The ATJustice Business Code of Ethical Conduct is based on the general principle that businesses should treat members of the general public in a fair, ethical and helpful manner, consistent with how most employees at the business themselves like to be treated.  Businesses may voluntarily sign on to the ethical conduct code if they comply with all of the following five principles and the associated guidelines under each principle:

Principles & Guidelines

1. Protection of User Personal Information.  The Company agrees to take care to protect the personal information of its customers.  Personal information includes any information that reveals, or can be used to ascertain, a person’s name, address, email address, phone number, social security number, account number, credit card information, demographic information, biometric information, financial information, or other sensitive information.  This protection must include:

1. Taking reasonable and customary measures to secure the information and protect it from data breaches and hacking attempts.

2. Limiting access to the information to company employees who need to use it for the purposes for which it was collected.

3. Not selling or sharing customer data with other entities without the customer’s explicit advance permission, and providing an easy mechanism for customers to “opt out” of such data sharing at any time.

4. Not inputting customer data into versions of any ai engine that may use that data for training the ai engine and/or otherwise may leak that data to other users of the ai engine.

5. Not retaining the customer information longer than needed for the purpose for which it was collected– and under no circumstances for more than 2 years after the last contact with the customer.

6. Promptly notifying customers in the event of a data breach that may result in any of their information being leaked or shared, and promptly taking reasonable steps to mitigate and remedy the results of any such breach.

7. Actively taking steps to discourage, investigate and pursue all attempts to defraud the Company’s customers.  For example, if a customer reports that someone contacted them posing as a Company representative, it is not sufficient simply to direct the customer to law enforcement authorities– the Company must be proactive about preventing and addressing such fraud and pursuing anyone engaged in such fraud. This may include the Company working with law enforcement authorities, as well as providing warnings to other customers about active schemes specifically targeting Company customers. 

2. Responsiveness to Customer’s Attempts to Contact the Company.  The company agrees to remain accessible to customer communications, including giving customers easy access to one or more human representatives to try to address their concerns.  This accessibility must include:

1. Having a “contact us” option on the company website that provides both an email address and a phone number that customers can use to make contact.

2. Promptly responding to written communications, in no event more than two business days after an inquiry.  Where it may take more than two business days to investigate, the original communication should at least be acknowledged within two business days.

3. Having humans “in the loop”, whom customers can easily access if any automated or ai-driven response system is not meeting the customer’s needs.

4. An easy mechanism for customers to download a transcript of the communication chain between the customer and the Company, should the Company use a written communication platform other than email.

5. Not preventing communications in instances where customers do not know, or do not have access to, their account number, complaint number, or username and password, or where the communication does not fit into a preset list of allowed types of communications or issues (unless an “other” option is also provided).

6. If the Company contact phone number ties into an automated response system, having the customer be able to ask for and be channeled toward a human representative within the first 3 minutes of their call being answered, not requiring more than 3 inputs or requests from the customer to be channeled to a human representative, and not limiting access to the human representative to those who already know their account number or whose concern or communication necessarily fits into a preset list of allowed types of communications or issues (unless an “other” option is also provided).  The human telephone access must be available at least from 9 am to 4 pm, Monday through Friday, in the time zone(s) where the Company regularly conducts business.

7. Not putting customers on “hold” for an average of more than 10 minutes, without providing an option that the customer can opt to be called back as soon as a representative becomes available.

8. Taking reasonable steps to ensure that customers are not disconnected by the company in the midst of a call, and/or getting the customer’s phone number and calling them back promptly should there be any such accidental disconnection. 

1. Dispute Resolution.  The Company needs to make readily available to customers mechanisms for reasonable resolution of customer complaints and disputes without forcing customers to resort to burdensome and expensive lawsuits or arbitration procedures. 

1. What is reasonable may depend on the magnitude of the claim but should be set up based on principles of fairness, minimizing burden and expense for the customer, and maximizing the speed of the resolution.

2. Customers should not be left at the mercy of only a single Company representative, but should have the ability to access a supervisor if the initial representative cannot resolve the matter to the customer’s satisfaction.

3. Recognizing that companies need to be protected as well, the Company may include safeguards to protect itself from false claims or vexatious claimants and to help ensure that customer representatives are treated with respect and without abuse.

1. On-line Offer Fairness.  When offering goods or services on-line, the Company needs to make available to customers, early in on-line communications, and conspicuously, all of the important details of the offer, including the financial details.

1. If a price is advertised, and there are mandatory add-in costs beyond the advertised price (e.g. “convenience fees,” hotel “resort charges,” etc.), that must be disclosed on the first page or screen once the customer has clicked on the offer.

2. If shipping charges are extra, that should be disclosed up-front, including the amount of any “handling” charges.

3. If a payment is “non-refundable” that must be conspicuously disclosed before payment is accepted.  If the charge is refundable, but the Company imposes any time limitation, “restocking fee,” or other limit on the refundability, that must be disclosed in advance as well.  

4. Where there will be a delay between payment and access or delivery, the customer must be informed, before customer payment is accepted, of the likely delay (e.g. estimated delivery date, or number of delivery days, or the date that an on-line service or on-line access will be provided). 

5. Where there is an unanticipated delay after payment in fulfilling any customer order, the Company must immediately notify the customer and provide an opportunity for the customer to cancel the order for a full and immediate refund.

6. Where there are contraindications or exclusions for particular products or services (e.g. age, size or weight limits to use certain products, food or beverage restrictions associated with taking any medications or supplements) those must be disclosed before payment is accepted.

7. The Company may not substitute similar products, or products that differ in any manner from those originally advertised and/ordered, without advance notice to the customer and an opportunity for the customer to cancel the order for a full and immediate refund.

8. Where an offer is cancellable/refundable, the mechanism for cancelling must be conspicuous, easily accessible to the customer, and easy to execute (e.g. not requiring detailed actions), such as filling out long forms or including account or order numbers that may not be readily available to the customer.

5. Ongoing Payments and/or Contacts. When customers are invited to subscribe to ongoing communications, payments or auto-renewals, there must be an easy and accessible mechanism for unsubscribing, opting out, and/or cancelling.

1. In the case of emails, texts, or other communications, the mechanism for opting out needs to be included on each communication, and at least as simple to execute as the original mechanism for signing up (e.g. through a “stop” or “unsubscribe” message or link).  Users should not have to remember and use any username or password in order to unsubscribe.

2. In the case of auto-renewals, the customer needs to be given at least 30 days notice, and an easy mechanism to cancel, before any new charges are imposed or auto-billed.