplifies the process of providing your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same website, the information you previously provided can be retrieved for your convenience.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can typically modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the SONDERLY services or websites you visit.

Openness about Policies and Practices

SONDERLY is committed to ensuring that information about our privacy policies and practices is available to you. SONDERLY makes general information regarding its privacy policies and practices available online. For additional information, please contact us by email info@autism.net or by phone (416) 322-7877 Ext 513.

Communicating with Us

E-mail is not a 100% secure medium and you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy

This policy is effective September 1, 2019. Since SONDERLY regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. Please refer to our website for revisions and updates.

Requests for Access

If you have any questions, wish to review your personal information, comment on this policy or make a complaint, please contact us by email info@autism.net or by phone (416) 322-7877 Ext 513.