B. WHAT IS PERSONAL INFORMATION?
C. WHAT PERSONAL INFORMATION DO WE COLLECT?
contact and identification information, such as your name, address, telephone number, e-mail address, date of birth, and gender;
personal information in connection with your request for certain products or services that you seek from us;
additional service-related information concerning the products or services that we provide to, or receive from, you; and
business relationship information, including information related to your agreements, preferences, advisors, and suppliers, feedback and information requested by or provided to you.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. We may also collect information related to our media, investor and public relations activities, and information related to our interactions with financial and other advisors.
As a general rule, FIGR collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We may use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our other business purposes, such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our website.
In connection with the foregoing, we may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.
In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by, for example:
Our website may contain links to other websites that may be subject to less stringent privacy standards. If you click on a link to such a third party website, a third party may also place a cookie on your hard drive. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. FIGR is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
Please visit www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information, visit tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on, and visit www.google.com/settings/ads/ to adjust the settings for your Google account.
D. WHY DO WE COLLECT PERSONAL INFORMATION?
FIGR collects personal information to enable us to manage, maintain, and develop our operations, including for example:
E. HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your personal information:
We may also use information we collect about you in the aggregate for statistical purposes, for example to identify the demographics of our consumers. We may publish and/or disclose aggregate statistics to third parties but never any identifiable personal information (except in accordance with this Policy).
Please note: Our website may provide you with an opportunity to interact with others and share your thoughts, information, content and materials (collectively, “User Generated Content”). You are solely responsible for the User Generated Content that you post on our website. Unless explicitly stated otherwise, any User Generated Content that you post onto our website (including your username) will be made publicly available. As such, do not post any personal information onto our website (such as your name or address) if you wish to remain anonymous.
Finally, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
F. WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?
MANAGING OUR BUSINESS
For example, we may share your personal information from time to time with our third party information technology, data processing and payment processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in Canada and the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.
Your personal information may be disclosed:
As above, Canadian law permits or requires the use or sharing of personal information without consent in specific circumstances.
G. YOUR CONSENT IS IMPORTANT TO US
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our email@example.com. All communications with respect to such withdrawal or variation of consent should be in writing.
I. HOW IS YOUR PERSONAL INFORMATION PROTECTED?
FIGR will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.
The security of your personal information is important to us, please advise firstname.lastname@example.org immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
J. UPDATING YOUR PERSONAL INFORMATION
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
K. ACCESS TO YOUR PERSONAL INFORMATION
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact email@example.com. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact firstname.lastname@example.org.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
L. INQUIRIES OR CONCERNS?
You may potentially be able make a complaint under the Ontario Personal Health Information Protection Act to the Information and Privacy Commissioner of Ontario. If so, complete the applicable form found here: www.ipc.on.ca/privacy/filing-a-privacy-complaint/. If you reside in another jurisdiction, you may potentially file a complaint with the relevant authority in that jurisdiction.