1) User Acknowledgment

• By accessing and using the Site, you acknowledge and agree that this Privacy Policy is part of the terms and conditions (the “Conditions”) of the Application and Services. You further agree that using the Application and Services signifies your acceptance of this Privacy Policy and your consent to the collection, use, and disclosure of your personal information as described herein.
• If you do not agree with this Privacy Policy, you will not be granted access to the Application. Your use of the Application and any dispute over privacy is subject to this Privacy Policy and our Conditions, including limitations on damages.

2) Definitions

• “Personal information” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
• “Sensitive Personal Information” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Information relating to criminal offences and convictions.
• “Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
• “Performance of contract” means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.“Performance of contract” means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

3) Collection, Use, and Disclosure of Personal Information

• a) The Site may collect and use information provided by you to the Site including, without limitation, the following (“Personal Information”):
• a. Profile Information: Includes certain profile information provided by you, including, but not limited to, your name, username, password, email address, phone number, mailing address, photographs, resume, and professional credentials.
• b. User Content: Includes all information and materials you provide, submit, or post to or through the Application.

b) Jurisdiction

• All Personal Information submitted to the Site will be collected, processed, used, stored, disclosed, and disposed of in accordance with applicable Canadian law, this Privacy Policy, and the Conditions.

c) Data protection principles

• When handling Personal Information, Fairly Staffing adheres to the following principles that Personal Information shall be:
• processed lawfully, fairly and in a transparent manner;
• collected only for specified, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
• accurate and where necessary kept up to date;
• not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the Personal Information is processed;
• processed in a manner that ensures its security using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage;
• not transferred to another country without appropriate safeguards being in place; and
• made available to data subjects and allow data subjects to exercise certain rights in relation to their Personal Information.
• We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

d) Use of Information

• All Personal Information provided including profile information and user content provided and relating to the Site will be treated as confidential information by Fairly Staffing. Fairly Staffing will not disclose any Personal Information or materials provided by you to the Application to any third party unless authorized and such Personal Information will be used by Fairly Staffing for internal purposes such as to tailor programs and content, and to address the needs of authorized Users. However, you understand and agree that, by using the Application, Fairly Staffing may use your Personal Information to contact you to provide information regarding its products and services, as well as events. Should you wish to opt out of the use of your Personal Information for marketing purposes, you may contact Fairly Staffing to indicate your desire to opt out. You own and will continue to own all of the Personal Information provided by you to the Application, and you may add, change, or remove your Personal Information from the Application at any time.
• We may collect, use, store and transfer different kinds of Personal Information about you. We collect and process Personal Information about you when you:
• access and use the Application and Services;
• register an account on the Application;
• submit a copy or scan of your photo identification such as a driver’s license;
• enter your location;
• make a payment through the Application;
• make an enquiry about the Application and/or Services;
• submit a general enquiry to us;
• submit a search on the Application;
• enter a promotion or competition;
• leave your feedback or a review on the Application; or
• manage your hiring/placement preferences with us.
• We will use the Personal Information you provide to us for the following purposes:
• To provide our Services to you
• To process payment in accordance with these Conditions;
• To enable an Employer to contact you as permitted under these Conditions;
• To allow Employers and Contractors to see each other’s’ geographical locations and travel times to and from each other;
• To verify your identity;
• To verify your ability to legally operate a motor vehicle;
• To send updates regarding the Application or Services;
• To send newsletters, offers, and promotions that we believe may interest you;
• To mediate disputes between Employers and Contractors;
• To administer our fee payment and invoicing;
• To analyze the behaviours of our Users;
• To determine new features and content of the Application and Services;
• To conduct marketing and promotional activities.
• We may also use some of your Personal Information to compile, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is typically anonymized and is therefore not considered Personal Information under the Applicable Laws, as it does not directly or indirectly reveal your identity. For example, we may combine Application use information from you and other users to analyze the popularity of certain features of the Application. However, if use your Personal Information to compile Aggregated Data in a manner that directly or indirectly identifies you, we will treat the Aggregated Data in the same manner as Personal Information in accordance with these Conditions.
• We do not knowingly collect or process any Sensitive Personal Information about you. Please do not provide us with any Sensitive Personal Information through the Site. If we become aware that we have collected Sensitive Personal Information, we will use our reasonable endeavours to delete that information as quickly as possible.
• e) Failure to provide Personal Information
• Where we need to collect Personal Information by law, or in order to give you access to the Application, our Services, or part thereof, and you fail to provide that information when requested, we may not be able to give you access to the Application or Services.
• f) Marketing
• We will only contact you by e-mail or text message for marketing purposes if you have given us your opt-in consent to do so. We will continue contacting you to provide you with our newsletter if you have previously signed up to receive it. You can ask us or third parties to stop sending you marketing messages by contacting us at any time or by clicking the “unsubscribe” button in the relevant e-mail.
• We will not share your information for marketing purposes with any company or other entity outside of Fairly Staffing or its affiliates and subsidiaries, unless we have your opt-in consent to do so.
• We do not and will not sell any of your Personal Information to any third party.
• g) Third-party Sites
• We collect information when you register to join us by logging into an account that you already have with certain third-party sites (“TPS”) (including, but not limited to, Facebook, LinkedIn, Instagram and Twitter). For example, the Application allows you to create an account and login for the Application using your Facebook account credentials. If you are not currently registered as a user of the Application and you click on “Sign Up with Facebook,” you will first be asked to enter your Facebook credentials and then be given the option to register and join us. If you decide to create your user account by logging into a TPS account via the Application, you are using the Personal Information you have already provided to the TPS (such as your “real” name, email address and other information you make publicly available via the TPS) to create your user account with us. The Personal Information we collect may depend on the privacy settings you have with the TPS, so please consult the TPS’s privacy and data practices. The Personal Information we may collect in this way may include, but is not limited to, your name, email address, TPS sign-in or username, profile photo, and any biography you have provided to them. We may share the information in your user account (including your personal information) with the TPSs that you have linked to your account. These TPSs have access to your personal information only for this purpose (unless the TPS has received your personal information independently of the Application) and not for other purposes. You may update certain TPS preferences, including the option to share or post your activity through your respective TPS accounts, under your account settings.
• h) User Content Displayed to Public
• If you submit User Content to the Application, your username and other information you include is displayed in your reviews, postings, comments, etc., and is therefore available to the public. All of your activities in the public areas of the Application will be identified by your username, and other Users can see your published profile content. When you register through the Application and submit Personal Information to create a user account profile, other Users will see your name. If you choose to provide additional Personal Information in your profile, other users will see that additional Personal Information, including, but not limited to, your photo, location, website, and biography. Providing additional Personal Information is voluntary. We recommend that you avoid disclosing any information you consider sensitive and confidential. certain cases the Application allows Users to provide ratings and reviews of other Users, and such information will be published on the areas of the Application visible to registered Users. When completing an evaluation survey after a placement, comments designated as “public” may be visible to all members of the public, regardless of whether they are registered Users or not. Regarding comments designated as “private”, we make reasonable efforts to maintain the confidentiality of these comments although we make not warrant of guarantee that these comments might not be made inadvertently public.
• i) Change of purpose
• We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
• If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
• Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
• j) Cookies
• The Site uses “cookies”, or similar technologies, to improve and tailor your experience and to save you time. Cookies are tags placed onto your mobile device or computer from which you access the Site, thereby allowing your device or computer to be recognized each time you access the Site. Through the use of cookies, the Site can be customized to your individual preferences in order to create a more personalized and convenient experience. Please note that the cookies used for the Application do not store personally identifiable information about you.
• You can delete cookies stored on your computer or change your privacy settings at any time via your browser settings. These browsers include;
• Internet Explorer
• Chrome
• Firefox
• Safari
• You may be able to change the preferences on your browser or device to prevent or limit your computer’s or device’s acceptance of cookies, but doing so may negatively affect the functionality of the Site and its services.
• Our advertising partners may transmit cookies to your computer or device when you click on ads that appear on the Site. This Privacy Policy does not cover cookies delivered to you by any of our advertisers or TPSs, as we have no control over these cookies.

4) Security of Personal Information

• We will aim to protect your Personal Information, including the confidentiality, security, and integrity of data stored on its systems. Only those employees, agents, contractors, and other third parties who need access to your Personal Information in order to perform their duties are allowed such access. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
• We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5) Disclosure of Personal Information

• Fairly Staffing may disclose your Personal Information without your knowledge or consent in certain circumstances. Fairly Staffing may disclose information when we, in our sole discretion, deem it necessary in order to protect our rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Conditions.
• We may share your Personal Information with the parties set out below for the purposes set out in the table in paragraph 2(d) above.
• -Third party transaction platforms such as Paypal and Stripe for the purpose of receiving payment from Users.
• -Employers, with whom you will have been matched, for the purposes of facilitating placement, enabling the Employer to contact you, and providing updates and other communications relevant to the placement with the Employer.
• -Contractors, with whom you have been matched, for the purposes of facilitating placement, enabling the Contractor to contact you, and providing updates and other communications relevant to the placement with the Contractor.
• -Promotional partners, if you have given us or them your opt-in consent.
• -Service providers who provide IT, software, marketing, advertising, and system administration services.
• -Third party agencies, such as credit reference agencies and fraud prevention agencies, for fraud prevention and detection purposes.
• -Providers of professional services such as lawyers, bankers, accountants, and insurers who provide legal, banking, consultancy, accounting, insurance and other related services.
• -Third parties approved by you, such as social media providers.
• -The Canada Revenue Agency, governmental regulators, and other authorities based in Canada who require reporting of processing activities in certain circumstances.
• -Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, or with whom we may choose to acquire or merge with.
• We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We only permit third party service providers to process your Personal Information for the specific purposes for which they are hired and in accordance with our instructions and this Privacy Policy.

6) International Transfers (for residents of the European Union only)

• Fairly Staffing and some of our external third party service providers or partners are or may be based outside the European Economic Area (EEA), in which case, the processing of your Personal Information may involve a transfer outside the EEA.
• Whenever we transfer your Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
• -We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission (such as Canada, the United States, New Zealand, and Switzerland).
• -Where we use service providers based in the U.S., we may transfer Personal Information to them if they are part of the Privacy Shield.
• Alternatively, we may transfer your Personal Information outside the EEA where data protection law allows or requires us to do so.

7) Request for Correction of Personal Information

• Individuals are permitted, by law, to submit written requests to obtain the following:a)
• Internet Explorer
• a) Their Personal Information under the custody or control of Fairly Staffing;
• b) Information about the purposes for which their Personal Information under the custody or control of Fairly Staffing has been and is being used; and
• c) The names of persons to whom and the circumstances in which their Personal Information has been and is being disclosed by Fairly Staffing.
• Each such request will be responded to as accurately and completely as reasonably possible. An individual’s ability to access his or her personal information under the control of Fairly Staffing is not absolute. Fairly Staffing shall not disclose personal information where doing so would likely reveal personal information about a third party, or where Fairly Staffing chooses not to disclose the personal information, including where disclosure would reveal confidential commercial information.

8) Data Retention

• We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
• The appropriate retention period for Personal Information will depend on the purpose for which the Personal Information was collected, available alternative means to achieve such purposes, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, and the Applicable Law.

9) Your legal rights

• Under certain circumstances, you may have rights under the Applicable Laws in relation to your Personal Information, including the right to:
• Internet Explorer
• Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. See Section 6, above.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information if there is no longer a reason for us to retain it. You also have the right to ask us to remove your Personal Information if you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Information to comply with local law. In certain circumstances, we may not be able to comply with your request. In such circumstances, we will notify you of the legal reasons for such inability, if available.
• Object to processing of your Personal Information if your particular circumstances make you want to object to the processing of your information as you feel it impacts your fundamental rights and freedoms. In some cases, we may have overriding compelling legitimate grounds to process your Personal Information.
• Request restriction of processing of your Personal Information. You may request the suspension of the processing of your Personal Information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Information. Please note this will not affect the lawfulness of any information processing carried out before your withdrawal of consent. If withdrawal of consent affects the provision of any of our services to you, we will notify you at the time you withdraw your consent.
• If you wish to exercise any of the rights set out above, please contact us.
• You typically do not have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is to ensure that your Personal Information is not given to persons not authorized to receive such information. We may also contact you to ask you for further information regarding your request to facilitate our response.
• We try to respond to all legitimate requests within one month. In some circumstances, such as when you make multiple requests and/or a complex request, we may take longer to respond.

10) Changes in Policy

• The Fairly Staffing reserves the right to change the Conditions and this Privacy Policy at any time. Any changes will be posted on the Site so that you are always aware of the Privacy Policy.
• Unless stated otherwise, the current Privacy Policy applies to all information obtained about you and your account.

11) Contacting or Communicating with Us

• Fairly Staffing is the controller and responsible for your Personal Information.
• If you have any questions or concerns with respect to the Privacy Policy concerning the handling of your Personal Information, or if you wish to request access to, or correction of, your Personal Information under the care and control of Fairly Staffing, please contact [NAME AND EMAIL ADDRESS] in writing. If you are writing with respect to concerns, you have regarding the handling of your Personal information, please state the reason for your concern. If you remain dissatisfied after we have reviewed and responded to your concern, you may wish to contact the Office of the Privacy Commissioner of Canada at:
• Office of the Privacy Commissioner of Canada
  30 Victoria Street
  Gatineau, Quebec
  K1A 1H3