Last Updated: April 18, 2022

 Fathom4sight Inc. (“Fathom4sight”, “we”, “us” or “our”) is committed to protecting the privacy and confidentiality of personal information in our custody and control. This Privacy Policy explains how we collect, use, disclose and protect personal information in the course of providing our Fathom4Sight Pro and Fathom4Sight Live platforms (together the “Platform”), and through our website at https://www.fathom4sight.com (the “Website”).

COLLECTION AND USE OF PERSONAL INFORMATION 

If you contact us, access or use the Platform or Website or register for our news alerts, we will ask you to provide us with personal information.

Contacting Us:  If you choose to contact us with an inquiry or question, or to request information about our services or content, you will be asked to provide information that identifies you, such as your name, email address and a telephone number, along with additional information relating to your inquiry, question or request.  We use this information to respond to your inquiry, question or request and to provide you with other information we believe may be of interest, including Fathom4Sight news alerts.

Platform: The Platform provides you with access to proprietary information content and other services relating to the Canadian fintech market. In order to access Platform, you must provide your email address, password, full name, and mobile phone number for the purposes of administering your account. We may use this information to administer your account and personalize your experience on Platform.  

News Alerts: If you choose to register for Fathom4Sight news alerts, we will collect your name, email address and telephone number in order to send you these alerts.  You can opt-out of receiving news alerts at any time by following the opt-out or “unsubscribe” instructions provided in the email, or by contacting us as set out below.

INFORMATION COLLECTED AUTOMATICALLY

We collect the IP (Internet protocol) addresses of all visitors to the Website or Platform and other related information such as page requests, browser type, operating system and average time spent on the Website or Platform. We use this information to help us understand our Website and Platform activity and to improve our Website and Platform.

Cookies:  Our Website and Platform use a technology called "cookies". A cookie is a tiny element of data that our Website and Platform sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user when they return.  We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Platform, you may not be able to take advantage of all of the Website or Platform features. 

Analytics: We may use third party service providers to collect information about your use of the Website and Platform, such as the features used, your internet protocol (IP) address and system details, and time spent on the Website or Platform, to help us better understand our users, provide the services and improve the Website and Platform.  For example, for information about information processed in connection with such third party service providers read the policy of Google Analytics Policy here, the policy of Heap.io here and the policy of Pendo.io here. 

DISCLOSURE OF PERSONAL INFORMATION 

Service Providers: We may transfer (or otherwise make available) personal information to service providers who provide certain services on our behalf.  For example, we may use service providers to host the Website or Platform, store data, provide back-up services (including cloud-based service providers) and manage our communications.  Some of our service providers may be located outside of Canada, including in the United States. While outside of Canada, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances. Our service providers are given access to the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. For more information, please contact us as set out in the “Contact Us” section below.

Sale of Business:  We may transfer personal information as an asset in connection with a prospective or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Fathom4Sight or as part of a corporate reorganization or other change in corporate control.

Legal: Fathom4Sight may disclose your personal information where permitted or required by law, including to comply with a subpoena, warrant or other legally valid inquiry or order (which may include lawful access by Canadian or foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, to protect our rights and the safety and security of our employees, to enforce our agreements and collect debts owed to us, or as otherwise required or permitted by applicable law.  

LEGAL BASIS FOR PROCESSING

We rely on one or more of the following legal grounds (as appropriate) to process personal information:

• To enter and perform a contract with you or to perform any steps you require from us before entering into a contract.

• To pursue our legitimate business interests in establishing, managing or concluding our relationship with you.

• Where you have specifically consented to us processing your personal information.

• To comply with our legal obligations and establish, exercise or defend our legal rights.

Where personal information is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described in the “Contact Us” section below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain of our services.

THIRD PARTY SITES

The Website and Platform may contain links to other websites that Fathom4Sight does not own or operate. We provide links to third party websites as a convenience to the user.  These links are not intended as an endorsement of or referral to the linked websites.  The linked websites have separate and independent privacy policies, notices and terms of use.  We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

SECURITY OF PERSONAL INFORMATION

We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We limit access to personal information to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information. However, please note that no security measures can offer absolute security and we cannot guarantee that your personal information will not be stolen or accessed without authorization.

RETENTION OF PERSONAL INFORMATION
Personal information is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfilment of the purposes for which it was collected, in accordance with prudent business practices on general document retention, or as otherwise required by law.

YOUR RIGHTS

You may request access or correction of your personal information (subject to limited exceptions prescribed by law) by submitting a written request to us (see “Contact Us” below).  You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us be transferred to another person, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. If you have any questions about these rights, or you would like to exercise any of them, please contact us as described in the “Contact Us” section below. We may take steps to verify your identity prior to responding to your requests.

UPDATES TO OUR PRIVACY POLICY 
This Privacy Policy may be updated periodically to reflect changes to our personal information practices.  The revised Privacy Policy will be posted on our Website.  We encourage you to refer to this Privacy Policy often for the latest information about our personal information practices. 

CONTACT US

Please contact our privacy officer at privacy@fathom4sight.com or at the address below if you have any questions, comments or complaints about this Privacy Policy.

Sue Britton, on behalf of Privacy Officer

Fathom4Sight 

628 Fleet Street, Unit 1006

Toronto, Ontario. 

M5V1A8