Personal Information That You Provide
When you use FidSafe, we collect some personal information about you, such as your name, date of birth, telephone number and email address. If you decide to use FidSafe’s sharing functionality, you provide similar information about your sharing partner, such as name and email address. In addition to this information, we may also collect technical and navigational information such as computer or other device, browser type, Internet Protocol address, web pages visited and time spent on the FidSafe website, and Content-related information such as document file name, size and type.
FidSafe may use information about you, such as your name, email address and date of birth, to service and protect your Account, communicate with you and make you aware of new FidSafe products and services. This information may also be shared with affiliated Fidelity Investments companies to perform administrative and other services for FidSafe. The technical and navigational data collected may be used by FidSafe and its affiliates for analytical purposes, improving the FidSafe product and customer experience and to protect your Account.
If you want to update your personal information or close your Account, you can do so on the website’s profile page. Or, you may contact us by telephone or postal mail at the contact information listed at the end of this Policy.
Your Account Content
Your Account Content includes the various electronic files and information uploaded and input into your FidSafe Account. Access and use of your Account Content by you and your sharing partners is controlled by you. FidSafe contracts with a limited number of third-party service providers to furnish and support FidSafe services including the storage of your encrypted Account Content. Your Account Content remains encrypted and is not accessed, used or shared by FidSafe or its third-party service providers for any purpose, except at your direction or as required or permitted by law.
FidSafe also makes its services available to affiliated and unaffiliated organizations so they, at your request, may make documents and other electronic files available to you and you to them. If you choose to use FidSafe through your relationship with any of these organizations, FidSafe may upload electronic files into your Account as instructed by you either directly or as forwarded by that organization. In addition, certain activity information such as the date and time you retrieved an electronic file may be made available to that organization.
We retain your personal information and your Account Content for as long as your Account is active, or as needed to provide you services, and as necessary to comply with our legal obligations.
Protecting Your Information
The security of your personal information and electronic files is taken very seriously by FidSafe. All of your Content is considered highly sensitive information and is treated with a commensurate level of security and protection. Physical, electronic and procedural controls are maintained to protect the confidentiality, security and integrity of your Account Content and these controls are adapted to respond to changing requirements and advances in technology. While we cannot guarantee absolute security, our efforts include firewall barriers, encryption of your Content while in transit and at rest, authentication procedures, and audit logs, among others, designed to maintain the security of your Content and prevent unauthorized access.
Cookies and Other Online Technologies
When you access FidSafe from a computer or other device, we may collect certain information from that device about your browser type, location and Internet Protocol address through cookies or similar technologies.
FidSafe also uses tools, such as Google Analytics, to help us analyze how you and other visitors use our website and to improve its functionality. FidSafe does not provide any personal information about you to Google Analytics and any information collected by Google is done anonymously without identifying an individual user. We do not associate information collected by Google Analytics with information you may have provided to us. For more information on Google Analytics, including how to opt-out, click here.
Protecting Children’s Privacy Online
FidSafe’s website and other FidSafe applications are not directed to individuals under the age of thirteen (13). FidSafe does not intentionally collect information on FidSafe’s website or other FidSafe applications from those we actually know are under the age of 13, and we request that these individuals do not provide personal information through the site and other applications.
Supplemental information for California Residents
- Why we provide additional information
- Categories of personal information we may collect about you
- Categories of sources from which personal information is collected
- Why we collect personal information
- How we share personal information about you with third parties
- Categories of personal information disclosed for business purposes
- Information regarding the CCPA
Why we provide additional information
This Supplement is provided for purposes related to the California Consumer Privacy Act of 2018, as amended (the “CCPA”) and applies to the personal information and that is subject to CCPA. As used in this Supplement, “personal information” means information that is considered to be personal information as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.
Categories of personal information we may collect about you
In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and the products and services that we provide to you. The categories of personal information that we may collect about you are:
- Personal identifiers, such as your name, address, email address, and other unique identifiers
- Information covered by California’s records destruction law (California Civil Code $1798.80), such as your signature, telephone number and financial account information
- Commercial information, such as records of the products and services we have provided to you, and transactions in your account
- Characteristics of protected classification
- Internet and other electronic network activity information, such as information regarding your interactions with our websites and applications
- Audio, electronic, visual and similar data
- Professional or employment-related information
- Analytical information
- Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences and characteristics
Categories of sources from which personal information is collected
- Information provided by you when registering on our website
- IP address
- Activity information from the logs captured on the application
- When an existing customer of ours who knows you, adds you as their contact on the application
Why we collect personal information
- Marketing and communication purposes
- Reporting and analytical purposes
- Personalizing your interactions and experiences with us
- Training and quality control measures
- Verify your identity
- Protect against malicious, fraudulent or illegal activity
- Business analysis, planning and reporting
- Customer education
- Effectiveness measurements
- Adhere to applicable laws and regulations
- Provide you information about products and services that may interest you
How we share personal information about you with third parties
We do not share personal information about you with unaffiliated third parties for their use in marketing their products and services (except in those circumstances where you have directed or authorized us to share your information with a particular third party). In addition, we do not sell personal information about you and have not done so at any time during the twelve month period preceding the date of this Supplement. As required by the CCPA, we disclose that we do not sell personal information of minors under 16 years of age.
Categories of personal information disclosed for business purposes
Like most businesses, we disclose personal information to third parties for our business purposes. Depending on the nature of your relationship and your interactions with us, and the products and services that we provide to you, we disclose (and during the twelve month period preceding the date of this Supplement, we have disclosed) for business purposes the personal information that is encompassed by one or more of the categories described above in the section entitled “Categories of personal information we may collect about you”.
Information regarding the CCPA
The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents have under the CCPA generally. Please note that the CCPA contains a number of exemptions and exclusions, so some or all of these rights may not apply to you with regard to personal information collected by us. Please see “CCPA exemptions” below for more information. As used below, a “consumer” means a resident of the State of California and a “covered business” means a business that is subject to the CCPA.
- A consumer has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the following:
- the categories of personal information it has collected about that consumer,
- the categories of sources from which the personal information is collected,
- the business or commercial purpose for collecting or selling (if applicable) personal information,
- the categories of third parties with whom the covered business shares personal information, and
- the specific pieces of personal information it has collected about that consumer.
These disclosures are not required to include any information about activity that occurred earlier than twelve months prior to the date the covered business received the consumer’s request.
- A consumer has the right to request that a covered business delete any personal information about the consumer which the business has collected from the consumer. However, the covered business is not required to comply with such a request if the covered business needs to maintain the consumer’s personal information for certain purposes set forth in the CCPA.
- A consumer has the right to request that a covered business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer:
- the categories of personal information that the covered business collected about the consumer,
- the categories of personal information that the covered business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold, and
- the categories of personal information that the covered business disclosed about the consumer for a business purpose.
- A consumer has the right to direct a covered business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
- A covered business cannot discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
The requests described in this section that a consumer can make to a covered business are referred to as “CCPA requests”.
CCPA Exemptions: Please note that certain types of personal information collected or maintained by a covered business are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases no obligations, under the CCPA with regard to the following types of personal information:
- personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act, (Public Law 106-102), and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the California Financial Code)
- medical information governed by the Confidentiality of Medical Information Act (Part 2.6 (commencing with Section 56) of Division 1 of the California Civil Code) or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5)
- personal information collected from a job applicant, employee, owner, director, staff member, officer or contractor of a covered business when the information is used by the covered business within the person’s role as a job applicant, employee, owner, director, staff member, officer or contractor of the covered business
- personal information about an employee, owner, director, officer or contractor of another business that is collected by the covered business in connection with due diligence activities regarding the other business, or in connection with the covered business providing or receiving a product or service to or from the other business
In addition, some businesses are not subject to the CCPA, such as:
- a business that does not do business in the State of California
- a business that is not organized or operated for the profit or financial benefit of its shareholders or other owners
- a business that does not determine the purposes and means of processing consumer’s personal information
- a business that has annual gross revenue of $25,000,000 or less
Furthermore, under the CCPA there are number of situations where a covered business may refuse to honor a CCPA request to delete a consumer’s personal information and is allowed to continue to maintain the consumer’s personal information. Some examples include situations where retention of the personal information is necessary to:
- complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of the covered business’s ongoing business relationship with the consumer, or otherwise perform a contract between the covered business and the consumer
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
- exercise free speech or another right provided for by law
- enable internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the covered business
- comply with a legal obligation
- otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information
Please note that the description of the CCPA set forth in this Supplement is a summary of only certain aspects of the CCPA and is not, and should not be considered to be, a complete description of the CCPA. In addition to what is described above, the CCPA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer’s request to delete the consumer’s personal information.
If you are a CA resident and wish to submit a CCPA request to FidSafe, you may initiate your request through one of the options below. Before submitting your request, please ensure you have reviewed the CCPA Exemptions above where FidSafe may have no obligation under the CCPA to accept any requests.
- Using the form below
- Email us at email@example.com
- Call us at 1-800-453-3332
Through the request process we will make you aware of any information that you will need to provide to us in order to process your request. Additionally, that information you provide will be used to help verify your identity.
For questions or concerns about a FidSafe’s privacy policies and practices, please contact us by emailing firstname.lastname@example.org or calling us at 1-800-453-3332.
Click here California Consumer Protection Act (CCPA) Question Form.
Fidelity Wealth Technologies, LLC
245 Summer Street, V7A
Boston, MA 02210
Revised and effective October 2018.
©2019 FMR LLC. All rights reserved.