1. Introduction

This privacy policy (“Privacy Policy”) explains how attune Consulting (collectively “attune”, “we” and “us”), collects, uses, shares, and retains personal information that you provide to us at all touch points , or that we collect, when you use the attune website located at www.attuneconsulting.com and other websites owned or controlled by attune (the “Websites”) or related mobile applications, use attune products and services and complete related forms, participate in attune events, or communicate with one of our customer service representatives. The term “Websites” includes all subdomains of Websites and any content, code, data, services, features or functionality made available from or through the Websites. This policy explains the types of information we collect regarding users of the Websites and how we may use that information so you can make an informed decision about whether to view the content and/or use the services on the Websites. This Privacy Policy applies to information we collect via the Websites, however accessed and/or used, whether via personal computers, mobile devices or otherwise (“Device”). This Privacy Policy is incorporated into and subject to the Websites’ Terms of Use. Each time that you access or use the Websites, you agree that you have read, understand and agree to and be bound by the Terms of Use and the Privacy Policy and you expressly consent to the collection, use and disclosure of your information, including without limitation, Personally Identifiable Information (PII) in accordance with this Privacy Policy. For the purposes of this Privacy Policy, “Personally Identifiable Information” or “PII” is information that we can use to identify or contact you as an individual, and includes your name, email address, address, telephone number and any other information that we associate with any of the foregoing. Please note that if you disagree with anything in this Privacy Policy, you must not use the websites or mobile applications, or provide personal information to us in connection with attune’s products or services and features therein.

This Privacy Policy applies to information we collect via the Websites however accessed and/or used, whether via personal computers, mobile devices or otherwise (“Device”). This Privacy Policy is incorporated into and subject to the Websites’ Terms of Use. Each time that you access or use the Websites, you agree that you have read, understand and agree to be bound by the Terms of Use and the Privacy Policy and you expressly consent to the collection, use and disclosure of your information, including without limitation, Personally Identifiable Information in accordance with this Privacy Policy. For the purposes of this Privacy Policy, “Personally Identifiable Information” or “PII” is information that we can use to identify or contact you as an individual, and includes your name, email address, address, telephone number and any other information that we associate with any of the foregoing.

If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the Websites and all services and features therein.

2. The Subscription Service

Our Subscription Service allows any company or individual that uses it to receive information about attune, and to learn more about the company, as well as download content, and provide their contact information and other demographic information. This information, which is stored and managed on our service providers' servers, is then used so that the visitors can be contacted about their interest in our services and interact with the company

3. Collection of Personal Information

A) Information You Directly and Voluntarily Provide to Us

Personal Information: When you submit your information on certain pages of our Websites that may require registration for downloadable content, webinar or event, or other electronic services such as subscribe to receive newsletters, or send us an email or feedback, you may be asked to provide PII such as your e-mail address, name, phone number, address, job title and company name and we (or third party service providers on our behalf) will collect such information as well as any other content you provide to us. If you wish to opt-out of receiving these communications from us, please follow the instructions contained in an applicable communication you receive from us or submit a request at info@attuneconsulting.com.

Events and Conferences: attune may host events that include in-person and virtual conferences, training, knowledge sharing and webinars. If you register for an attune event, we will access the information to provide you with information and services associated with the event. If you participate in one of our events, we will collect your first and last name, email address, business or home address, and the type of business you work for or with, which we will use to provide you with further information and services associated with the event.

Publications: We offer various publications and materials through our websites. Some of these publications and materials are publicly accessible, however, others require that you create an account and subscribe to receive these publications and materials. If you are already not created an account for this purpose, you will be required to provide certain information as part of your account registration, including your first and last name, email address, and business or home address and professional information. You may manage your attune subscriptions by subscribing or unsubscribing at any time. If you have any difficulties managing your subscription or other preferences, reach-out us at info@attuneconsulting.com.

Communications with attune: If you communicate or correspond with us by email, through postal mail, via phone or through other forms of communication, we may collect the information you provide as part of those communications. For example, if you correspond with us through email, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry; to notify you of attune business services, events, publications, or other services; or to keep a record of your complaints, service requests, and similar purposes.

B) Information Collected As You Access and Use the Websites

In addition to any PII or other information that you choose to submit to us, to provide you with services and content that are more customized to your interests, we and our third-party service providers may use a variety of technologies (including cookies, Flash cookies, web beacons and embedded scripts) (“Tracking Technologies”) that automatically or passively collect information when you visit or interact with the Websites (the “Usage Information”). This Usage Information may include, without limitation, the browser that you are using, your IP address (“Identifier”), the URL that referred you to our Websites and all of the areas within our Websites that you visit. We may use Usage Information for a variety of purposes. Usage Information gathered from your use of the Websites may be combined with information from third party sources to identify your location by state and region. More specific Usage Information may be collected for certain Websites (“Geolocation”), as set forth below. Some of the more common Tracking Technologies used to collect Usage Information include, without limitation, the following:

Usage Information gathered from your use of the Websites may be combined with information from third party sources to identify your location by state and region. More specific Usage Information may be collected for certain Websites (“Geolocation”), as set forth below.

Some of the more common Tracking Technologies used to collect Usage Information include, without limitation, the following:

1. Cookies

Please refer to the attune cookie policy for further information.

2. Log Files

We may collect demographic information, such as your ZIP code, age, gender, preferences, interests and favourites using log files that are not associated with your name or other personally identifying information. There is also information about your computer hardware and software that is automatically collected by us. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by attune for the operation of the Subscription Service, to maintain quality of the Subscription Service, and to provide general statistics regarding use of our Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.

3. Third Party Tracking Technologies

We may acquire information from other trusted sources to update or supplement the information that you provided or we collected automatically, such as information to validate or update your address or other demographic information and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal business analysis or other business purposes. We may also acquire information from other sources about your visits over time and across other third party web sites, in order to serve more targeted advertising to you on the Website(s). Those third parties have privacy policies that differ from this Privacy Policy.

C) Information Collected by Third Parties through Third-Party Links and Content.

The websites may include links to other websites and other content from third-party businesses and can offer direct interaction with external websites, networks or platforms that are outside attune’s control. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. attune does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the security, privacy of the information collected by these third parties or the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of those websites.

D) Information Collected by Third-Party Analytics Services

We may work with third-party analytics services to help us understand how the Websites are being used, such as tracking the frequency and duration of use of the websites. We may use Adobe Analytics and Google Analytics, and web analytics services provided by Adobe and Google (“Analytics Tools”) to collect information about your use of the websites. These Analytics Tools may use cookies to collect information about the content you view, what websites you visit immediately and prior to and after visiting the websites, and your system information and geographic information. The information generated by these cookies about your use of the websites will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyse your use of the websites. The Analytics Tools may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the websites. At the moment that you cancel your consent for the processing of personal information, attune will not be able to access the personal information processed by third-party analytics. By using the websites, you consent to the processing of data about you by Adobe and Google in the manner and for the purposes set out above. You can opt-out of Google Analytics by installing Google’s opt-out browser add-on, and out of interest-based Google ads using Google’s Ads Settings.

E) Information You Share through Social Media Services.

Various social media services may include links to third-party websites and social media services where you will be able to post comments, stories, reviews or other information outside of attune’s control. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. attune is not responsible for the security or privacy of any information collected by other websites or other services. Information collected by third parties is governed by their privacy practices. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

F) Information You Post on the Websites and Social Media platforms

If you post your personal information on public areas of the websites and Social Media platforms, that information may be collected and used by attune, other users of the websites and Social Media platforms, and the public generally. In addition, if you are registered user and choose to participate in our professional networking features, which are provided by our third-party vendor and volunteer platform provider, postings you make in connection with those features will be associated with the personal information in your public member profile (which includes your name, user name, and other optional information you may choose to include). If you decide to participate in our platforms and professional networking features, keep in mind that your personal information (for example, your name and online user name), along with any substantive information you disclose in the communication you decide to post, will be publicly accessible and viewable by others who visit that area. In addition, we may highlight certain users’ postings or contributions to other members of the professional networking features. For example, users who participate actively in our social networking features, like contributing materials and engaging in certain online activities, will be listed as “active members” in a roster that is viewable by all other registered users. It is possible that your posting may result in unsolicited messages from third parties. We strongly recommend that you do not post any information on the public areas of the websites and Social media that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

4. How We Use and Share the Information Collected.

We use information we collect from you in part to provide you with the content you have requested, to respond to inquiries, and send information to you which we think may be of interest to you by email, or other means. We also use the information in connection with advertising and to serve other content, as described below. We also use the information we collect and obtain about you to measure and improve our Websites, to customize certain features of the Websites, to deliver relevant content and to provide you with an enhanced experience based on the type of device you are using. We may provide access to information, including PII, to certain vendors that are performing services on our behalf to other companies or individuals in the following situations:

(a) Marketing. We may combine and use any and all information we collect on you either online or otherwise, including from third parties, for marketing purposes, including sending you promotional emails regarding our products and related content. If you have received a promotional email and do not want further emails about similar promotions or offers from us or, as applicable, from the third party marketing partner, simply follow the unsubscribe instructions that are located at the bottom of those emails.

(b) Delivery of Advertising and other content. In addition to content that we serve you directly, attune may use third party advertising companies and marketing services to serve ads and other content when you visit the websites and elsewhere on the internet and in other media. We also use analytics services supported by third party companies to perform analytics and track trends. We work with other third parties to provide certain functionalities on the Websites and to improve the effectiveness of the Websites and its content. Those third party companies may use Tracking Technologies to collect and store Usage Information about you and may combine this information with information they collect from other sources. If you access the Websites through a mobile device or app, we may also share your information with mobile carriers, operating systems and platforms. To provide ads on the Websites, we use a variety of third party advertising service providers, including networks, data exchanges, ad servers, analytics providers and others. These third parties may use technology to send, directly to your Device, the advertisements and links that appear on the Websites. They automatically receive your Identifier when this happens. The third party service providers, as well as the advertisers themselves, may collect and use information about your visits over time and across the Websites and other third party websites, as well as information received from other sources, in order to serve more targeted advertising to you on the Websites. Third parties may also use information gathered from your usage of the Websites to serve targeted advertisements to you on third party websites and applications. Google is one of the companies that we use to serve advertising and perform analytics on some of the Websites. We and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to help implement the above uses of your information. We also use Google Analytics along with audience data (such as age, gender and interests of users) to help understand users’ visits to the Websites and to optimize the content that we serve to users. We do not control Tracking Technologies used by third parties, and their use may be governed by the privacy policies of the third parties employing the Tracking Technologies. You should consult the respective privacy policies of these third parties to see your options for opting out of their use of such devices.

(c) Response to Subpoenas, Court Orders, Government Requests or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties if: (a) required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Sites by using them to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

(d) Business Transfers, Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. Unless you are residing in the European Economic Area, we reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users to third parties. attune will still ensure the confidentiality and security of any user information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy.

(e) Aggregate Information. We may share your information with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally. Where we do share your personal data with third parties, attune takes steps to ensure that they use appropriate safeguards to protect your personal data.

5. Information for Individuals located in the European Union.

Legal Basis for Processing of Personal Information from EEA Residents If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows:

(i) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.

(ii) If the processing of your personal data is necessary for the performance of a contract between you and attune or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) (b). If this data is not processed, attune will not be able to execute the contract with you.

(iii) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) (c), for example complying in the fields of employment law.

(iv) And where the processing is necessary for the purposes of attune’s legitimate interests, such processing will be made in accordance with GDPR Article 6(1) (f), for example to detect fraud.

 

6. Transferring Personal Data from the EU to non-EEA nations:

attune has its headquarters in German Republic. Information we collect from you may be processed in some of the non-EEA nations. attune will check availability of the “adequacy” from European Union in all the cases. In case it is found that such nations have not sought nor received a finding of “adequacy” from the European Union (under Article 45 of the GDPR) attune relies on derogations as set forth in Article 49 of the GDPR as non-EEA nations have no “adequacy” decision and no other safeguards under the GDPR are in place. A finding of “adequacy” in short means that the European Commission has decided that such country outside the EEA ensures an adequate level of data protection. In particular, attune collects and transfers your personal data only, with your explicit consent; to perform a contract with you; in a manner that does not outweigh your rights and freedoms. If this data is not processed and transferred, attune will not be able to execute the contract with you or you will not have access to any or all of the benefits and features associated with your transaction. attune endeavours to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with attune and the practices described in this Privacy Policy. attune also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

If you wish to confirm that attune is processing your personal data, or to have access to the personal data attune may have about you, please contact us at info@attuneconsulting.com.

7. European Union Data Subject Rights

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects (these are persons that can be identified). You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside attune might have received the data from attune; what the source of the information was (if you did not provide it directly to attune); where the personal data is stored and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by attune if it is inaccurate. You may request that attune erase that data or cease processing it, subject to certain exceptions. You may also ask attune for your personal data to be supplemented or updated, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. You may withdraw your consent for the processing of personal data or the further processing of personal data by attune at any time. You may also request that attune cease using your data for direct marketing purposes. In many countries (including EEA countries), you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how attune processes your personal data. When technically feasible, attune will—at your request—provide your personal data to you or transmit it directly to another controller. You have the right to receive your personal information in a structured and standard format. In addition to the information contained in this Privacy Policy, you may be provided with additional and contextual information concerning particular services or the collection and processing of your personal data upon request. Reasonable access to your personal data will be provided at no cost to attune all data subjects, event attendees and others upon request made to attune at info@attuneconsulting.com. If access cannot be provided within a reasonable time frame, attune will provide you with a date when the information will be provided. If for some reason access is denied, attune will provide an explanation as to why access has been denied.

8. Security of Your Information.

attune uses reasonable physical, technical and administrative measures to safeguard personal information you provide through the websites or in connection with attune’s products and services. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, attune cannot guarantee or warrant the security of any information you transmit on or through the websites and you do so at your own risk.

9. Data Storage and Retention

Your personal data is stored by attune on its servers, and on the servers of the database management services (including cloud services) attune engages, attune retains data for the duration of the customer’s business relationship with attune and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your personal data are processed. We will retain your personal data as long as you are an attune client or require our services so that we can provide these services to you. If you are located in the European Economic Area, at the moment you cancel your business relationship or withdraw your consent for the processing of your personal information, all your personal data received and stored are erased if no longer needed by us, unless we are required to retain this personal data by law or to comply with our regulatory obligations. In such a case, we will only keep this personal data for as long as necessary. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our data privacy resource at info@attuneconsulting.com.

10. Personal Information of Children

attune is a business entity and its activities and websites are not directed to children under the age of 13. attune does not knowingly collect personally identifiable data from persons under the age of 13. If you are a parent of a child under 13, and you believe that your child has provided us with information about him or herself, please contact us at info@attuneconsulting.com.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online. You should check this page occasionally to review any changes. If we make any material changes we will notify you by posting the revised Privacy Policy on our Website. This helps you to always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Your continued use of the Websites, the Subscription Service, and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

12. International Transfer of Information

To facilitate our global operations, we may transfer and access Personal Information from around the world, including the United States, Asian countries. This Privacy Policy shall apply even if we transfer Personal Information to other countries.

13. Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us at info@attuneconsulting.com.