Fidelius LLC (“Fidelius”) respects your privacy. This Privacy Notice (“Notice”) informs you about our privacy practices, which includes without limitation, details of the personal information we collect, use, disclose and transfer. There may be choices you can make and rights you can exercise about your information. This Notice is available from a link on the footer of every Fidelius web page.
This Notice applies to all Fidelius -owned websites, content, domains, services, applications, and products, and those of our subsidiaries (the “Services”). There may be a different privacy notice that is specific to a program, product, or service. If this is the case, that different notice will apply to that specific program, product, or service. This Notice may also supplement the different privacy notice.
Fidelius understands that your privacy is important to you and that you care about how your information is used. Fidelius respects and values the privacy of everyone who uses our Services and will only collect and use personal information in ways that are described in this Notice, and in a way that is consistent with our obligations and your rights under the law.
In general, changes will be made to this Notice to address new or modified laws and/or new or modified business procedures. However, we may update this Notice at any time, with or without advance notice, so please review it periodically. We will update the ‘Last Updated’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. You can determine when this Notice was last revised by referring to the date it was “Last Updated” above. Your continued use of the Services after any modification to this Notice will constitute your acceptance of such modifications and/or updates.
Information About Us
Fidelius is based in Denver, Colorado. Our founder and Data Protection Officer is Zachary Jablonski.
801 S Cherry St Apt 431, Denver, CO 80246
E-mail contact: firstname.lastname@example.org
We have an accountability-based program and are committed to principles called ‘Fair Information Practices’ which are based on internationally recognized privacy frameworks.
Lawfulness, Fairness & Transparency: We use information in compliance with the law, and with transparency and fairness to you. We use your information: 1) with your consent; 2) in order to meet contract requirements; 3) to run our operations, or 4) to meet legal requirements we must follow.
Notice & Choice of Information Use: We are transparent and provide notice to you about the types of information collected, and the purposes for which it is collected and used. We will not use information for purposes that do not follow our Notice or these privacy principles.
Information Access: Where the law requires it, we provide you with reasonable access to your information. That may include the ability to review, correct, amend, or delete the personal information you have shared with us. Not all these actions may be available to you. This would be the case if granting the action would breach the privacy of another person.
Information Integrity & Purpose Limitation: We only use information for the reasons we describe to you at the time we collect it and in compliance with the law. We take reasonable steps to ensure that information is accurate, complete, and current. We only collect information we need, and it is limited for the purposes we told you it was collected for.
Information Security: To protect information against unauthorized use or disclosure we implement information security controls in all our operations to keep your information secured.
Recourse, Oversight & Enforcement: We are committed to resolving any concerns regarding your personal information. We will hold our employees, contractors, vendors and anyone handling information responsible.
What Information We Collect
We collect three types of information: (1) information we need to provide you Services, (2) information collected automatically and (3) information from third parties for specific purposes.
(1) Information we need to provide you Services that you knowingly provide:
Contact Information: We may collect personal and/or business contact information including your first name, last name, mailing address, telephone number, email address, and other similar information.
Payment Information: We collect information necessary for processing payments and preventing fraud, including credit/debit card numbers, security code numbers, and other related billing information. However, we will limit such information to only what we need to provide you Services.
Account Information: We collect information such as how you purchased or signed up for our Services, your transaction, billing and support history, the Services you use and anything else relating to the account you create.
Location Information: We collect geolocation information when you enable location-based services or when you choose to provide location-related information during product registration or when interacting with our website.
Security Credentials Information: We collect user IDs, passwords, password hints, and similar security information required for authentication and access to Fidelius accounts.
Demographic Information: We collect, or obtain from third parties, certain demographic information including, for example, country, gender, age, preferred language, and general interest information.
Preferences: We collect information about your preferences and interests as they relate to Fidelius’ Services (both when you tell us what they are or when we deduce them from what we know about you) and how you prefer to receive communications from us.
Social Media Information: We may provide social media features that enable you to share information with your social networks and to interact with us on various social media sites.
Other Unique Information: Examples of other unique information that we collect from you include information you provide when you interact in-person, online or by phone or mail with our services centers, help desks or other customer support channels, your responses to customer surveys or contests or additional information you have provided to us to facilitate delivery of Fidelius’ Services and to respond to your inquiries.
(2) Information we automatically collect:
Product Usage Information: We collect product usage information such as log-in, log-off, duration, pages.
Device Information: We collect information about your computer, printer and/or device such as operating system, firmware, amount of memory, region, language, time zone, model number, first start date, age of device, device manufacture date, browser version, device manufacturer, connection port, warranty status, unique device identifiers, advertising identifiers and additional technical information that varies by product.
Application Information: We collect information related to our applications such as location, language, software versions, information sharing choices and update details.
Performance Information: We collect information regarding the performance of individual device hardware components, firmware, software, and applications.
Website Browsing Information: We collect information about your visits to and your activity on our Fidelius Services, applications or websites “powered by” another company on our behalf including the content (and any ads) that you view and interact with, the address of the website from which you arrived and other clickstream behavior (such as the pages you view, the links you click or which items you’ve added to your shopping basket).
Cookies: A “Cookie” is a tiny data file that resides on a computer, mobile phone, or other device, and allows us to recognize users when they return to our website using the same device and web browser. This allows us to collect information about how you use our Services. Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at using the Service.
By using Fidelius Services, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Fidelius Services to frame service content to/from our business partners while preserving the look and feel of our websites. For more details, please refer to the table below. These Cookies are not integral to the functioning of Fidelius Services, and your use and experience of Fidelius Services will not be impaired by refusing consent to them. All Cookies used by and on Fidelius websites are used in accordance with applicable Cookie law.
Cookies are categorized by how long they are stored and their function. The Cookies we use are as follows:
- Strictly Necessary Cookies: Strictly necessary Cookies are essential to navigate around the Services and to use its features.
- Third Parties Cookies: Third Parties whose content appears on Our Site may use third-party Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves and we advise you to check the privacy policies of any such third parties. The following third-party Cookies may be placed on your computer or device:
- Functionality Cookies – These cookies allow the provision of enhanced functionality and personalization, such as videos and live chat. They may be set by third-party providers whose services we have added to our pages or by us. If you do not allow these cookies, then some or all of these functions may not work properly.
- Targeting/spamvertising – Cookies are used to create profiles or personalize content. Third parties often set them, and these cookies present the highest privacy risks to visitors
In addition to the controls that we provide, you can choose to enable or disable Cookies in your Internet browser. Most Internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time. In some cases that may negatively impact your experience with using our Services, and you may lose any information that enables you to access Fidelius websites more quickly and efficiently including, but not limited to, login and personalization settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your Internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Analytics: Fidelius Services use third party analytics services to gather statistics and usage trends for product and service improvement purposes. The Services may record data from your phone, table or computer such as how frequently you use the Service, which elements you may use to navigate from one page to another, what actions you take and performance data.
(3) Information from third-party sources:
Fraud prevention or credit reporting agencies: Information collected to prevent fraud and in connection with credit determinations.
Analytics Providers: We also receive non-personal information, such as aggregated or de-identified demographic/profile information, from third-party sources such as companies that specialize in providing enterprise information, analytics and software as a service.
How We Use Information About You
We use information collected as described in this Notice to provide you with the Services and/or information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services. We also use the information collected to take the following actions:
- operate, maintain and improve the Services;
- managing your account;
- answer questions and respond to your requests;
- perform analytics and conduct research;
- send you reminders, support and marketing messages;
- manage our administration of the Services;
- managing payments for our Services;
- analyze programs, products and services we offer;
- collect feedback from you about third-party products and/or services;
- inform you about products, events and/or other promotional purposes; and
- use information for other purposes about which we notify you.
Marketing: With your permission and/or where permitted by law, we may also use your information for marketing purposes related to the Services we provide you. This can be done by contacting you by email with information, news, and offers on our Services. We will work to fully protect your rights and comply with our obligations under the ‘Data Protection Legislation’, and you will have the opportunity to opt-out. We will obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes, and you will be able to opt-out at any time.
Unsubscribing from Marketing: You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us an email to: email@example.com.
Customers cannot opt out of receiving transactional emails related to their account with us or we will not be able to provide Services for you.
Parties with whom we may share your information:
- Service Providers: We may share your personal information as well as aggregated information from with employees, contractors, and/or agents that help Fidelius provide the Services to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services.
- Compliance with Laws: Fidelius will not disclose your personal information to third parties except as set forth in this Notice and in the following circumstances: (i) to investigate and defend Fidelius’ members against any third party claims and/or allegations and/or otherwise to protect Fidelius from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service.
- Business Transfer. If we sell or otherwise transfer part or all of Fidelius or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.
Security of Your Information
The security of your information is important to us. These are some steps we take to protect your information:
Information security: We have adopted appropriate safeguards to secure the personal information we have in our possession. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
Duty of confidentiality: All Service Providers that process personal information on our behalf are bound by a duty of confidentiality. Service Providers are required to handle personal information appropriately. Failure to abide by our requirements will lead to disciplinary action.
Encryption: We will use encryption when handling information. This may include when it is being sent or when it is stored.
Access controls: We implement technical access controls that restrict access to information. We limit access to authorized Service Providers only. We identify and appoint designated people with overall responsibility for granting, changing or voiding information access privileges.
Usernames / passwords: Access to information will be controlled through using usernames and confidential passwords. No two Service Providers may share or use the same username. Service Providers will be required to change their passwords on a regular basis. All Service Provider passwords will be stored in encrypted format.
We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the Internet is not a completely secure environment, Fidelius cannot warrant the security of any information you transmit to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your account, at all times.
Our Services are not targeting minors (under the age of 18). We also follow laws specific to the information of children. This includes a law called the Children’s Online Privacy Protection Rule (“COPPA”). If we learn that we have collected information from a child under age thirteen (13), we will delete such information as quickly as possible. Also, if you believe that a child under the age of thirteen (13) may have provided us information, please contact us at firstname.lastname@example.org.
California Privacy Rights
If you live in California, California law allows you to request and obtain from us once a year, free of charge, the categories or sources of personal information we collected about you, a list of the third parties to whom we have disclosed your personal information (if any, and as defined under California law) for the third party’s direct marketing purposes in the prior calendar year, as well as the type of your personal information disclosed to those parties.
If you live in California and would like to request this information, please send your request in an email to email@example.com.
We reserve the right not to respond to requests submitted in ways other than those specified above. The followingexceptions may prevail with respect to fulfillment of data access requests: (a) Fidelius may not provide personal data to an individual, if management determines that we cannot identify the individual in our systems because the data we have has been de-identified to the extent that identification is not possible; and/or (b) Fidelius may not provide personal data to an individual, if the individual is involved in a civil or criminal proceeding with Fidelius.
The governing language of this Privacy Notice is English, which shall prevail over any other languages used in any translated document