Privacy Policy

Article 1 — Definitions and Interpretation

1.1 Definitions

In this Privacy Policy, unless the context otherwise requires:

• (a) "Act" means the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, and all regulations promulgated thereunder, as amended or re-enacted from time to time;
• (b) "Client" means any individual who requests a Career Audit consultation or purchases Services from the Corporation;
• (c) "Corporation" means Aligned People Advisory Inc., a corporation duly incorporated under the laws of the Province of Ontario;
• (d) "External Advisor" means an independent contractor retained by the Corporation to provide expert review services to Clients who purchase the Professional Edge Package;
• (e) "Personal Information" has the meaning ascribed to such term in the Act and includes any information about an identifiable individual;
• (f) "Privacy Officer" means the individual designated by the Corporation as responsible for ensuring compliance with this Privacy Policy and the Act;
• (g) "Services" means the career advisory and strategic positioning services provided by the Corporation, including the Foundation Package and Professional Edge Package;
• (h) "Website" means the Corporation's website located at www.alignedpeopleadvisory.com.

1.2 Headings

The division of this Privacy Policy into articles and sections and the insertion of headings are for convenience of reference only and shall not affect the construction or interpretation hereof.

Article 2 — Scope and Application

2.1 General Application

This Privacy Policy governs the collection, use, and disclosure of Personal Information by the Corporation in the course of its commercial activities and applies to:

• (a) all visitors to the Website;
• (b) all individuals who request a Career Audit consultation;
• (c) all Clients who purchase Services;
• (d) all individuals who subscribe to the Corporation's communications; and
• (e) all External Advisors in the Corporation's network.

2.2 Exclusions

This Privacy Policy does not apply to:

• (a) information concerning businesses or organizations, as opposed to individuals;
• (b) publicly available information; or
• (c) information collected, used, or disclosed solely for journalistic, artistic, or literary purposes.

Article 3 — Accountability and Privacy Officer

3.1 Designated Privacy Officer

The Corporation has designated a Privacy Officer who is accountable for the Corporation's compliance with this Privacy Policy and the Act. The Privacy Officer may be contacted as follows:

3.2 Accountability

The Corporation is responsible for Personal Information in its possession or custody, including Personal Information transferred to External Advisors or third-party service providers for processing. The Corporation shall use contractual or other means to provide a comparable level of protection while such Personal Information is being processed by such third parties.

Article 4 — Collection of Personal Information

4.1 Limitation on Collection

The Corporation shall limit the collection of Personal Information to that which is necessary for the purposes identified in Article 5 hereof. Personal Information shall be collected by fair and lawful means.

4.2 Information Collected Directly from Clients

The Corporation collects the following Personal Information directly from Clients:

(a) Upon Request for Career Audit Consultation:

• Full name, email address, and telephone number;
• Current employment status and career objectives;
• Target industries and any additional information voluntarily provided.

(b) Upon Purchase of Services:

• All information collected during the Career Audit;
• Billing information and payment details (processed through third-party payment processors);
• Resume, work history, educational background, and professional certifications;
• LinkedIn profile uniform resource locator and profile content;
• Career goals, target job titles, and additional contextual information.

(c) Through Communications:

• Email correspondence, messages submitted through Website contact forms, support inquiries, and feedback.

4.3 Automated Collection

The Corporation automatically collects certain technical information through the Website, including:

• (a) Internet Protocol (IP) address;
• (b) browser type and version;
• (c) device type and operating system;
• (d) pages visited, time spent on pages, and referring website;
• (e) date and time of access; and
• (f) cookies and similar tracking technologies.

4.4 Third-Party Sources

The Corporation may receive Personal Information from third-party sources, including:

• (a) payment confirmation data from payment processors;
• (b) publicly available information from LinkedIn (only if the Client provides their LinkedIn uniform resource locator); and
• (c) information from scheduling platforms if the Client books appointments.

Article 5 — Purposes for Use of Personal Information

5.1 Identified Purposes

The Corporation collects, uses, and discloses Personal Information only for purposes that a reasonable person would consider appropriate in the circumstances. Such purposes include:

• (a) Service Delivery: conducting Career Audit consultations; providing Foundation Package and Professional Edge Package services; matching Clients with appropriate External Advisors; delivering Strategic Assessment Reports, Advisor Review Memos, and career materials; providing email support; and communicating with Clients regarding their service engagement;
• (b) External Advisor Matching (Professional Edge Package): sharing the Client's complete career package with a vetted External Advisor for purposes of providing expert validation services;
• (c) Payment Processing: processing payments through third-party payment processors; maintaining transaction records for accounting and taxation purposes; and preventing fraudulent transactions;
• (d) Business Operations: responding to inquiries and providing customer support; improving Services based on Client feedback; analyzing usage trends; maintaining business records; and complying with legal and regulatory obligations;
• (e) Marketing and Communications: with the Client's consent, sending service updates, promotional offers, and career development resources; and requesting feedback on Services received; and
• (f) Legal Compliance: complying with court orders, legal processes, or governmental requests; protecting against legal liability; investigating and preventing fraud or security issues; and enforcing the Corporation's Terms of Service.

5.2 New Purposes

The Corporation shall not use Personal Information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

Article 6 — Consent

6.1 Requirement for Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate or where permitted or required by law.

6.2 Express Consent

The Corporation obtains express consent for:

• (a) sharing a Client's complete career package with External Advisors (Professional Edge Package);
• (b) using Personal Information for marketing communications; and
• (c) collecting sensitive Personal Information, where applicable.

Express consent is obtained by means of consent checkboxes during service purchase, execution of service agreements, verbal confirmation during consultations (documented in the Corporation's records), or active opt-in to communications.

6.3 Implied Consent

Implied consent is obtained when an individual:

• (a) provides an email address to book a Career Audit (implying consent to contact regarding the appointment);
• (b) submits information through the Website contact form (implying consent to respond to the inquiry); or
• (c) uses the Website (implying consent to collect basic analytics data).

6.4 Withdrawal of Consent

An individual may withdraw consent at any time, subject to legal and contractual restrictions, by contacting the Privacy Officer. Withdrawal of consent for essential service functions may prevent the Corporation from continuing to provide certain Services.

Article 7 — Disclosure of Personal Information

7.1 General Limitation

The Corporation discloses Personal Information only in the circumstances set forth in this Article 7.

7.2 Disclosure to External Advisors

For Clients who purchase the Professional Edge Package:

• (a) the Client's complete, unredacted career package is shared with a vetted External Advisor;
• (b) all External Advisors execute confidentiality agreements;
• (c) External Advisors are prohibited from using Personal Information for any purpose other than providing review services;
• (d) External Advisors must delete Personal Information upon completion of the engagement; and
• (e) External Advisors cannot share Personal Information with third parties.

7.3 Service Providers

The Corporation may share Personal Information with trusted third-party service providers, including payment processors, email service providers, scheduling platforms, and website hosting and analytics providers. All service providers are contractually obligated to protect Personal Information and may only use such information for the specific services they provide to the Corporation.

7.4 Legal Obligations

The Corporation may disclose Personal Information when required or permitted by law, including in response to court orders, subpoenas, or legal processes; to comply with regulatory investigations or audits; to protect the Corporation's rights, property, or safety, or that of Clients or the public; and in connection with investigating or preventing fraud, security breaches, or illegal activity.

7.5 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, Personal Information may be transferred as part of such transaction. The Corporation shall provide notice before Personal Information is transferred and becomes subject to a different privacy policy.

Article 8 — International Data Transfers

8.1 Primary Storage Location

Personal Information is primarily stored and processed in Canada. However, certain service providers may process data outside of Canada.

8.2 Foreign Jurisdiction

When Personal Information is transferred outside Canada, it is subject to the laws of the foreign jurisdiction, and foreign governments, courts, or law enforcement agencies may be able to access such information. The Corporation ensures that service providers use appropriate safeguards to protect Personal Information.

8.3 Consent to Transfer

By using the Corporation's Services, individuals consent to the transfer of their Personal Information to foreign jurisdictions for the purposes described in this Privacy Policy.

Article 9 — Safeguards

9.1 Security Measures

The Corporation implements physical, technical, and organizational safeguards to protect Personal Information against unauthorized access, disclosure, copying, use, or modification. Such safeguards include:

(a) Technical Safeguards:

• SSL/TLS encryption for data transmission;
• Encrypted storage for sensitive materials;
• Secure, password-protected file-sharing systems;
• Regular software updates and security patches; and
• Firewall and intrusion detection systems;

(b) Organizational Safeguards:

• Access to Personal Information limited to employees and External Advisors who require it to perform their duties;
• Confidentiality agreements with all External Advisors;
• Regular privacy and security training for staff; and
• Documented information security policies; and

(c) Physical Safeguards:

• Secure storage of physical documents and controlled access to facilities where Personal Information is stored.

9.2 Safeguards Appropriate to Sensitivity

The level of protection corresponds to the sensitivity of the information. More sensitive information receives a higher level of protection.

Article 10 — Retention and Disposal

10.1 Retention Periods

The Corporation retains Personal Information only as long as necessary to fulfill the purposes for which it was collected or as required by law:

• (a) Client service records: duration of engagement plus one (1) year;
• (b) Career Audit records: one (1) year from audit date;
• (c) payment and transaction records: seven (7) years for taxation and accounting purposes;
• (d) marketing communications: until the individual unsubscribes or requests deletion; and
• (e) website analytics: aggregated, anonymized data may be retained indefinitely.

10.2 Secure Disposal

When Personal Information is no longer required, the Corporation securely deletes or anonymizes such information using methods appropriate to the sensitivity of the information.

Article 11 — Accuracy

11.1 Reasonable Efforts

The Corporation shall make reasonable efforts to ensure that Personal Information is accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

11.2 Client Responsibility

Clients are responsible for providing accurate and complete information and for notifying the Corporation of any changes to their Personal Information.

Article 12 — Individual Access and Correction

12.1 Right of Access

Upon request, an individual shall be informed of the existence, use, and disclosure of their Personal Information and shall be given access to that information. The Corporation shall respond to access requests within thirty (30) days.

12.2 Right to Challenge Accuracy

An individual shall be able to challenge the accuracy and completeness of their Personal Information and have it amended as appropriate. If the Corporation disagrees with the request, it shall document the individual's challenge.

12.3 Exceptions

The Corporation may refuse access to Personal Information where permitted or required by law, including where the information contains references to other individuals, cannot be disclosed for legal, security, or commercial proprietary reasons, or is subject to solicitor-client or litigation privilege.

12.4 Minimal Fee

The Corporation may charge a minimal fee for providing copies of documents containing Personal Information.

Article 13 — Challenging Compliance

13.1 Internal Complaint Process

An individual may challenge the Corporation's compliance with this Privacy Policy by filing a complaint with the Privacy Officer. The Corporation shall investigate all complaints and respond within a reasonable timeframe.

13.2 Office of the Privacy Commissioner

If an individual is not satisfied with the Corporation's response, they may file a complaint with the Office of the Privacy Commissioner of Canada:

Article 14 — Cookies and Tracking Technologies

14.1 Use of Cookies

The Corporation's Website uses cookies and similar technologies to enhance user experience and collect usage information. Types of cookies include:

• Essential cookies: required for Website functionality;
• Analytics cookies: tracking usage to improve performance; and
• Marketing cookies: optional, used for targeted content.

14.2 Cookie Management

Individuals may control cookie settings through their web browser. Disabling cookies may impact Website functionality.

Article 15 — Children's Privacy

15.1 Age Restriction

The Corporation's Services are not directed to individuals under the age of eighteen (18) years. The Corporation does not knowingly collect Personal Information from minors. If the Corporation becomes aware that it has inadvertently collected information from a minor, such information shall be deleted immediately.

Article 16 — Amendments

16.1 Right to Amend

The Corporation reserves the right to amend this Privacy Policy from time to time to reflect changes in its practices, legal requirements, or business operations.

16.2 Notice of Changes

The Corporation shall post the updated Privacy Policy on the Website with a new effective date. For material changes, the Corporation shall notify individuals via email. Continued use of Services after changes constitutes acceptance of the updated Privacy Policy.

Article 17 — Interpretation and Governing Law

17.1 Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein.

17.2 Severability

If any provision of this Privacy Policy is determined to be invalid or unenforceable, such provision shall be severed and the remaining provisions shall continue in full force and effect.

Article 18 — Contact Information

18.1 Privacy Inquiries

Questions, concerns, or requests regarding this Privacy Policy or the Corporation's privacy practices may be directed to the Privacy Officer using the contact information set forth in Article 3.1 hereof.

18.2 Response Time

The Corporation endeavours to respond to all privacy inquiries within five (5) business days.