Security & Privacy Policy

This web site is owned and operated by Turner Change Management Inc

The https://thinktransition.com/ (the “Site”) is operated by Turner Inc. (also known as “Turner”,us”, or “we”).  At Turner, the privacy of our users is of extreme importance to us.  Whether you are participating in our online educational resources or sharing feedback, we want to make sure that the personal information that you disclose to us remains secure.  That is why we have developed this Privacy Policy, which governs how we collect, use and disclose your personal information (the “Privacy Policy”).

This page contains the Privacy Policy for the Site, as well as for any related subdomains and subsidiary sites operated by Turner (collectively, the “Sites”), and for any online services offered by Turner, including but not limited to the education program services, consulting services in the field of transition management and change management, coaching, change maps, audits and assessments, books, manuals, guides, handbooks, worksheets, webinars, podcasts, blog and events offered by Turner (together with the Sites, the “Service”).

By using the Service, you consent to the collection, use and disclosure of your personal information by Turner in accordance with this Privacy Policy.  You may choose not to provide us with your personal information.  However, if you make this choice we may not be able to provide you with the product, service, or information that you have requested.

  1. Definitions

For the purposes of this Privacy Policy, the following words have the following meanings:

“collection” means the act of gathering, acquiring, storing, retrieving, recording or obtaining personal information from any source, including third parties, by any means.

“consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative, such as a parent, guardian, teacher or group leader.  Express consent can be given orally, electronically or in writing.  Implied consent is consent that can reasonably be inferred from a user’s action or inaction.

“disclosure” means making personal information available to a third party.

“employee” means an employee of Turner, and for the purpose of this Privacy Policy only, includes agents, independent and other contractors performing services for Turner.

“personal information” means information about an identifiable individual, and includes aggregated information that cannot be associated with a specific individual. 

“processing” or “process” means any operation performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“registered user” means a person who has registered for the Service, as well as a Subscribing Organization that has registered for the Service.

“Subscribing Organization” means a company, entity or organization that has registered for the Service.

“third party” means an individual other than the user, or the user’s agent, or an organization outside Turner or a Subscribing Organization.

“use” means the treatment, handling and management of personal information by and within Turner.

“user” means a person who uses and accesses the Service in any manner, including merely accessing or viewing the Sites, and includes a registered user, visitor, customer or browser. Such a person is referred to in this Privacy Policy as “user” or “you”.

  1. Collection

Turner may collect any or all of the following personal information if the information is reasonably required to provide the services accessed or requested by you:

(a)       information that you provide when you become a registered user or otherwise complete forms on the Sites, such as your name, email, telephone number, postal address, age;

(b)       information that you provide to Turner when you subscribe to the Service;

(c)       information you provide when you access the Site such as your geographical location, browser type and version, operating system, length of visit, page views and website navigation paths;

(c)       your correspondence with Turner employees, including any questions, concerns or comments you may have about the Service or problems that you report;

(d)      details of your requests made through the Service.

Turner does not collect information related to method of payment such as a credit or debit card number. All purchases of Turner products and services will be directed to and handled by third parties such as PayPal. You will be bound by the privacy policies of these third party sites.

  1. Processing and Retaining Personal Information

Turner may process your personal information about your use of our Site and Services. Turner does not collect IP addresses and any IP addresses are loaded anonymously to the Site. Personal information may be processed for the purposes of analyzing users’ use of the Site. The legal basis for this processing is Turner’s legitimate interests, including monitoring and improving its website and services. Turner will not retain personal information longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.

  1. Purpose of Collection and Use of Personal Information

Turner collects your personal information and will use your personal information as is reasonably required for the following purposes:

(a)       to subscribe to  its blog;

(b)       to improve users’ experience of the Sites (in relation to user feedback);

(c)       to provide the ongoing products, services or information that you request;

(d)       to respond to questions, comments, requests, or complaints that you submit to Turner;

(e)       to process purchases, provide invoices and to ship products;

(f)        to assist you in tracking your order;

(g)       to provide the installation and/or maintenance services that you request;

(h)       to track communications with you;

(i)         to analyze use of the Service and to improve the Service;

(j)         to improve users’ experience of the Service, including to customize website settings;

(k)       to detect and protect against fraud and error;

(l)         to guide Turner in selecting new products to be offered through the Service;

(m)      to promote existing products by posting the testimonials that you submit, if any;

(n)       to send emails, newsletters, regular mail or other communications you have consented to receive from Turner;

(o)       to provide Service-related announcements or notifications to you;

(p)       to fulfill a purpose that we disclose to you when we request your personal information; and/or

(q)       to meet legal and regulatory requirements.

Turner staff 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.  Personal information will only be collected and used by authorized staff in a manner consistent with the activities of Turner.

  1. Disclosure

Turner may disclose your personal information to:

(a)       its employees, agents, partners and service providers as is reasonably necessary to enable these parties to perform a business, professional or technical support function for Turner;

(b)       a person who, in the reasonable judgment of Turner, is seeking the information as your agent;

(c)       a third party or parties, where you consent to such disclosure or the disclosure is required by law; and

(d)        in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of Turner’s assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

  1. Safeguarding Your Personal Information

Turner is committed to safeguarding your personal information. Turner uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction regardless of the format in which it is held. The methods of protection and safeguards used by Turner include, but are not limited to, locked filing cabinets, need-to-know access and technological measures, including the use of passwords, encryption and firewalls. While Turner cannot guarantee that risks such as loss, theft, unauthorized access or disclosure of personal information will not occur, Turner will make every effort to prevent such unfortunate and unforeseen occurrences.

Turner will retain the personal information of a registered user for one (1) year from the date of registration for the Service after which point Turner will dispose of or destroy in a secure manner the personal information of a registered user unless required to maintain for a longer period to meet legal and regulatory requirements.  This does not apply to personal information of a registered user who has subscribed to receive commercial electronic messages from Turner.  Turner will retain the personal information from a registered user subscribed to receive commercial electronic messages until such time as the registered user unsubscribes in accordance with Section 13 of the Privacy Policy.

Turner takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.  Turner also ensures that its employees with access to personal information are made aware of the importance of maintaining the confidentiality of personal information. Finally, Turner protects personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

  1. Accuracy

Turner is committed to keeping your personal information as complete, up-to-date and accurate as is necessary for the purposes for which it is to be used. Turner will promptly correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, Turner will transmit amended information to third parties having access to the personal information in question. Upon request, Turner will provide you with a reasonable opportunity to review the personal information in your file to review its accuracy. Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.

Also upon request, Turner will provide an account of the use and disclosure of your personal information within thirty business days after the date of the request and, where reasonably possible, will state the source of the information. In providing an account of disclosure, Turner will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list. Upon request, Turner will provide personal information in a structured, commonly used and machine-readable format within thirty business days after the date of the request.

  1. Complaints

Turner will promptly investigate all complaints concerning our compliance with the Privacy Policy and our dealings with your personal information.  If a complaint is found to be justified, Turner will take appropriate measures to resolve the complaint, including, if necessary, amending our policies and procedures. You will be informed of the outcome of the investigation regarding your complaint.

  1. Breach

In the event of a breach of personal information, Turner will promptly inform all users affected by the breach within 72 hours of Turner discovering the breach. In the event the breach will affect your rights and freedoms, we will inform you about the breach without undue delay.

 

  1. Withdrawing Consent

You may withdraw your consent to the collection, use or disclosure of your personal information by Turner at any time, subject to legal or contractual restrictions and reasonable notice.  In certain circumstances, your withdrawal of consent will result in the inability of Turner to continue providing aspects of the Service to you. Please contact Turner for more information regarding the implications of withdrawing consent.

  1. Non-Personal Information

Non-personal information is information that does not identify you and which we are unable to connect to other information in order to identify you. Turner may collect any or all of the following non-personal information:

(a)        The Service uses Google analytics, a web analytics service provided by Google, Inc. (“Google”).  Google analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the Service. The information generated by the cookie about your use of the Service (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the Service, compiling reports on Sites activity for the Sites’ operators and providing other services relating to website activity and Internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.  Google will not associate your IP address with any other data held by Google.  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 Service.  By using the Service, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Google currently offers a free Google analytics opt-out tool for Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera which is available at https://tools.google.com/dlpage/gaoptout.

(b)       We may also use additional analytics programs from time to time to process non-personal information about you.

We make no attempt to link this non-personal information with the identity of individuals using the Service. Non-personal information may be permanently archived for future use in any manner whatsoever by Turner.

  1. Inquiries

To submit an inquiry, complaint, request a review of your personal information, correct or update your personal information, withdraw your consent or request more information or additional copies of the Privacy Policy contact:

Turner Change Management Inc.

Telephone No.: 204-415-4278

Contact us 

  1. Unsubscribe

If you no longer wish to receive commercial electronic messages from Turner regarding our new products or services, promotions or other similar communications, you may unsubscribe here . Please note that, after you unsubscribe, Turner may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications, or to provide information that Turner is legally obligated to provide you. Please note, personal information provided to subscribe to our commercial electronic messages is stored on MailChimp. You will be bound by the privacy policies of these third party sites.

  1. Privacy Policy Changes

To accommodate changes in our services, changes in technology and legal developments, this Privacy Policy may change over time without notice to you. We may add, change or remove portions of the Privacy Policy when we feel it is appropriate to do so. We encourage you to review our Privacy Policy periodically. Each time you submit personal information or use the Service you agree to be bound by terms of the Privacy Policy which is then current. Whenever we update the Privacy Policy, we will change the date below to indicate when the changes were made.

 

Date: May 23, 2018

Security

We appreciate your interest and your business and we respect and guard your privacy. In order to complete your order or to satisfy your request for information, you will be asked to provide certain personal information. Safeguards are in place to ensure the security and privacy of your information. These safeguards are detailed below.

The staff at Turner Change Management never see your credit card information or financial details – this is all handled through Paypal for your security and privacy.

Secure Web Site Browsing

In order to be sure that information transferred between your browser and our server is secure, it is important to be aware of the security information available to you through your browser.

Data Collection

In several areas of our site, we ask you to provide information by filling out and submitting an online form. The information we collect is never used personally, rather it’s used to improve our web site (in the case of customer feedback), to mail out our opt-in newsletters or to notify consumers about updates to our Web site (in the case of subscription forms), and for special notices to our customers who have signed up for our educational offerings. As a strict policy, we do not sell, trade, rent or otherwise share your e-mail address with any other company or third party.

Materials Policy

All information provided on this web site is for educational and informational purposes only and is protected by intellectual property, copyright, trademark and other proprietary rights and laws. Any distribution or reproduction of this material (in whole or in part) without permission is prohibited. If you are interested in distributing this information within your organization, please contact Dr. Dawn-Marie Turner or call at 204.415.4278.



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