Privacy Policy

At FactR Limited ("FactR", "we", "us", "our"), we are committed to protecting your privacy and safeguarding your confidential and personal information.

The purpose of this Privacy Statement is to inform you about the types of Personal Information, as defined below, that FactR collects, uses, and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the "last revised" date which appears at the top of this page.

We will treat Personal Information in a manner consistent with our Privacy Statement unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

1. What is Personal Information?

"Personal Information" includes any factual or subjective information, recorded or not, about an identifiable individual.

2. How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means. We collect Personal Information directly from you, or indirectly from third-party sources as otherwise permitted by applicable law.

With respect to www.factr.me (the "Website"), FactR may use cookies, log files, and web beacons to collect information regarding the use of the websites. Generally, this information is non-identifiable and would likely not be considered Personal Information.

Cookies: Cookies are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is FactR’s policy to use cookies to make navigation of the Website easier for visitors and to facilitate efficient registration procedures. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate the Website.

Log files: In order to properly manage the Website, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters and are generally non-identifiable.

Web beacons: To gather visitor statistics and manage cookies, we use electronic images called a "single-pixel GIF" or "web beacon." Web beacons allow our third-party tracking tools, Adobe Analytics, and Google Analytics to gather information such as the IP address of your computer, the time the material was viewed, and the type of internet browser used to access the page. This information is tracked on the third-party tracking tools' servers and reported in aggregate to our webmasters. If you are concerned about the use of Web beacons you can turn off your browsers' cookies. This action will prevent Web beacons from tracking your specific activity; however, the Web beacon may still record a visit from your IP address.

Finally, FactR understands the importance of protecting children's privacy online. The Website is not designed for or directed at children 13 years of age or younger. It is FactR's policy never to knowingly collect or maintain information about anyone under the age of 13.

3. Where do we store your Personal Information?

Personal Information provided to us is stored on servers in a number of locations around the world. Rest assured that FactR has taken appropriate steps for the protection of Personal Information handled by our service providers. However, information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.

4. How do we use your Personal Information?

We generally use your Personal Information for the following purposes (the "Purposes"):

• to process and deliver products and services that you have ordered from us;

• to invoice and collect payment for products and services provided by us to you;

• to develop and maintain our relationship with you and communicate with you;

• to research, develop, manage, protect, and improve our products and services;

• to assist us with improving our operational efficiency, marketing campaigns, and customer service efforts;

• to process your application for employment and resume; and

• such other uses as may be permitted or required by applicable law.

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your informed, freely given, and unambiguous consent prior to each specific use. When you provide us with consent to use your Personal Information, your consent covers all processing activities carried out for the same purpose or purposes. When the use of your Personal Information has multiple purposes, we will seek your consent for each separate purpose for which the Personal Information will be used.

5. Data Anonymization and Aggregation

Subject to your consent if required by law, we may anonymize or aggregate your Personal Information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor products and services and to conduct a risk assessment and analysis of costs and charges in relation to our products and services. We may share anonymized or aggregated data with other third parties. This policy does not restrict our use or sharing of any non-personal, summarized, derived, anonymized, or aggregated information (i.e., volumes, totals, averages, etc.).

6. To whom do we provide your Personal Information?

We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.

Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of FactR or as otherwise permitted or required by law, in which case the use of your Personal Information by the new entity would continue to be limited by applicable law.

In addition, we may send Personal Information outside of the country for the purposes set out above. To the extent that any Personal Information is out of Canada, it is subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts or law enforcement, or regulatory agencies of such other country, pursuant to the laws of such country.

7. When and how do we obtain your consent?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically, or in writing. FactR may also rely on your implied consent to the collection, use, and disclosure of your Personal Information where implied consent is permitted under applicable law.

We will not require you to consent to the collection, use, disclosure, or protection of information beyond that which is required to fulfil the specified and legitimate purposes for which the information is being collected.

8. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

We ensure that all third parties, which are retained to perform services on our behalf and are therefore provided with Personal Information are contractually required to observe the intent of this Privacy Statement and FactR's privacy and data security policies and practices.

9. How long will we use, disclose or retain your Personal Information?

We may keep a record of your Personal Information, correspondence, or comments in a file specific to you. We will use, disclose or retain your Personal Information for as long as necessary to fulfil the purposes for which that Personal Information was collected, or as permitted or required by law.

10. Residents of the European Economic Area ("EEA")

We generally process Personal Information pursuant to one of the legitimate business interests listed in Section 4. Otherwise, we will obtain consent from an individual in respect of the processing of Personal Information if required by law to do so.

If you are an EEA resident, Personal Information that we process in relation to you may be transferred and stored at, a destination outside the EEA that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

Where your information is transferred outside the EEA, we take steps reasonably necessary to ensure that your Personal Information is subject to appropriate safeguards, such as where applicable relying on a recognized legal adequacy mechanism and contracts, to help ensure your rights and protections travel with your Personal Information and that your Personal Information is treated securely and in accordance with this Privacy Statement.

If you are an EEA resident, you have the following additional rights under certain circumstances:

• to be provided with a copy of your Personal Information held by us;

• to request the rectification or erasure of your Personal Information held by us;

• to request that we restrict the processing of your Personal Information (for example, while we verify or investigate your concerns about your information);

• to object to the further processing of your Personal Information, including the right to object to marketing; and

• to request that your Personal Information be moved to a third party.

11. How can you access the Personal Information that we have collected, utilized, or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized, or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable and will explain any abbreviations or codes. To submit a written access request, or to obtain further information with respect to your access rights, you may contact us, as indicated below.

12. How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete, and up-to-date as possible. We will not routinely update your Personal Information unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

13. What if the Personal Information we have on you is inaccurate?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

14. How fast will we respond to your written requests?

We will respond to each of your written requests no later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

15. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?

We will not charge any costs for you to access your Personal Information in our records or to access our Privacy Policy or practices without first providing you with an estimate of the approximate costs if any. You may withdraw your requests for access to information by notifying us within the thirty (30) day notice period disclosed on the estimate. If you do not notify us within such a thirty (30) day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within thirty (30) days. If, after the expiry of this second thirty (30) day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.

16. How do we know that it is really you requesting your Personal Information?

We may request that you provide sufficient identification to permit access to the existence, use, or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

17. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual, and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use, or modification. The only employees who are granted access to your Personal Information are those with a business 'need-to-know' or whose duties reasonably require such information.

18. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

All comments, questions, concerns, or complaints regarding your Personal Information or our Privacy Statement, should be forwarded to: info@factr.me