Last revised: February 16, 2022
Please read this Policy carefully to understand our policies and practices for collecting, processing, and disclosing your information. We will only use your personal information in accordance with this Policy except where otherwise permitted or required by applicable law. By visiting our Platform or providing us with personal information, you consent to the practices described in this Policy.
1. What Information Does Fidelity Collect?
The types of information we collect depends on the nature of your interaction with us. We may collect and use several types of information from and about you, including:
Personal information. Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information may be collected online when you voluntarily register with us or update your existing profile with us, purchase products or services, sign up for newsletters or emails, use chat or telecommunication features, enter contests or other promotional opportunities or interact with our advertising on third-party websites. Here are the types of personal information we may collect when you navigate the Platform:
• Contact information. For example, your name, postal address, telephone number, email address and login credentials. In certain circumstances, we may request a video call during which we may request to verify your identification with a driver’s license or similar card and to verify your credit card.
• Your personal preferences. For example, product preferences based on previous transactions and page interaction information (including the timing, frequency and pattern of use)) and marketing consent.
• Your transaction information. For example, products purchased, delivery addresses, methods of payment, amounts paid and card details.
• Technical information. For example, IP address, geographical location, browser type and version, operating systems and platforms, referral source, length of visit on the Platform, page views and website navigation paths.
• Other information you provide us. For example, information contained in or relating to any communication that you send to us or send through the Platform (including the communication content and metadata associated with the communication) or any other personal information that you choose to send to us.
Non-personal information. Fidelity may also create and collect “non-personal information.” This is information that is not associated with or linked to your personal information, including information that has been aggregated or otherwise anonymized so that it no longer relates to an identifiable individual. Fidelity may use, disclose, transfer, and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then the non-personal information will be treated as personal information for the purposes of this Policy.
2. How does Fidelity Collect Information?
Fidelity may use a variety of methods to collect your information, including through:
• Direct Interactions with You. We collect information you directly provide us by, for example, filling in forms or corresponding with us by email.
• Website Tracking Tools. We may use web beacons or pixel tags to compile statistical information, for example, regarding website user demographics, preferences and traffic patterns.
• Social Networking Platforms. We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins, and applications, you may allow us to have access to certain information associated with your social media account (for example: name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application.
3. Interest-Based (behavioral) Advertising and Third Parties
Links to Third Party Websites. Our website may contain links to other third-party websites or internet resources which are provided solely for your convenience and information. As will be evident, when you click on one of those links, you will be leaving Fidelity’s Platform and going to the third party’s website. Any information provided to such third party is governed by their privacy policies, which you may read on the applicable site. Fidelity has no responsibility or liability for, or control over, the collection, use, and disclosure of your personal information by those third-party websites or internet resources.
4. For What Purposes Does Fidelity Use Personal Information?
We use your personal information to operate, provide, develop, and improve our products and services, including in connection with:
• Account management. We use your personal information to verify your identity and manage your account.
• Purchase and delivery of products and services. We use your personal information to take and handle orders, deliver products and services, process payments and communicate with you about your orders, products, services and promotional offers.
• Recommendations and personalization. We may use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences and personalize your experience with the Platform.
• Improve Fidelity. We may use your personal information to operate, evaluate and improve our business, including to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Platform.
• Interest-Based (behavioural) Advertising. We may use your personal information in connection with Interest-Based (behavioural) Advertising. For more information, see “3. Interest-Based (behavioral) Advertising and Third Parties”.
• Employment. Fidelity may use and disclose your personal information to administer and process your application for employment with Fidelity and related matters.
• Other. We may use your personal information as required or permitted by applicable law, to prevent fraud or criminal activity, to protect or enforce the rights of Fidelity and to safeguard the security of our customers, Fidelity and others.
5. How Fidelity Shares Personal Information
Fidelity does not sell our customers’ personal information to any other party. However, in the normal course of business, we may share some of your personal information for our legitimate business purposes and as required or permitted by law, including:
• With affiliates. Fidelity may share personal information amongst our corporate affiliates.
• With suppliers and service providers. Fidelity may disclose your personal information to Fidelity’s suppliers and service providers who perform services on our behalf such as the provision of payment processing services, customer communications, data processing, data management, advertising, marketing or fraud detection. When we do use an outside company, we use contractual or other appropriate means to ensure that your personal information is used in a manner that is consistent with this Policy.
• With Advertisers. Fidelity may disclose aggregated information to advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to advertising networks, but we may provide them with aggregate information about our users. For more information, see “3. Interest-Based (behavioral) Advertising and Third Parties”.
• To facilitate product safety recalls. In the event we receive notice from a manufacturer of a product safety recall, we may provide your contact information, limited to name, address, and telephone number, to the manufacturer so that they may notify you of the recall and supply details of any replacement or repair programs. This transfer or your contact information will occur only for recalls that may impact your personal safety or impair the functionality of the product you purchased from us.
• With any successor to all or part of our business. Fidelity may disclose your personal information in connection with a proposed or actual business transaction, such as a corporate reorganization, merger or acquisition, or the sale of some or all of Fidelity’s business or assets (including in connection with a bankruptcy proceeding), but Fidelity will require that the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Policy. • With legal authorities. Fidelity and its service providers may disclose your information as permitted or required to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• Other. We may disclose your personal information as required or permitted by applicable law, to prevent fraud or criminal activity, to protect the rights and interests of Fidelity and to safeguard the security of our customers, Fidelity and others.
6. Retention, Location, and Protection of Personal Information
Fidelity retains your personal information for the period necessary to fulfill the purposes outlined in this Policy or such longer retention period as may be required or permitted by applicable legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
We may process, store, and transfer your personal information in and to a foreign country, such as the United States, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, law enforcement or regulatory agencies of that country may be able to obtain access to your personal information in accordance with the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation.
Fidelity employs safeguards, including organizational, technical, and physical measures, appropriate to the sensitivity of the personal information in its possession or under its control to protect that information from unauthorized access, collection, use, disclosure, disposal or similar risks. For example, we store all the personal information you provide on our secure (password- and firewall-protected) servers and all electronic financial transactions entered through our application are protected by encryption technology. While Fidelity uses reasonable efforts to protect your information, no method of transmission over the internet, or method of electronic storage is 100% secure, and therefore, Fidelity cannot guarantee absolute security of your personal information.
7. Accuracy, Access to Personal Information and Withdrawing Consent
By law you have the right to request access to and to correct the personal information that we hold about you. You may review, verify or correct your Fidelity account information through Fidelity’s Platform. You may also contact us using the information provided below under “10. Contact Us” to request access to, correct, or delete any personal information that you have provided to us.
We may request specific information from you to help us confirm your identity and your right to access and provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Examples of such exceptions include: information protected by solicitor-client privilege, information that is part of a formal dispute resolution process, information that is about another individual that would reveal personal or confidential commercial information or information that is prohibitively expensive to provide.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the information provided below under “9 Contact Us”. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service.
8. Change to the Policy
9. Contact Us
If you have additional questions regarding this Policy, you can call us at (289) 851-1076, reach us by email at email@example.com or write to us at:
FIDELITY PAC METALS LTD.
855 Steeles Avenue E, Unit #1
Milton, Ontario, Canada