FIDELITY RETAIL INC.. (“FIDELITY RETAIL,” “we,” “us,” or “our”) is committed to safeguarding the privacy of registered users of the FIDELITY RETAIL platform. This Notice informs you how FIDELITY RETAIL collects, uses, secures and shares your personal information when you use our platform and related services as a customer (“Services”).

If you do not feel comfortable with any part of this Notice, please immediately cease using our Service. This Notice may change from time to time. If we make a change to this Notice that we believe materially affects how we process your personal information or reduces your rights, we will provide you with notice.

 

1. Collected Information: Personal information is generally any information that identifies you or makes you identifiable such as your name, IP address or user preferences. We may collect, store and use the following personal information from you in relation to the Services (“Collected Information”): 
   1. Information You Voluntarily Provide. To register with us on the platform or subscribe to our website services and/or email notifications, you must provide us with your first and last name, email address, and phone number. In order to provide our Services, we are required to collect information about your transactions with us in relation to the Services, including information relating to any purchases you make of our goods or services. We collect: first and last name, title, job position, employer, contact information (company, email, phone, physical business address), ID data, professional life data, personal life data. You may also provide additional information in the setup and ongoing use of the Service. We collect any information that you provide to us when you contact us for customer service, technical support, or for any other purposes.
   2. Information You Automatically Provide. When you use the Service, we automatically record information from your device, its software, and your activity using the Service (“Log Data”). This may include the device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your files, and other interactions with the Service. We may use your IP address to identify the general geographic area from which you are accessing the website. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address.
   3. Location Data. We may collect geolocation and proximity of your device if location services are enabled on your device ((e.g., GPS-based functionality on mobile devices used to access our website) and may use that information to customize the Interactions with location-based information and features. If you access our website through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. Cookies and Other Tracking Technologies. We use cookies on the platform. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. We may send one or more cookies which may be stored by your browser on your computer. The information we obtain from cookies is part of the Collected Information. Our advertisers and service providers may also send you cookies. For more information about cookies and other tracking technologies we use.
2. Use of Collected Information: Collected Information may be used for the following purposes:
   1. To provide our Service to you. We process your Collected Information to provide you with the Service you request. We share this information with third parties upon your request, or our service providers or partners to the extent necessary to provide you with the Service. We cannot provide you with Service without processing your personal information. For instance, if you so elect, to connect a third-party email account to your FIDELITY RETAIL account. This allows you to compose and send email messages in FIDELITY RETAIL. We then import replies to messages you send to access in FIDELITY RETAIL. You will also have the option to import and update events on your linked calendar. We employ a software technology called web beacons in our HTML-based emails to let you know which emails have been opened by a recipient. Please note that to the extent that you elect to connect with a Gmail account, our use of Collected Information will be further limited as indicated in the “Additional Limits on Use of Your Google User Data” section of this Privacy Policy.
   2. To administer and improve the platform’s usability. When you sign up for our Service, we will send you administrative or account-related information to you to keep you updated about our Service, inform you of relevant security issues or updates, or provide other transaction-related information to you. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Service that could affect your use of the Service.
   3. To personalize your experience on the Service. We process your Collected Information to improve your browsing experience via modification and replacement of text, images, videos, links to increase relevance to the visitor. By personalizing the Service, you get to enjoy our Service even more because we keep track of your preferences (e.g. your language selection, your time zone, etc.). Without processing your personal information for such purposes, you may not be able to access or personalize part or all our Service. To respond to your inquiries and provide customer service. We process your Collected Information when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your Collected Information, we cannot respond to you or ensure your continued use and enjoyment of the Service.
   4. To enforce our terms, agreements or policies. We process your personal information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Service; investigate, prevent, or mitigate violations of our terms, agreements or policies; enforce our agreements with third parties and partners; and, as applicable, collect fees based on your use of our Service. We cannot perform our Service in accordance with our terms, agreements or policies without processing your personal information for such purposes.
   5. To ensure the security of the Service. We are committed to ensuring your safety and continued enjoyment of our Service. To do so, we process your Collected Information to: combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Service if we do not process your personal information for security purposes.
   6. To provide you with information about other services. We process your Collected Information to send to you marketing and other communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you by post or, where you have specifically consented, by email or similar technology.
   7. To conduct research and development. To continue to provide you with continued updates to the Service, we collect information about the way you use and interact with our Service for research and development purposes. Research and development help us improve our Service and build new services and customized features. We take additional security measures when processing your personal information for such purposes, by de-identifying or anonymizing your information, and limiting access to personnel that may conduct research and development. We may also provide other companies with statistical, de-identified information about our users. The information we provide to other companies will not identify any individual user.
3. Sharing Collected Information: We may share Collected Information about you as described below:
   1. Service Providers, Business Partners and Others. We use trusted third-party companies to assist us provide, analyze and improve the Services, including but not limited to providing data center hosting services, database hosting services, dialer infrastructure services, email sync services, and to enable our third-party processors to provide sales and marketing operations services. These third parties may have access to your Collected Information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Notice or our agreements with you.
   2. Compliance with Laws and Law Enforcement Requests; Protection of Our Rights. We may disclose files stored in your FIDELITY RETAIL account and other information about you to third parties when we have a good faith belief that disclosure is reasonably necessary to: (i) comply with a law, regulation or legal requests including to meet security or law enforcement requirements; (ii) protect the safety of any person from death or serious bodily injury; (iii) prevent fraud or abuse of FIDELITY RETAIL or its user, or (d) protect FIDELITY RETAIL’s property rights.
   3. Business Transfers. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any change in control or use of your personal information, or if either become subject to a different Notice.
4. Third Party Services: Our platform may contain links to other websites and third party products, which you may elect to use in your sole discretion. We are not responsible for what the third parties and their services do with your Collected Information or the information that you choose to share with them. Your use of these third-party services will be subject to their respective terms of service and privacy policies. You may ask us to collect information about you or about others from organizations. For example, you can ask us to import your contacts by giving us access to your third-party services (for example, your email account). If you are acting on behalf of an employer using the Service, please note that you are responsible for complying with all applicable laws in relation to the Collected Information that you process on the Service. Additional Limits on Use of Your Google User Data: Notwithstanding anything to the contrary in this Notice, if you provide the FIDELITY RETAIL platform access to the following types of your Google user data, Gmail or Google Calendar (read, write, modify, and control), the platform’s use of such data will be subject to these additional restrictions:
   • The platform will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a solution that allows your users of the platform to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide, support and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
   • The platform will not use this Gmail data for serving advertisements.
   • The platform will not allow humans to read this data unless (1) we have your affirmative agreement for specific messages, (2) doing so is necessary for security purposes such as investigating abuse, (3) to comply with applicable law, or (4) for the platform’s internal operations and even then only when the data have been aggregated and anonymized.
   • Third-party applications and products use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.”

   We may need to amend this section from time to time to comply with the “Google API Services: User Data Policy,” to the extent it relates to our use of such Gmail data. For the avoidance of doubt, the additional restrictions contained in this section shall only apply to Gmail data received through the Google OAuth API, to the extent such use is applicable to you.

5. Security of Collected Information: We will take reasonable precautions to prevent the loss, misuse or alteration of your personal information. Data transmission over the Internet is inherently insecure and we cannot guarantee the security of information sent over the Internet. We will store all the personal information you provide or that we collect about you on our secure servers. You are responsible for keeping your passwords confidential. We will not ask you for your passwords. We have procedures in place to ensure we can react quickly to any possible issue. If you ever find a security issue, or simply have a security related concern, please reach out directly to us. The quickest and most effective way is by sending an email to corporate@readymode.com
6. Transfers of Collected Information We are located in Canada. If you access or use our Service or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. If you do not want your information transferred to or processed or maintained outside the jurisdiction where you are located, you should not use our Service.
7. Accessing and Updating Collected Information: If you are a registered user, you may review, update, or correct the personal information provided in your registration or account profile. If your personal information changes, or if you no longer desire our service, you may update or delete it by making the change on your account settings. Notwithstanding the foregoing, as a platform user, we depend on you to update and correct your personal information to the extent necessary for the purposes for which that data was collected, such as contact information you provide so that we can provide you invoicing information. In some cases, we may retain copies of your personal information if required by law. For questions about your personal information on our Service, please contact info@fidelityretailinc.com. We will use responsible efforts to respond to your inquiry as soon as practicable. When updating your personal information, we may ask you to verify your identity before we can act on your requests.
8. Retention of Collected Information: We retain your personal information until it is requested to be purged from our systems by an authorized member of your organization. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we do not delete from our servers files any information that you have in common with other users. While retention requirements can vary by country, we generally apply the retention periods noted below.
   • Interactions on Our Service. We may store any information about your interactions on our Service or any content created, posted or shared by you on our Services(e.g., pictures, comments, support tickets, and other content) after the closure of your account for the establishment or defense of legal claims, audit and crime prevention purposes.
   • Web Behavior Data. We retain any information collected via cookies, clear gifs, flash cookies, webpage counters and other technical or analytics tools up to one year from expiry of the cookie or the date of collection. Please refer to our Cookie Policy for more information.
   • Call Detail Records. We may retain CDRs for an indefinite period for compliance purposes.
9. Children Our Service is not directed to persons under 18, and we do not knowingly collect personal information from children under 18. Any individuals under the age of 18 must have consent from their parent or guardian to use the Service. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at privacy@readymode.com. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our files.
10. Special Notice for Individuals in the EEA, UK and Switzerland This section only applies to interactions with individuals who are in the European Economic Area, United Kingdom or Switzerland (collectively, the “Designated Countries”) at the time of data collection. Parties’ Roles. FIDELITY RETAIL is a data controller with regard to any personal information collected from users of the Service. Any third parties that handle your personal information in accordance with our instructions are our service providers and are “data processors.” You are a “user.” Users are individuals providing personal information to us via the Service pursuant to a contract that has been entered into with FIDELITY RETAIL.

    Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or the individual’s consent. To the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services and other materials that are similar to those which were the subject of a previous Interaction with you. If you do not want us to use your personal information in this way please go to the email settings for your account to opt out, click an unsubscribe link in your emails, or contact us at info@fidelityretailinc.com. You can object to direct marketing at any time and free of charge.

    Additional Privacy Rights. We provide you with the rights described below. We may limit these privacy rights requests (a) where denial of access is required or authorized by law, (b) when granting access would have a negative impact on others’ privacy, (c) to protect our rights and properties, or (d) where the request is frivolous or burdensome. If you would like to exercise your rights under applicable law, please contact us at corporate@readymode.com. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.

    • Right to withdraw consent. For any consent-based processing of your personal information, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
    • Right of access/right of portability. You may have the right to access the personal information that we hold about you, and in some limited circumstances, have the personal information provided to you so that you can provide that personal information to another controller.
    • Right to rectification. You may request to correct any of your personal information in our files.
    • Right to erasure. In certain circumstances, you may have a right to the erasure of your personal information that we hold on you.
    • Right to restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances.
    • Right to object to processing. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
    • Notification to third parties. When we fulfill your individual rights requests for correction, erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.

    Legal Bases for Processing Personal Data. Our legal bases for collecting and using the personal information described above will depend on the type of personal information collected, the specific context in which we collect it and the purposes for which it is used. We rely on the following legal bases under the European Union’s General Data Protection Regulation (“GDPR”) in processing your personal information. Article 6(1) of the GDPR describes when processing can be done lawfully. When we process your personal information for a specified purpose, we shall apply one of the Article 6 legal bases described below.

    • Whenever we require your consent for the processing of your personal information such processing will be based on Article 6(1) lit. (a) GDPR.
    • If the processing of your personal information is necessary for the performance of a contract between you and GT or for taking any pre-contractual steps upon your request, such processing will be based on Article 6(1) lit. (b) GDPR. If this data is not processed, FIDELITY RETAIL will not be able to execute the contract with you.
    • Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of Article 6(1) lit. (c) GDPR, for example for complying with obligations under anti-money laundering laws. Where the processing is necessary for the purposes of FIDELITY RETAIL’s or another party’s legitimate interests, such processing will be made in accordance with Article 6(1) lit. (f) GDPR, for example to enforce legal claims.
11. Contacting Us: To exercise your rights, or if you have any questions about this Notice or our treatment of your personal information, please send us an email at info@fidelityretailinc.com or by post to FIDELITY RETAIL INC. 483 Bay St., Toronto, ON M5G 2C9