YOUR PRIVACY IS IMPORTANT TO US
Fit First® recognizes its obligation to its users, community and online visitors to adhere to the highest standards of decency, fairness and integrity in all its operations. Likewise, Fit First® is dedicated to the fundamentals of protecting consumer privacy on the internet, especially for children. We support active self-regulation and adherence to recognized best practices where regulations do not exist and to compliance with personal information protection legislation where such legislation exists.
We want to ensure that your experience with this Site is a comfortable, safe and secure one.
What personal information of mine is collected through the website?
This Site is primarily a matchmaker, facilitating the intelligent matching of people to opportunity with the use of proprietary tools and cutting-edge science. There are three types of people who may access the Site and the information we collect about each one is different:
Visitors – Visitors to the Site may visit various pages on the Site to learn more about the services we offer and explore other information we publish. We do not collect any personal information from visitors to the Site until they specifically request something or decide to sign up as a user.
User (Employer) – As an Employer you will need to supply your basic contact information when you sign up to use the service (name, email address and company). If you subsequently decide to use any of our paid services, we will require credit card or invoicing details to process the payments for these services.
User (Individual Job Seeker) – As an Individual User you will need to supply your basic contact information when you sign up for the service (name and email address). If you subsequently either apply for a job and/or create a personal profile you will be required to enter information to complete your application or profile. This information includes information typically found in a résumé, such as your work experience and education, as well as responses to questions asked in relation to the position you are applying for (e.g., “How many years of experience do you have in a direct sales role?”). All Individual Users who are applying for a job will also need to complete our TalentSorter assessment, which involves responding to between 50 and 250 questions
We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency or to collect a debt owed to us.
As you explore the Site, we may also collect information via frequently used information-tracking tools, such as “cookies”. These cookies collect information such as your browser type, your Internet Protocol (IP) address and the actions you take on the website (i.e. pages viewed and links clicked).
How is this information used?
The information we gather from Employers allows us to communicate with each Employer individually and provide them with the transactional communications necessary for their account. We may additionally use this information to send marketing or other communications unless the Employer has opted-out (see below).
The information we gather from Individual Users will be used to communicate directly with each Individual User and provide them with the transactional communications necessary for their account. We may additionally use this information to send marketing or other communications unless the Individual User has opted-out (see below).
Additionally, any information the Individual User has included in his or her profile or in the course of an application for a specific job application will be made available to the Employer who posted the job in order to help that Employer to sort and select candidates to create the best shortlist for the position they are looking to fill. If the Individual User has chosen to make their profile “open”, certain aspects of it (résumé, experience, education, etc.) may be visible to other employers or intermediaries who may be looking for candidates.
Do you share my information with anyone?
Fit First® uses a third-party company to manage credit card processing. This company is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on Fit First®’s behalf and they are required to maintain the confidentiality of the information we provide to them.
We may also share non-personally identifying information in the aggregate with third parties, such as the media, industry observers, potential customers or partners. For example, we may disclose the number of users that have been exposed to, or clicked on, through our Site.
Fit First® also partners with third party scientific partners in order to continually validate and strengthen the predictive value of our psychometric assessment. The responses to the personality assessment questions may be provided to our scientific partners in a non-identifiable format to permit the scoring of those responses. In other words, none of your personally identifiable information will be provided to, or otherwise associated with your responses to the personality assessment questions provided to our external scientific partner solely for the purpose of permitting scoring of your assessment so there will be no ability for our scientific partner to identify you when scoring the personality assessment. All communications with our scientific partners are done via a secure interface and no personal details of the Individual User will be transmitted with the response or the returned scores.
How do we obtain your consent?
Individual Users are also able to opt-in at sign up to have their profile information visible to multiple users of the systems (other employers, coaches, government organizations, etc), or only to the Employer of a specific job to which they are applying. This option is also configurable in the user account management screen and can be changed at any time.
How do I “opt-out” of marketing communications?
We respect and abide by Canada’s Anti-Spam Legislation (CASL), one of the most stringent anti-spam laws in the world. We ask for your explicit consent; you are able to opt-out of marketing and non-transactional communications when you sign up for an account on this Site, or at any subsequent time with the click of a button. If you initially opt-in at sign up but would like to change this later, you can choose to be excluded from marketing and non-transactional communications at any time by de-selecting those options in your account. You can also request this via our support options or by contacting Privacy@FitFirstTechnologies.com.
How do you keep my information safe and secure?
We are committed to protecting the security of your personal information. We employ reasonable technical, administrative and physical safeguards to protect the confidentiality of your personal information, employing industry-recognized technical safeguards, such as firewalls, and have adopted and implemented security procedures to protect your information from loss, misuse or unauthorized alteration. Notwithstanding our efforts, we cannot guarantee absolute or unqualified protection of this information given the open nature and resulting instability of the Internet and World Wide Web, and we make no representations or warranties as to the effectiveness of our security and assume no liability for security breaches or any failure in the security of your computer equipment, your Internet service provider or other networks and communications providers.
Third Party Links
The Site provides links to third-party websites, such as those listed in a job posting. While on these sites, we or these third parties may collect information about you. In addition, you may be asked to provide certain personal information in connection with their use of their products and or services, such as when you respond to a survey or register or pay for a product, or otherwise.
Because we do not control the information policies or practices of these third parties, you should review their privacy policies to learn more about how they collect and use personally identifiable information. We are not responsible for the privacy practices of any third parties.
We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie (_ga) with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have – or ask us to delete any GA data – please delete your _ga cookies, contact us, and/or install the Google Analytics Opt-Out Browser Add-On.
Our Site is not directed to persons under 16. We do not knowingly collect personally identifiable information from children under 16. In communicating with children 16 years of age or older, Fit First® is especially mindful of the need to protect their personal privacy. In doing so your child will be asked to provide parental information confirming your consent for him/her to do so. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us by phone at +1 800-513-7277 or by email at privacy@FitFirstTechnologies.com. If we become aware that a child under 16 has provided us with personal information, we will delete such information from our files.
Please note that privacy laws in some provinces are different than those in Nova Scotia (where the Fit First® registered office is based) or under federal Canadian law. The onus is on the user to keep apprised of the laws of their home jurisdiction.
General Data Protection Regulation (GDPR)
GDPR is a European regulation, enacted to protect the data privacy rights of European citizens. It sets a high standard for protections (currently the highest in the world); standards which we agree with and adhere to.
GDPR – What You Need to Know
The EU has implemented GDPR to make sure that private individuals’ data (PII or Personal Information) is processed and managed transparently, and only for the specific purposes cited by the companies that hold the data.
When it comes to Fit First®, the most relevant forms of data include personally identifiable information (or PII), like people’s names, e-mail addresses, and any other information that distinguishes someone’s identity.
How Has Fit First® Prepared for the GDPR?
At Fit First®, we take compliance very seriously. For GDPR, we are working to ensure that we are compliant with the rules laid out by the law, and that we provide product functionality that enables our customers to remain compliant.
Fit First® collects data to operate effectively and to provide you with the best experiences while using our products. You provide some of this data directly, such as when you take an assessment, create an account, interact with the website, or contact us for support. We collect some of this data by using cookies, and we also obtain data from third parties. Information can be collected from the website and blog, directly from our customers, and from the customers’ test takers through several forms on our websites.
We are committed to providing you with an online experience that respects and protects your personal privacy choices and concerns.
Who is Covered?
Part of GDPR includes definitions of different roles and their responsibilities: Data Controller, Data Processor, and Data Subprocessor. In most situations, here is how GDPR roles are applied and what they entail:
Data Controller = Employer or other End User (Agency, Job Developer, Coach, Consultant, Service Provider)
The controller is the natural person or legal entity that determines the purposes and means of the processing of personal data (e.g., in collecting, using and processing an employee’s or job candidate’s personal data, the employer or end user is considered to be the controller).
As a data controller, that organization is responsible for all personal data they have access to for individuals in the EU. This applies to user data stored in electronic or printed PDF reports, emails, spreadsheets, other online services, paper files, etc. As such, the data controller may be required to appoint a Data Protection Officer to ensure that the organization (and their data processors) is in compliance with GDPR.
Data Processor = Fit First® and Authorized Partners
A natural person or legal entity that processes personal data on behalf of the controller (e.g., a consultant acting on behalf of its client) is considered to be a processor. Authorized Partners may be involved in processing the data, including the use of TalentSorter or other platforms for user assessment and report delivery.
Both Controller and Processor
There are instances where Fit First® may act as both Controller and Processor, collecting data provided by Job Seekers and using it to identify employment or training opportunities that may be of interest, presenting them to the individual for consideration and, if directed to, making the introduction.
As such, Fit First® has appointed a Data Protection Officer to ensure that Fit First® is in compliance with GDPR.
Fit First® (as the “data processor”) is able to effectively support clients (“data controllers”) who have employees and applicants residing in the EU as they also meet their own obligations under the GDPR.
Specific Provisions under GDPR
GDPR describes seven very specific rules and protections:
- Data breach notification
- Right to access
- Right to rectification
- Right to be forgotten
- Data portability
- Right to notice
- Right to object
Data Breach Notification Rule: Data Processors are required to notify their customers (the controllers) of a data breach without delay. The supervisory authority must be notified within 72 hours of occurrence.
Fit First® Actions: Any security or privacy breach, or any other circumstances that may have resulted in unauthorized access to, disclosure of, or use of customer data, will be communicated by a message displaying the relevant details. Significant security incidents will also be announced via email or phone.
On discovery of a breach, Fit First® will notify the user of the occurrence immediately, not exceeding 48 hours after the occurrence.
Right to Access Rule: The Data Controller must receive consent from the individual after informing them what kind of personal data will be collected or processed and for what purposes.
We request a separate consent for receiving marketing communication. Website visitors can always decline to submit their personal information through our forms. In this case, Fit First® may be unable to provide certain services to them.
For more information about Fit First®’s information collection practices, please contact Privacy@FitFirstTechnologies.com.
Right to Rectification Rule: The right to rectification refers to the correction of inaccurate personal data without undue delay. The rectification will be communicated to each recipient who receives the data unless this proves impossible or involves disproportionate efforts.
Fit First® Actions: You can choose to view or correct your personal data by following the specific steps for the category you fit in:
- Marketing subscribers: If you would like to view or correct your personal data information, please contact us at Privacy@FitFirstTechnologies.com, Subject: PII Information.
- Test-Takers: Upon request, Fit First® will let you know whether we hold or process your personal information (PII) on behalf of a third party. To request this information, please contact us at Privacy@FitFirstTechnologies.com, Subject: PII Information. Fit First® will reply to your request in an e-mail within an estimated period of 30 (thirty) days.
- Customers: If you are a Customer, you may submit a request to access, review, correct, or delete your PII by contacting Privacy@FitFirstTechnologies.com with the Subject: PII Changes. If you are a Customer, we cannot delete all of your PII unless we also delete your user account. If you wish to cancel your account, please contact your account manager.
- For all three of the above-mentioned categories, you can always choose whether you wish to receive promotional e-mails, telephone calls, or postal mail from Fit First®. Every marketing email from Fit First® contains instructions for how to opt out of receiving further marketing e-mails.
- We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to become incorrect.
- Since we keep track of past transactions, you cannot delete information associated with past transactions on the Websites or through the Services. In addition, it may be impossible to completely delete your PII because some residual information may exist in archived data backups. Finally, we reserve the right to retain and use your PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Right to Be Forgotten Rule: Individuals have the right to have the data controller erase or anonymize their personal data, cease further dissemination of the data, and potentially have third parties halt the processing of the data. The right to delete the data (“the right to be forgotten”) enables the individual to ask the controller to delete personal information, without any delay, should one of these conditions be met:
- The data is no longer necessary to meet the purpose for which they were collected and processed.
- The individual withdraws the consent they had given, so there is no legal basis for processing their personal data.
- The data has been processed illegally.
- The personal information needs to be deleted in compliance with a legal obligation.
Fit First® Actions: You can choose to view or correct your personal data by following the specific steps for the category you fit in:
- Marketing subscribers will be able to delete their PII by contacting Privacy@FitFirstTechnologies.com, which will allow them to request the removal of their personal information from Fit First®’s marketing database. Their request will be processed within one week.
- Test-takers who have not been hired by a customer have the “right to be forgotten” and Fit First® customers will be required to anonymize a test taker’s personal data when requested by the test taker. Fit First® will provide tools that allow them to anonymize the information, so that it won’t be accessible via the Fit First® platform. If a test-taker has been hired, then Fit First® will ensure that the Customer has an appropriate record for their legitimate purposes before the data is anonymized.
- Customers may submit a request to delete their PII by contacting Privacy@FitFirstTechnologies.com with the Subject: PII Changes. If you are a Customer, we cannot delete all of your PII unless we also delete your user account.
Data Portability Rule: Individuals have the right to receive their personal data in a structured format that is currently used and is automatically readable. The Data Controller will need to provide this data to the individual upon request in an efficient and easy format.
Fit First® Actions: By default, Fit First® offers several formats for exporting test taker information data in several formats, such as PDF, Word, Excel, and CSV. The Customer will have access to all the necessary tools for an easy export.
Enhanced Rights to Notice Rule: Data Controllers are required to provide a variety of details at the time the data is requested (for example, when an individual takes a test), including why they are requesting certain information, how long it will be stored, and where it will be sent.
The Right to Object Rule: Individuals have a right to restrict their personal data from being used for direct marketing purposes.
Fit First® Actions: For all our website visitors, we will provide a user notification (displayed at the bottom of all website forms) and request user consent to receive marketing communications from Fit First®. All our subscribers, customers or partners will be able to unsubscribe at any time and request the removal of their personal information from Fit First®’s marketing database. Requests should be directed to Privacy@FitFirstTechnologies.com
Feedback/Communication and Choice
From time-to-time our site requests information from users via surveys, email communications or contests. Participation in these surveys, email communications or contests is completely voluntary, and the user therefore has a choice whether or not to disclose their job search-related information. Information requested may include any job search-related information, such as contact information (such as name and shipping address), and demographic information (such as zip code). Information collected will be used for purposes of monitoring or improving the use, satisfaction and services of this site.
Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site at the point where we ask for the information. Users who no longer wish to receive contact from Fit First® or from our partners may opt-out of receiving further communications from a particular party by replying with unsubscribe in the subject line in the email or email us at info@FitFirstTechnologies.com
Fit First® Referral Program
When you register with any of our Sites, you will be able to refer friends and/or employers who you think might be interested in our unique services. Individual users are able to refer people using tools such as the Career Planning Report. Employers can refer other employers as well. Fit First® does not store the referred person or employer’s email address until they register themselves. We do not sell referral email addresses to any third parties. We at Fit First® strongly encourage all our members not to engage in spamming activities. The referred party may contact the Privacy Officer at info@FitFirstTechnologies.com to request the removal of this information from our database.
If you use a blog or testimonial on this site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. For testimonials, we do obtain the customer’s consent prior to posting their name along with their testimonial. We are not responsible for the personally identifiable information you choose to submit in these forums. If you want to remove your personal information that is being displayed on our website under public pages, please contact us at info@FitFirstTechnologies.com.
Social Media Widgets
As a User you can elect to be excluded from any surveys, contests or announcements, which may be sent out by Fit First® at any time. Individual Users may do this by going to the “preferences” area of their “Personal Profile” page and de-select the option, or simply using the opt-out feature on any email sent to you from Fit First®. Employers may do this by going to the “Account” tab. In these areas we may use your information to make you aware of additional products and services, which may be of interest to you, or to contact you regarding site changes. You may access and edit all of your personal information at any time. We will retain your personal information for as long as you remain a user or for as long as legally required. Users may terminate, correct, update, amend, delete/remove their account with Fit First® by sending a request to our customer service department through the ‘Contact Us’ section of our site or by emailing us at info@FitFirstTechnologies.com.
When you use “Share This” to bookmark and share our products and site, you will be taken to a third party site. Please note that these third party sites’ privacy policies govern the collection and use of the information collected on those sites.
How do I contact you to get more information about a privacy issue or concern?
Effective January 1, 2022