Privacy Policy

At Innovana, we value your business and respect your right to privacy. We want you to feel secure about any private information that you provide to us, and have therefore outlined our Privacy Policy below. This Privacy Policy has been adopted by Innovana and by those organizations using the Innovana trademark under license from Innovana (referred to collectively as “Innovana”), in order to demonstrate their commitment to the protection of individual privacy. The following discloses the personal information collection, use and disclosure practices of Innovana.

For the purposes of this Statement, “Personal Information” means information that is personally identifiable to individuals. “Non-Identifiable Information” means information that cannot be associated with or traced back to specific individuals with any certainty.

HOW AND WHEN INNOVANA COLLECTS PERSONAL INFORMATION

Innovana collects personal information from individuals on a voluntary basis through surveys, contest entry forms, registration forms, questionnaires and transaction documents both online and offline. The personal information includes contact information (name, mailing address, e-mail address, telephone number, etc.), demographic information, household information, preference information and transaction-related information.

USE OF PERSONAL INFORMATION BY INNOVANA

Innovana uses personal information that it collects for the following:

  1. to communicate with individuals;
  2. to understand individual needs;
  3. to promote and offer products, services and special offers that meet individual needs or that might be of interest to individuals based on information provided and approved by Innovana;
  4. to provide individuals with products or services that are requested or that is part of Innovana’s ongoing service with its customers; and
  5. to conduct, process and complete transactions with Innovana customers.

The information also enables us to develop and customize our products and services to better meet the needs and preferences of customers. Innovana may, from time to time, contact individuals by electronic format, regular mail or telephone for any of the purposes set out above.

DISCLOSURE OF PERSONAL INFORMATION BY INNOVANA

Innovana does not sell, rent or trade personal information that it collects. Innovana will not knowingly disclose personal information to any third parties except in the following circumstances:

  1. when Innovana has received consent to do so or under limited circumstances, specifically described at such time as personal information is collected;
  2. when Innovana, in good faith, believes the law permits or requires such disclosure;
  3. to affiliated and associated companies within Innovana and only for the purposes as described herein – these affiliated and associated companies and their respective employees are restricted from using the personal information for any other purpose other than as described herein;
  4. to its agents, professional advisors, promotional and marketing agencies, and to any other third parties in order to complete transactions, to process data and to service customers – these third parties and their respective employees are only provided with such personal information as is necessary to perform the services for which they have been contracted and are restricted from using the personal information for any other purpose other than as described herein; and
  5. in the event of the sale of Innovana, personal information may be one of the transferred business assets.

RETENTION OF PERSONAL INFORMATION BY INNOVANA

At such time as personal information is no longer required for the purposes stated in this Privacy Statement or other statutory requirements, such personal information will be made non-identifiable or destroyed.

COLLECTION, USE AND DISCLOSURE OF NON-IDENTIFIABLE INFORMATION

Innovana collects and uses non-identifiable information to assess the effectiveness of website content and traffic. This allows Innovana to improve the quality of visits to websites by streamlining visitors’ ability to navigate these sites and develop featured programs and content that will be of interest to visitors. Aggregate non-identifiable information is used to perform statistical analyses of the collective characteristics and behaviour of individuals, and to measure demographics and interests.

COOKIES AND SIMILAR TECHNOLOGIES

We may collect information using “cookies” or similar technologies (altogether, “Cookies”). Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Website.

We use two broad categories of Cookies:

  1. first party Cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Website; and
  2. third party Cookies, which are served by service providers on our Website, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.

Our Website uses the following types of Cookies for the purposes set out below:

Local Storage: This technology allows our Website to remember choices you make when you use our Website. The purpose of this is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Website.

Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Website and how users use our Website. The information gathered may include the number of visitors to our Website, the websites that referred them to our Website, the pages they visited on our Website, what time of day they visited our Website, whether they have visited our Website before, and other similar information. We use this information to help operate our Website more efficiently, to gather broad demographic information, monitor the level of activity on our Website, and improve the Website. We use Google Analytics for this purpose. Google Analytics uses its own cookies.

You can typically remove or reject Cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept Cookies until you change your settings.

WEBSITES OPERATED BY THIRD PARTIES

Websites operated by Innovana may contain links to other websites that may collect personal information. This Statement does not extend to the data collection, disclosure, use and retention practices of such third parties and Innovana does not assume any responsibility for the privacy practices, policies or actions of such third parties. Individuals should read the privacy policies of such third parties, and make an informed decision about whether or not to visit such websites and/or provide personal information to such third parties based upon their privacy practices and individual discretion.

SAFEGUARDING PERSONAL INFORMATION

Innovana has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. Any information transmitted via the Internet, however, may be intercepted by third parties. Innovana does not assume any liability for interception, alteration or misuse of information transmitted over the Internet. Innovana employees are restricted from using and disclosing personal information collected by Innovana other than in accordance with this Statement.

ACCESSING PERSONAL INFORMATION

Individuals have the right to access, verify and correct or amend all of their personal information collected by Innovana. Innovana believes that it is imperative that personal information be as accurate, complete and up to date as is necessary for the purposes for which it is collected. Accordingly, to help Innovana keep personal information as current as possible, Innovana encourages individuals to amend inaccuracies and make corrections in their personal information collected by Innovana as often as necessary. To access, verify and correct or amend personal information, please email info@innovana.com.

HOW TO FILE A COMPLAINT

To file a complaint with Innovana concerning the collection, use and/or disclosure of personal information, please email info@innovana.com. All complaints will be investigated by Innovana as soon as is practical in the circumstances. Individuals will be notified of the outcome of the investigation of complaints and will be notified of any relevant steps taken or to be taken as a result of a complaint.

THE CHOICE TO PROVIDE PERSONAL INFORMATION OR TO RECEIVE CERTAIN INFORMATION AND PROMOTIONAL MATERIALS

Individuals always have the choice whether or not they wish to supply Innovana with personal information. Individuals wishing to ‘opt-out’ of receiving certain informational and promotional materials from Innovana or who otherwise object to the collection, use and disclosure policies as provided under this Privacy Statement, are asked to contact the Privacy Officer at Innovana by email at info@innovana.com.

Opt-out opportunities are also provided in other circumstances such as in certain promotional mailings. Individuals are reminded that the decision to withhold personal information or to object to the use and/or disclosure of personal information as provided in this Privacy Statement or in any agreement between such individuals and Innovana, may, in certain instances, limit their ability to complete purchases of Innovana products and services and limit their ability to access or take advantage of certain promotions and features. Your personal information is obtained and used only with your consent, which may be expressed or implied depending on the circumstance.

PERSONAL INFORMATION REQUIRED AS PART OF PURCHASE TRANSACTION

Additional personal information, in excess of what is outlined in this Statement, may be required to facilitate the successful completion of a purchase and sale agreement between Innovana and a purchaser. Where additional personal information is required or collected, the agreement of purchase and sale will outline the conditions on which such personal information is collected, retained, and/or distributed. When a conflict exists between this Statement and the applicable agreement of purchase and sale, the agreement of purchase and sale will govern.

EFFECTIVE DATE OF STATEMENT

This Statement has been adopted by Innovana as of July 2022. Revisions to the Statement will be posted on www.innovana.com as soon as practical.