Privacy Policy

This Privacy Policy describes how Athena Labs LLC and its affiliates and subsidiaries (collectively, “Athena”, “we”, “us” or “our”) handle personal information that we collect through our online services that link to this Privacy Policy and the services provided by the executive assistants we place with our customers (“EAs”) (collectively, the “Service”), our marketing and social media activities, our communications with you, and the other activities described in this Privacy Policy.

For details regarding data collection through cookies and other technologies, see our Cookie Notice.

Individuals in the European Economic Area/United Kingdom: See our Notice to European Users for information about your personal information and data protection rights.

State Law Privacy Rights: See the State Law Privacy Rights section below for important information about rights you may have under applicable U.S. state privacy laws.

If you have questions or concerns about our use of your personal information, please contact us.

Index

You can click on the links below to jump to specific sections, but we recommend that you read this Privacy Policy in its entirety.

Scope of this Privacy Policy

Personal Information We Collect

How We Use Your Personal Information

How We Share Your Personal Information

Your Choices

Other Sites and Services

Security and Retention

International Data Transfers

Children's Privacy

Changes to This Privacy Policy

Contact Us

Notice to European Users

State Law Privacy Rights

Notice to Canadian Users

Scope of this Privacy Policy

Athena trains and supports EAs, including by providing them software tools, and matches them with Customers in order to provide the Service to users.  This Privacy Policy does not apply to:

• Personal information that we process on behalf of our enterprise customers in our capacity as a processor or service provider pursuant to our separate agreements with them; or
• Personal information about EAs and other Athena personnel or job candidates that we process in our capacity as an employer.  

We may provide additional or supplemental privacy notices to individuals at the time we collect their personal information.

Personal Information We Collect 

The personal information we collect from you, directly or indirectly, will depend on how you interact with us and with our Service.  The sources from which we collect personal information include the following:

Information you provide to us.  Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, phone number, and address.
• Professional data, such as your job title and company.
• Matching data that you provide to help us match you with an EA, such as information about how an EA can support you.
• EA workflow data, meaning any communications, content and other information that you transmit, share, or otherwise make available to your EA.  For example, any documents, files, content or other information you make available to your EA, and any communications you exchange with your EA through email, phone, text, video conference or otherwise.
• Transaction data, such as your transaction history, and any payment card or bank account information you use them to pay for the Services.  
• Communications data from your interactions with Athena, including when you send us an e-mail, complete a form through our website, or otherwise communicate with us.  Communications data does not include communications you exchange with your EA.
• Marketing data, such as your preferences for receiving marketing communications from us about our Service, products, activities, events and publications.
• Other data not specifically listed in this Privacy Policy, which we will use as described in this Privacy Policy or as otherwise made apparent at the time of collection.

Information about others.  You should not submit personal information of others to the Service unless they have given you permission to do so or you are otherwise authorized to provide the Service with their information.  

Third-party sources.  We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

• Public sources, such as public records, social media platforms, and other publicly available sources.  
• Data brokers, which provide personal information about our customers and prospective customers, such as brokers that provide sales leads or help our marketing partners associate the IP addresses and other usage data of our website visitors with email addresses and other personal information that we use to send marketing communications to them.
• Our business contacts, such as our professional contacts who share with us contact details about individuals in their networks, including prospective customers, vendors, and partners.

Automatic collection.  When you access or interact with the Service, our communications, and other online services, we, our service providers, and our advertising partners automatically log, monitor and record information about you, your computer or mobile device, and your interaction over time with the Service and our communications.  This information includes:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, Bluetooth, LTE, 3G) and location data that can be derived from it, and general location information such as city, state or geographic area that can be derived from your IP address.
• Usage data, such as pages you viewed, how long you spent on a page, videos and other content that you view, the website you visited before browsing to the Service, navigation paths between pages, information about your activity on a page, access times and duration of access, whether you have opened our emails or clicked links within them, and other functional information on Service performance (like diagnostics and crash logs).

Cookies and other technologies. Some of the information we automatically collect is captured using cookies and other technologies described in our Cookie Notice.

How We Use Your Personal Information

We may use your personal information as permitted by applicable law, including for the following purposes or as otherwise described at the time of collection:

Service delivery.  We use your personal information to provide the Service, to process your payments, and to communicate with you about our Service (including support and administrative messages).

Business operations.  We use your personal information to administer and maintain our Service and our IT systems (including monitoring, troubleshooting, data analysis, testing, system maintenance, repair and support, reporting and hosting of data), to manage the performance of our EAs, and to operate and expand our business activities.

Direct marketing.  As permitted by applicable law, we may collect and use your personal information to send you marketing emails we think may interest you or contact you by phone about our products, services or events. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Targeted advertising. Our third-party advertising partners may use cookies and other technologies to collect information about your use of the Service (including the device data and usage data described above), our communications, and other online services over time and with different browsers and devices. Our advertising partners use that information to show you ads online that they think will interest you and measure the ads’ performance. We may also share individuals’ contact data with our advertising partners to facilitate interest-based advertising on their platforms (e.g., social media platforms) to those individuals or others with similar traits.

Research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business, to develop new products and services, and to train artificial intelligence and machine learning models, except that we do not allow identifiable personal information to be used to train models controlled by third parties.  As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. As required by applicable law, we will maintain and use deidentified information in deidentified form and not attempt to reidentify it, except for purposes of testing to ensure that the information has been adequately deidentified.  We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for lawful business purposes.

EA supervision.  To the extent permitted by law, we may use your personal information to supervise and monitor our EAs for training purposes, for the compliance and protection purposes described below, and to enable workflow automations.  As part of these activities, we and the third-party service providers we work with monitor and record our EAs’ use of their Athena-furnished computers, applications and systems while providing the Service.  Please be aware that communications with your EA, as well as your EA’s interactions with your email, calendar and other tools you give your EA access to, are subject to this monitoring and recording. 

Compliance and protection.  We and our service providers may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• supervise and monitor our EAs, as described in the EA supervision section above;
• enforce the terms and conditions that govern the Service; and
• prevent, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

How We Share Your Personal Information

Except as otherwise specified in this Privacy Policy, we may share the categories of personal information listed above with the following parties and as otherwise permitted by law, described in this Privacy Policy or at the time of collection.

Affiliates.  We may share personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service Providers.  We share personal information with third parties that provide services on our behalf or help us operate the Service or our business, such as mail delivery, hosting, information technology, customer support, email delivery, marketing, artificial intelligence, and website analytics.  This also includes providers of Athena-provisioned video conferencing platforms and other business applications that EAs use to provide the Service.

Payment Processors.  Third party payment processors that collect your payment card data and other transaction data to process your payments for the Service.  For example, we may accept payment card payments through Stripe.  You can read Stripe’s privacy policy at https://stripe.com/privacy.  

Business and marketing partners.  Third parties to whom we provide certain personal information or whose products or services may be of interest to you.  We do not share EA workflow data described above with these partners.

Advertising partners. Third-party advertising companies may collect, and we may share with them, personal information for the interest-based advertising purposes described above.  Their use of personal information is subject to their own privacy policies.

Professional Advisors.  We may share your personal information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. We may share your personal information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above or as otherwise permitted by law.

Business transferees. Parties (and their advisors) to business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, us or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Other parties with your consent or at your direction.  We may share your personal information for other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

Your Choices

Privacy rights.  Residents of certain jurisdictions can exercise privacy rights with respect to the personal information we hold, as described in the Notice to European Users and State Law Privacy Rights sections below.

Opt-out of direct marketing.  You may request to opt-out of marketing emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us with your request.  If you choose to opt-out of marketing emails, you may continue to receive marketing emails until your opt-out is processed.  If you receive text messages from us, you may opt-out of receiving further text messages from us by replying STOP or CANCEL to our message.

Cookies.  Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, certain features of the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.  You can learn more about Google Analytics, one of the analytics services we use, and how to opt-out of being tracked by Google Analytics, here: https://tools.google.como/dlpage/gaoptout. 

Pixels. Most browsers and devices allow you to configure your device to prevent pixel images from loading.  To do this, follow the instructions in your browser or device settings.

Targeted ads. You may be able to limit use of your personal information for targeted advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Ad industry tools. Opting out of targeted ads from companies that participate in the following industry opt-out programs:
  
  • Network Advertising Initiative
  • Digital Advertising Alliance
  • AppChoices mobile app which will allow you to opt-out of targeted ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for targeted advertising purposes.
• Opt-out rights.  You may have the right under applicable state law to opt-out of the sharing of your personal information for certain targeted advertising purposes, as described in the State Law Privacy Rights section below.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your personal information for targeted advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do not track signals. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit All About DNT. 

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and online services you use.

Security and Retention

We employ technical and organizational safeguards designed to protect the personal information we collect.  For more information on our security measures, see https://www.athena.com/security.  However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the compliance and protection purposes described above. Factors determining the appropriate retention period for personal information include the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process the personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it (so that it is no longer personally identifiable with you) or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will isolate your personal information from any further processing, employing security safeguards designed to protect it until deletion is possible.

International Data Transfers

We are headquartered in the United States, and we and our service providers may store personal information in and process it from the United States and other countries.  These countries may have data protection laws that are not as protective as those where you live.

Children's Privacy

Our Service is not intended for anyone under the age of 18.  If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.  If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time.  If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).  In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your use of the Service and interaction with our business.

Contact Us

If you have any questions or comments concerning this Privacy Policy, please email us at privacy@athena.com.

Notice to European Users

The information provided in this notice applies only to individuals in the United Kingdom (“UK”), the European Economic Area (“EEA”) and Switzerland (we collectively refer to these countries as “Europe”).

The personal information that we collect from you is identified and described in greater detail in the section of the Privacy Policy entitled Personal information we collect.

Controller. Athena Labs LLC is the controller of your personal information described in this Privacy Policy. See the contact us section above for contact details.

Legal bases for processing. European data protection law requires that we have a “legal basis” for each purpose for which we process your personal information. Depending on the purpose for collecting your information, we may rely on one of the following legal bases:

• The processing is necessary to perform a contract that we are about to enter into, or have entered into, with you (“Contractual Necessity”).
• The processing is necessary to pursue our legitimate interests or those of a third party and we are confident that your privacy rights will be appropriately protected (“Legitimate Interests”).
• We need to comply with laws or to fulfill certain legal obligations (“Compliance with Law”).
• We have your specific consent to carry out the processing for the purpose in question (“Consent”). Generally, we do not rely on Consent as a legal basis for processing your personal information other than in the context of direct marketing communications where required by applicable law or where you voluntarily provide your EA with sensitive or special categories of personal data described below.

The table below identifies the legal bases we rely on in respect of the relevant purposes for which we use your personal information. For more information on these purposes and the categories of personal information involved, see the section in the Privacy Policy entitled How we use your personal information.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We do not require collection of sensitive or special categories of personal data as defined under European privacy laws (e.g., information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, biometrics or genetic characteristic, criminal background, or trade union membership) to provide the Service.  However, users may voluntarily provide such data to us.  If you provide us with sensitive personal data, you consent to our processing and use of such data in accordance with this Privacy Policy.  If you do not consent to our processing and use of sensitive personal data in accordance with this Privacy Policy, do not submit such data to us.

Your rights. European data protection laws give individuals in Europe the following rights regarding their personal information:

• Right of access. You can ask us to provide you with information about our processing of your personal information and give you access to your personal information.
• Right to rectification. If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.
• Right to erasure. You can ask us to delete or remove your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
• Right to restrict processing. You can ask us to suspend the processing of your personal information:
  
  • if you want us to establish the information’s accuracy;
  • where our use of the information proves to be unlawful but you do not want us to erase it;
  • where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims;
  • if you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.‍
• ‍Right to object. You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and you believe it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes.‍
• Right to data portability. You have the right, in certain circumstances, to ask us to provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. ‍
• Right to withdraw consent at any time. Where we are relying on consent to process your personal information, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Exercising those rights. Some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal information or where certain exemptions apply. If we decline your request, we will tell you why, subject to legal restrictions.

To exercise any of these rights, please contact us. We may request specific information from you to help us confirm your identity and process your request.

Your right to lodge a complaint with your supervisory authority. If you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the EEA:  The contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

For users in the UK:  The contact information for the UK data protection regulator is below:

The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

International data transfers. We may transfer your personal information to a country outside of Europe that is not recognized as providing an adequate level of protection for personal information by the relevant government body.  In these cases, we take appropriate safeguards to ensure your personal information remains protected in accordance with this Privacy Policy and applicable laws by entering into appropriate data transfer mechanism permitted under Article 46 of the GDPR / UK GDPR (as applicable), such as the European Commission's Standard Contractual Clauses or the UK International Data Transfer Addendum (as applicable). A copy of our data transfer mechanism can be provided on request.

State Law Privacy Rights

This section applies to residents of certain U.S. states with privacy laws applicable to us that grant their residents the rights described below (such laws, the “State Privacy Laws”). If you are not a resident of a state with a State Privacy Law, you may not be able to exercise these rights.

For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the State Privacy Laws, but does not include information exempted from such laws.

Your privacy rights. You may have the rights listed below.  The rights described below are not absolute, and, in certain cases, we may decline your request as permitted by law or where the laws in your state do not afford you these rights.  

• Right to information/know. You can request confirmation about whether or not we have collected your personal information, and, in certain cases, information about the categories of personal information that we have collected, the categories of sources from which we collected personal information, the business or commercial purpose for collecting, sharing and/or selling personal information, the categories of third parties with whom we share personal information, the categories of personal information that we sold, shared or disclosed for a business purpose, and the categories of third parties with whom the personal information was sold, shared or disclosed.  The specific information that may be requested varies depending on your state of residence.
• Right to access. You can request a copy of certain personal information that we have collected about you in a portable format that can be transmitted to another entity.
• Right to delete. You can ask us to delete certain personal information that we maintain about you.
• Right to correct. You can ask us to correct inaccurate personal information that we have collected about you.
• Right to opt out of:
  
  • Processing/sharing for targeted advertising purposes.  You can opt out of certain sharing and other processing of personal information for the targeted advertising purposes described in the targeted advertising section above.
  • Sales of personal information.  You can opt out of “sales” of your personal information as defined by applicable state privacy laws.  We do not “sell” personal information as defined in State Privacy Laws, except to the extent the use of targeted advertising services described above constitutes a “sale” under such laws.
  • Profiling.  You can request to opt-out of the processing of personal information for the purposes of “profiling” as defined in State Privacy Laws that will have a legal or similarly significant effect on you.  We do not currently engage in such profiling.
• Right to nondiscrimination. You are entitled to exercise the rights described above free from discrimination or retaliation as prohibited by State Privacy Laws.
• Right to request a list of third parties to whom we have disclosed or sold your personal information.  Depending on your state of residence, you can request a list of third parties to which we have disclosed or sold, or may sell, your personal information.  We may provide you a list of the third parties to which we have disclosed or sold personal information of any resident in the relevant state, where permitted by the relevant State Privacy Law.

How to exercise your rights. 

• Information/know, access, correction, deletion, list of third parties to whom we have disclosed or sold your personal information.  You can exercise the privacy rights described above by submitting a request to privacy@athena.com. The rights described above are subject to limits and exemptions and in certain cases we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.  
• Opt out of sharing/selling/processing for targeted advertising.  You can request to opt out of this activity by emailing us at privacy@athena.com or enabling the Global Privacy Control (GPC) signal from your browser before you visit our site.  Learn more at https://globalprivacycontrol.org.  Submitting a GPC signal request may only apply to the browser and the device from which the request is submitted, and the request may not stop sharing/selling/processing for targeted advertising that is not facilitated by cookies or other web technologies.
• Appeal.  You can ask to appeal any denial of your request in the same manner that you may submit the request.  You must submit your appeal within 45 days of the denial of our request or within any longer timeframe provided by the State Privacy Law in the state where you live. When sending your appeal, please include your name, contact information, details of the original request, the date of our response, and the reasons you believe the denial should be reconsidered. We will review your appeal and respond in writing within the timeframe required by the applicable State Privacy Law. If we deny your appeal, we will explain why.
• Revoke consent.  When we request your consent to process your personal information, you can contact us to revoke your consent.
• Verification of identity. We may need to verify your identity to process your requests to exercise your rights to information/know, access, deletion, and correction, and we reserve the right to confirm your residency. To verify your identity, we may require you to provide information we can match against information we may have collected from you previously, confirm your request using the email address we have on file, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.
• Authorized agents. Your authorized agent may make a request on your behalf through the same channels described above.  We may ask you and/or your agent to take steps permitted by law based on the nature of your request to verify your agent’s authority.

Sensitive Data.  With the exception of your payment details described in this Privacy Policy, we do not require you to provide us with data considered “sensitive” under State Privacy Laws. However, it is possible that users may voluntarily provide sensitive data to us. Do not provide us with this sensitive data if you do not consent to our handling of it as described in this Privacy Policy. By providing this sensitive data you affirmatively confirm that you freely give your informed, unambiguous agreement to our use and disclosure of it for the purposes explained or apparent at the time of collection or otherwise as described in this Privacy Policy. You can contact us to revoke this consent at any time but we will not be able to provide services or grant requests that require it.

Additional information for California residents. While you should read this Privacy Policy in its entirety, the following summarizes our practices currently and during the past 12 months regarding the categories of personal information that we collect and how we use them:

• Sensitive personal information. We do not use or disclose sensitive personal information for restricted purposes that California residents have a right to limit under the CCPA.
• Sources and purposes. We collect all categories of personal information from the sources described in the Personal information we collect section above, use them for the business/commercial purposes described in the How we use your personal information section above, and we disclose them for the business purposes described in the How we share your personal information section above.
• Children.  Although our Service is not intended for children under 16 years of age, we are required to inform you that we do not have actual knowledge that we have sold the personal information of California residents under the age of 16.
• Retention.  We retain personal information as described in the Security and Retention section above.
• Collection and disclosure. The chart below describes the personal information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of external parties to whom we disclose it. The terms in the chart refer to the data types described above in the Personal information we collect section and the external parties described above in the How we share your personal information section. Information you voluntarily provide to us, such as in emails or free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to professional advisors, authorities and others, and business transferees as described above in the How we share your personal information section of this Privacy Policy. 

Notice to Canadian Users

If you are a resident of Canada, you have certain rights regarding your personal information under applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial privacy legislation where applicable. These rights include the following:

Right to Access: You have the right to request access to the personal information we hold about you, including information about how we use and disclose it.

Right to Correction: You have the right to challenge the accuracy and completeness of your personal information and request that we correct any information that is inaccurate, incomplete, or outdated. If we make corrections to your personal information, we will also communicate those amendments to any third parties to whom we have disclosed the incorrect information, where appropriate.

Right to Withdraw Consent: If we have requested your consent for the collection, use, or disclosure of your personal information, you may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Upon withdrawal of consent, we will cease processing your personal information for those purposes, though we may retain certain information where we have a legal obligation or legitimate business purpose to do so.

Right to Request Deletion: You may request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

Right to File a Complaint: If you have any concerns about our compliance with applicable Canadian privacy laws, you may make a request as set out below.  We will address any complaints as appropriate and in accordance with the law.  If you believe we have not complied with applicable Canadian privacy laws, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner where applicable.

How to Exercise Your Rights: You can exercise your privacy rights described above and any others under Canadian and provincial privacy laws, by submitting a request to privacy@athena.com. The rights described above are subject to limits and exemptions and in certain cases we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.