Privacy

Effective as of July 27, 2020

A. GENERAL 

 

This privacy policy (this “Privacy Policy”) describes how Figure 1, Inc. (“Figure 1” or “we” or “us”) collects, uses, discloses, handles, or otherwise processes the personal information of the users (“you” or “your”) of Figure 1’s website (the “Website”), located at: www.figure1.com, and proprietary software application (the “Application”), and the features either in the Website or Application, including a method for viewing medical cases, a database of medical images, comments and questions, and mechanisms for users to upload medical cases to the database (collectively, the “Services”). 

 

(i)) Acceptance of Terms

 

Please read this Privacy Policy carefully to understand Figure 1’s policies and practices surrounding the collection, use, storage, handling and processing of your personal information in connection with your use of the Website, Application or Services. 

 

By using the Website, Application or Services, you agree to the terms of this Privacy Policy, and you expressly consent to Figure 1’s collection, use, disclosure, handling or processing (including, for certainty, any deletion or removal, storage or alteration) of any personal information (including, to the extent any Personal User Information, User-Provided Case Information and Automatically Collected Information, each as defined below, include your personal information) that you submit or otherwise provide to us through the use of the Website, Application or Services, as more fully described in this Privacy Policy. 

 

IF YOU DO NOT AGREE TO ANY OF FIGURE 1’S COLLECTION, USE, DISCLOSURE, HANDLING OR PROCESSING OF YOUR PERSONAL USER INFORMATION, OR ANY OF FIGURE 1’S POLICIES AND PRACTICES REGARDING THE FOREGOING AS DESCRIBED IN THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY DISCONTINUE AND CEASE TO USE THE WEBSITE, APPLICATION AND SERVICES.

 

(ii) Privacy Complaints or Inquiries

If you have any questions regarding your privacy with respect to your use of the Website, Application or Services or Figure 1’s practices or policies as described under this Privacy Policy, or wish to make a complaint about Figure 1’s collection, disclosure, use, handling or processing of your personal information, please contact Figure 1 via email at: privacy@figure1.com. We will make every effort to investigate and respond to your questions or complaints in a timely way.

Provided that you do so in good faith, asking any privacy questions or lodging any complaints pursuant to this Privacy Policy will not restrict or prohibit your use of the Website, Application or Services. Further, you acknowledge and agree that any complaints that you lodge regarding Figure 1’s compliance with applicable privacy laws, whether or not such complaints are thereafter substantiated by any arbitrator, court, tribunal or governmental authority with competent jurisdiction, will not release you from any duties or obligations that you owe to any third parties (including, if applicable, any of your patients) under any applicable local, national, provincial, state, and federal laws. 

 

(iii) Changes to this Privacy Policy

 

Figure 1 reserves the right to amend this Privacy Policy, in its sole discretion, from time to time for any reason. Each time you use the Website, Application or Services, the most current version of the Privacy Policy will apply. If Figure 1 makes any changes to this Privacy Policy, Figure 1 will post an updated copy of the Privacy Policy. You agree that your continued use of the Website, Application and Services, after we make any such changes to this Privacy Policy, indicates that you accept and consent to any changes made to Figure 1’s Privacy Policy. We therefore advise you to consult this Privacy Policy regularly for any changes. We will not materially change Figure 1’s policies and practices surrounding your personal information that make them less protective of your privacy without the consent of affected users.

B. INFORMATION WE COLLECT WHEN YOU USE THE WEBSITE, APPLICATION AND SERVICES 

 

Figure 1collects the following information from you when you register for a user account to use and when you use the Website, Application and Services, as further described below: (i) Personal User Information; (ii) User-Provided Case Information; (iii) Optional User-Provided Information; and (iv) Automatically Collected Information.

 

(i) Personal User Information

 

When you register for a user account through the Website, Application and Services, you will be required to provide your:

  • email address;

  • username;

  • password;

  • specialty (selected from a drop-down menu);

  • country of residence;

  • areas of interest; and

  • verification details.
     

These informational elements are referred to collectively as your “Personal User Information”. 

 

(ii) User-Provided Case Information

 

Based on your account status, some of the following Services may be made available to you:

  • Upload cases with captions and tags;

  • Share cases;

  • Comment on cases;

  • Answer medical and non-medical questions; and

  • Create “Collections” in the Website and Application.

 

(a) Upload cases and captions. We will collect your uploaded cases, case captions, case creation dates, number of times the image tag is used, common variations of image tags (such as misspellings), and information on whether the tag appears in searches among other data points. 

(b) Comment on cases. We will collect your comments, the dates of comments, and the username connected to the comments.

(c) "Save" cases. We will collect the cases you have "saved" into "Collections," as well as the date they were saved and the username connected to those cases.

(d) Flag cases and comments provided by other users (i.e., to indicate that identifiable information may have been improperly included in a case, caption, or comment). Until or unless the case or comment is deleted, we will collect and store the cases and comments that you flag, the subcategory of the flagged case, the date flagged, and the username referenced to the flagged case or comment.

The information provided by performing any of the tasks listed above is referred to collectively as “User-Provided Case Information”. 

 

All User-Provided Case Information that you generate through the use of the Website, Application or Services must comply with local, national, provincial, state, and federal privacy legislation and best practices. You must remove any identifying information prior to uploading any cases through the use of the Website, Application or Services, and you agree that you shall not include any identifying information in any captions or comments. 

 

In relation to the removal of identifying information, certain portions of the Website, Application and Services include certain proprietary features, such as automatic and manual information-blocking tools, to help you remove direct identifiers and other common identifiers from User-Provided Case Information. To the extent you use any of the foregoing features, you acknowledge and agree that Figure 1’s provision and your use of any such features will not release you from any duties or obligations that you owe to any third parties (including, if applicable, any of your patients) under any applicable local, national, provincial, state, and federal laws.

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(iii) Optional User-Provided Information

 

You have the option to do any of the following:

  • Request verification of your status as a healthcare professional. If you choose this option, you will be asked to provide us with additional information, which we will cross-reference with publicly available data to ensure that you are a licensed healthcare professional. You are required to update your status as necessary.

  • Invite colleagues to join the Application and/or Website so that they can use the Website, Application and/or Services. If you choose to do this, Figure 1 may require access to the address book on your mobile device or computer to enable you to choose which of your colleagues you would like to invite to the Website, Application and/or Services.

  • Expand your user profile, by adding additional and optional information to your profile on the Website or on the Application. You may complete any of the following fields: real name, state, country, institution, categories of interest, graduation date, and years of experience, among others. You may include a short biography and upload a profile picture. You are responsible for the accuracy of all of the information you provide. 

  • Respond to surveys. We may survey users or solicit comments and opinions.

 

The information provided by performing any of the optional actions listed above is referred to collectively as “Optional User-Provided Information”. If you perform any of the activities listed above, we may collect your Optional User-Provided Information from you.

 

(iv) Automatically Collected Information

 

In order to improve the Website, Application and delivery of the Services, Figure 1 may collect certain information from you automatically when accessing or using any of the foregoing.

When you access or use the Website, Application or Services, we may automatically collect information about you, including:

  • Creation Date. We store the date your account was created.

  • Log Information. We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the link you visited before navigating the Services.

  • Device Information. We collect information about the computer or mobile device you use to access the Services including the hardware model, operating system and version, unique device identifiers, and mobile network information.

  • Information Collected by Cookies and Other Tracking Technologies. We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Services and your experience, see which areas and features of the Site are popular and count visits. We may also collect information using web beacons (also known as "gifs", "pixel tags" and "tracking pixels"). Web beacons are electronic images that may be used on the Services or emails and help deliver cookies, count visits, understand usage, campaign effectiveness, and determine whether an email has been opened and acted upon.

 

The information listed above is referred to collectively as “Automatically Collected Information”.

 

Most web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

 

(v) Information Not Collected

 

The Website, Application and Services do not collect precise information about the location of your mobile device.

 

(vi) Managing Your Information

 

You may update, correct or delete information about you at any time by logging into your user profile. Further information related to this topic can be found in the section titled Data Retention Policy.

 

(vii) How to Opt Out of Information Collection

 

You may stop all collection of information by the Application by uninstalling the Application. To do this, you may use the standard application uninstall processes of your mobile device or via the mobile application marketplace or network. Once you complete the uninstallation process, no further information will be collected from you by the Application. However, any information collected by Figure 1 prior to uninstalling the Application may be retained for certain purposes – for further detail, please see the section titled Data Retention Policy.

You may also delete your account by going to your profile on the Application and tapping and holding the “Logout” button. You will be asked to confirm that you would like to delete your account. If you confirm, your profile information will be automatically deleted from Figure 1’s server and your stored information will be dealt with in the manner described in the section titled Data Retention Policy.

 

(viii) Data Retention Policy

Figure 1 will retain User-Provided Case Information for as long as you use the Application or Services, and will delete it if you delete your account, which can be done by tapping and holding the "Logout" button on the settings page within the profile tab in the Application or by contacting us via support@figure1.com. You will be asked to confirm that you would like to delete your account. If you confirm, your profile information will be automatically deleted from Figure 1’s server. Your cases and comments will be anonymized and attributed to "Healthcare Professional." You may request to have all images and comments associated with your account deleted. However, we cannot guarantee that we will be able to recall and delete images and comments that have been provided to third parties, such as medical journals or medical education websites. Please note that we may retain certain information as required by law or for legitimate business purposes.

 

When we delete any information, it will be deleted from the active database, but may remain in Figure 1’s archives. We may also retain your information for fraud detection or similar purposes. All provisions of this Privacy Policy which by their nature should survive termination, shall survive termination, including without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

If you contact Figure 1 to delete your account, the change will be processed within seven (7) calendar days.

C. HOW YOUR COLLECTED INFORMATION MAY BE USED

 

Your Personal User Information, User Provided Case Information, Optional User-Provided Information and any other information or materials you voluntarily provide may be used by Figure 1 for enhancing the Services. Figure 1 hereby reserves the right to and may alter, decompile, dissemble, and create derivative works of any and all such materials. You expressly consent to Figure 1's use of the foregoing content in this manner and understand that such information may be cross-marketed and shared with other users and third parties who may have an interest in your use of the Website, Application and Services.

 

(i) Personal User Information

 

Figure 1 collects your Personal User Information for the purpose of administering your use of the Website, Application and Services. Your password is cryptographically hashed, and your email address is encrypted.

 

Other than where Figure 1 shares Personal User Information with third parties in accordance with this Privacy Policy, you are solely responsible for (1) maintaining the strict confidentiality of your Personal User Information, (2) not allowing another person to use your Personal User Information to access the Services, and (3) any and all damages or losses that may be incurred or suffered as a result of any activities that occur under your Personal User Information. 

 

You may opt out of receiving content announcements and messages. However, the Website and Application will not allow you to opt out of any announcements and messages related to the implementation of this Privacy Policy and your obligations hereunder. As such, should your uploaded cases, case captions, or comments contain identifying information about a patient (as described in the Terms of Service), you may receive messages from Figure 1 notifying you of a potential privacy violation associated with this content.

 

You agree to immediately notify Figure 1 in writing by email to privacy@figure1.com of any unauthorized use of your Personal User Information or any other breach of security. Figure 1 is not and shall not be liable for any harm arising from or relating to the theft of your Personal User Information, your disclosure of your Personal User Information, or the use of your Personal User Information by another person or entity. For the purposes of this Privacy Policy, if we share any Personal User Information with any third party in compliance with the terms of this Privacy Policy, the third party’s use of that shared Personal User Information will not constitute unauthorized use.

 

(ii) User-Provided Case Information

 

In order to improve the Website, Application or Services; personalize the content; and make recommendations to you, we may use and analyze the User-Provided Case Information. We may conduct surveys and research, test features in development, and analyze the User-Provided Case Information to improve Figure 1’s products and services, develop new features, and conduct audits and quality assurance.

 

Figure 1 is concerned about safeguarding the confidentiality of your User-Provided Case Information. We have implemented physical, electronic, and procedural safeguards in our Website, Application and Services to protect information we process and maintain. Also, the Website, Application and Services store de-identified images only, not the original unedited image, which may contain personally identifying features (see list of identifying features in Figure 1’s Content Policy).

We use reasonable efforts to limit access to your User-Provided Case Information to authorized employees and contractors who need to know such information in order to operate, develop, or improve the Website, Application or Services. Please be aware that, although we will take reasonable steps to safeguard and maintain security of User-Provided Case Information that we process and maintain, no security system can prevent all potential security breaches. Please refer to the Terms of Service for more details about Figure 1’s and your obligations with respect to the proper use of the Application and notification obligations thereunder.

 

(iii) Optional User-Provided Information

 

If you perform any of the activities that results in Figure 1’s collection of Optional User-Provided Information, such Optional User-Provided Information may be handled in a different way, including as follows:

  • Request verification of your status as a healthcare professional. If you are verified, we will store your status as a “verified healthcare professional.”

  • Invite colleagues to join the Application and/or Website so that they can use the Application, Website and/or Services. While we may access your address book, we do not store your complete address book.

  • Expand your user profile with additional information. This information is public and can be seen by other users of the Website, Application or Services – for further detail, please see the section titled How Your Collected Information May Be Used - Access by Other Users of the Website and Application.

  • Respond to surveys. If you respond to any survey, any information that you provide thereunder may be used to learn more about healthcare, to help improve your experience on the Website, Application or Services, and for other purposes of Figure 1

 

(iv) Automatically Collected Information

 

In order to improve the Website, Application and Services; to personalize the content; and to make recommendations to you, we use and analyze the Automatically Collected Information.

 

Figure 1 may use your Automatically Collected Information to contact you from time to time to provide you with important information, push notifications, and marketing promotions. You may opt-out of the foregoing by updating your preferences in your user account. 

 

(v) Personalization of Experience

Figure 1 uses your information to personalize the Services, including its content, marketing messages, and advertising served to you on the Website or Application and to generally enhance and tailor your experience with the Services. For example, we tailor your Website and Application profile’s focus on content relevant to your practice, specialty and inferred interests based on your profile and how you engage with the Services. We use your information to target (and measure the performance of) advertising and other content sponsored by third parties.

 

(vi) Verification

Figure 1 may use your information in conjunction with information from third parties to recognize you as a registered user of the Website or Application when you use the Services and to verify your identity and/or professional credentials. We may require you to provide proof of your identity, including that you are a healthcare professional, and if you are unable to do so to Figure 1’s reasonable satisfaction, we reserve the right to deny you access to the Services. While we take steps to verify that Figure 1’s members who identify as healthcare professionals are actually healthcare professionals, we make no guarantee as to their identity, professional credentials or licensure status.

 

(vii) Access by Other Users of the Website and Application

 

Anything you do, post, and/or share through your use of the Services may be seen by other users of the website and Application. Therefore, you do not have a reasonable expectation of privacy when using such features of the Services. Certain portions of the Services are designed to allow you to share information, cases and comments with other users of the Website and Application. 

 

D. SHARING YOUR INFORMATION WITH THIRD PARTIES

 

Information about your use of the Website, Application or Services, including any of your Personal User Information, User-Provided Case Information, Optional User-Provided Information and/or Automatically Collected Information (collectively, the “Collected Information”), may be shared with third parties or otherwise disclosed, within or outside your jurisdiction, in any of the circumstances described below.

 

(i) Service Providers

 

Figure 1 works with third party service providers to help us provide the Services and to otherwise assist us in the operation of the Website and Application. These service providers assist us in areas such as email management and deployment, analytics, marketing, advertising, market research, sweepstakes and contest administration, identity and professional credential validation, content distribution, customer service, payment fulfillment, event logistics, website maintenance and data storage and security. We may provide these service providers with Collected Information so that they can properly provide their services to us. However, we do require that they agree to limit their use of Collected Information to the fulfillment of these responsibilities.

 

(ii) User Profiles

 

Subject to applicable law, Figure 1 may provide Personal User Information and other information related to users of the Website or Application (or portions thereof) to third parties, including Figure 1’s advertising customers, which these third parties may use for their business purposes including marketing.

 

(iii) Aggregated and Anonymized Information

 

Subject to applicable law, Figure 1 may provide aggregated and/or anonymized information about users of Figure 1’s Services to third parties as we deem appropriate in Figure 1’s sole discretion. For example, we may tell a customer what percentage of registered users of the Website or Application reside in a particular geographical area or specialize in a particular clinical area, or what percentage of participants in a market research survey selected a particular response to a survey question.

 

(iv) Advertising and Sponsored Content

 

Figure 1 may provide Collected Information to third party sponsors of advertisements, subject to applicable law. Specifically, when you are exposed to or otherwise engage with an advertisement through the Services, Figure 1 may provide any Collected Information (collectively, the “Advertisement Information”), such as your name, specialty, NPI and/or license number to the applicable sponsor and/or its agents on the sponsor's behalf. The Advertisement Information that may be shared with such third parties may include details about your engagement with advertisements on the Website or Application (e.g., whether you viewed or otherwise interacted with certain content), your answers to any questions contained in the Website or Application and information about you that we have received from third parties. Prior to sharing any Advertisement Information, we require the recipients to agree to limit their use to the authorized purpose. All advertisements and other sponsored content made available within the Website or Application, including through emails, will be identified to you by the label “Promoted”, “Featured”, “Advertisement”, “Information from Industry”, “Sponsored” or some similar designation indicating that the content, which may pertain to a particular medical condition, therapy, product or service, has been selected by a third-party sponsor.

 

(v) Social Widgets

 

Figure 1 may include social widgets within Figure 1’s Website and Application, which enable you to interact with the associated social media services, e.g., to share an article. These widgets may collect Automatically Collected Information, which may be collected by the third party providing the widget. We have no control over and are not responsible for the functionality of such widgets and we are therefore not responsible for any use of the Automatically Collected Information collected and used by such widgets. Accordingly, you acknowledge and agree use of such Automatically Collected Information collected through the use of any such widget will be governed by the privacy policy of the third party providing the widget. You may be able to manage your privacy preferences directly with the applicable social widget’s platform.

 

(vi) Adverse Event Reporting

 

If you provide us information about an adverse event regarding a pharmaceutical product or medical device, Figure 1 may be required to report such information, along with your contact information, to the manufacturer in order to fulfill its reporting obligations to the applicable regulatory authority. If you do not want this information reported to the applicable manufacturer and regulatory authority, then do not provide us with adverse event information.

 

(vii) Business Transfers and Affiliates

 

Figure 1 may share Collected Information with any member of Figure 1’s subsidiaries for their use for the purposes set forth in this Privacy Policy, including to market to you through a variety of channels as described herein, subject to applicable law. In connection with a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, we reserve the right to transfer your Collected Information to the new purchaser entity or to a prospective purchaser in connection with the discussions or negotiations of an agreement concerning any of the foregoing. In the event of such a change, your Collected Information will continue to be treated in compliance with this Privacy Policy.

 

(viii) Legal Requirements

 

Figure 1 may release Collected Information when we believe, in our sole discretion, that such release (i) is required to comply with valid legal requirements under law, regulation, search warrant, subpoena or court order or to meet national security or law enforcement requirements; or (ii) is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights of us or others.

 

(ix) Consent

 

Figure 1 may disclose your Collected Information to a third party in a manner not addressed by this Privacy Policy subject to your consent at such time.

 

E. ADDITIONAL TERMS SPECIFIC TO CERTAIN JURISDICTIONS

 

(i) Notice to Residents of California

 

California law permits users of the Application in California to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, a business must either provide this information or permit California users of the Application to opt in to, or opt out of, this type of sharing. We may from time to time elect to share certain information you collected by us on the Services with third parties or affiliates for those third parties' or affiliates' own direct marketing purposes.

If you are a resident of California, California Civil Code Section 1798.83 permits you to opt out and/or request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. This Policy applies only to their activities within the State of California. To make such a request, please send an email to privacy@figure1.com or write us at:

200 Wellington St. West, Suite 900, Toronto, Ontario, Canada M5V 3C7

Any such request must include "California Privacy Rights Request" in the first line of the request and include your name, street, address, city, state, and ZIP code. Please note that we are only required to respond to one request per user of the Application each year, and we are not required to respond to requests made by means other than through this email address or mail address. California residents are also entitled to contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210 for suspected violations and to learn more about their rights.

 

(ii) Additional Terms for Residents of the United Kingdom, Norway, Iceland, Kazakhstan, Turkey, The Russian Federation, South America, Ukraine, Uzbekistan and The European Union

 

If you are a resident of the United Kingdom, Norway, Iceland, Kazakhstan, Turkey, the Russian Federation, South America, Ukraine, Uzbekistan, or the European Union, legislation* permits you to request that we tell you what personal information we hold about you and how we process it and that we provide you with a copy of that information. You are also entitled to access, rectify, change, update, delete, revoke, or improve upon your personal information at any time. You can exercise this right free of charge. We may ask you to provide further information to confirm your identity before considering your request. To make such a request, please send an email to privacy@figure1.com or write to us at:

200 Wellington St. West, Suite 900, Toronto, Ontario, Canada M5V 3C7 or

Digital + Ethics: 15 rue Rougemont, 75009 Paris (if you are a resident of France).

If you use the Application to invite colleagues to join the Application and/or Website or to share cases with a colleague, you must first have their consent to use their email address for this purpose. Figure 1 will rely on your obtaining that consent.

 

For purposes of providing the Application, Figure 1 may transfer your Personal User Information (including User-Provided Case Information) to servers located in the United States or other countries outside of the European Economic Area/Ukraine which provide for a different level of data protection. By using and continuing to use the Application, you agree to that transfer.

The Personal User Information we hold is used solely for the purposes of operating the Application and communicating with you. The information we request from you is mandatory unless indicated otherwise and is necessary to enable Figure 1 to provide you with the Application. You are also entitled to object to any processing of your personal data on reasonable grounds.

If you are a resident of Ukraine, you are hereby informed that Figure 1 shall be your personal data controller, processing information defined as User-Provided Case Information and Automatically Collected Information. Apart from the rights listed in this section above, you also have the following rights as regards personal data protection:

  • the right to be aware of the collecting sources, location of your personal data, processing purpose, location and/or place of residence (location) of the controller or the processor of your personal data, or to give the respective instruction to obtain such information to authorized parties, except the cases, established by law;

  • the right to obtain the information about the terms for granting access to your personal data, including the information on the third parties to whom your personal data is transferred;

  • the right to obtain no later than thirty (30) calendar days from the moment of the request submission, except for the cases, established by law, a response regarding whether your personal data is processed, as well as to obtain the content of your personal data currently processed;

  • the right to protect your personal data from illegal processing and unintended loss, damage resulting from purposeful concealment, nondisclosure or untimely disclosure, as well as to protect the information that is inaccurate, or discrediting honor, dignity and business reputation of the individual;

  • the right to claim for the protection of your rights with respect to your personal data to the Parliament Commissioner of Ukraine on Protection of Human Rights or court;

  • the right to bring the means of legal protection in case of violation of personal data protection legislation;

  • to make a reservation with regard to restrictions of the right to processing your personal data when granting consent to your personal data processing;

  • the right to withdraw your consent for personal data processing;

  • the right to know the mechanism of automatic personal data processing;

  • the right to be protected from an automated decision that has legal consequences for you.

 

*Legislation

Argentina – Personal Data Protection Act N°25.326

Austria – The Data Protection Act 2000

Belarus – The Information, Informatization and Data Protection Act N°455-3 of 10 November 2008

Belgium – The Data Protection Act of 08 December 1992

Denmark – The Act on Processing of Personal Data

Finland – The Data Protection Act (523/1999)

France – The Law n°78-17 on Computers and Data Processing

Germany – The Federal Data Protection Act

Greece – Law 2472/1997 on the Protection of the Individual from Processing Personal Data, as amended and in force

Iceland – The Icelandic Data Protection Act

Italy – Legislative Decree 196/2003

Kazakhstan – Law on Personal Data and Its Protection from 21 May 2013 No. 94-V

Netherlands – Dutch Personal Data Protection Act 2000

Norway – Act of 14 April 2000, No. 31 relating to the processing of personal data (Personal Data Act)

Portugal – The Data Protection Act (Law 67/98 of 26 October)

The Russian Federation – Federal Law of the Russian Federation “On Personal Data”

Spanish Kingdom – Spanish Data Protection Act 15/1999 and Spanish Data Protection Royal Decree 1720/2007

Sweden – The Personal Data Act (1998:204)

Ukraine – The Personal Data Protection Act of June 01, 2010 No 2297-VI

United Kingdom – The Data Protection Act 1998

Uzbekistan – Law on Principles and Guarantees of Freedom of Information No 439-II dated 12.12.2002

 

(iii) Additional Terms For Residents of Australia, New Zealand, China, India, Israel, Japan, and South Africa

 

If you are a resident of Australia, New Zealand, China, India, Israel, Japan, or South Africa, applicable privacy legislation permits you to request that we tell you what personal information we hold about you and provide you with a copy of that information. You also have the right to request that we correct your personal information if it is inaccurate, out-of-date, or incomplete. We may ask you to provide further information to confirm your identity before considering your request. To make an access and/or correction request, please send an email to privacy@figure1.com or write us at:

200 Wellington St. West, Suite 900, Toronto, Ontario, Canada M5V 3C7

If you use the Application to invite colleagues to join the Application and/or Website or to share cases with a colleague, you must first have their consent to use their email address for this purpose. Figure 1 will rely on your obtaining that consent.

It is not mandatory or legally required for you to provide us with any of your personal information. However, if you do not provide the information that we ask for, you may not be able to access and use all of the Application’s features available to users.

Figure 1 may transfer your personal data to servers located in other countries for purposes of providing the Application. By using and continuing to use the Application, you agree to that transfer. If you are an Australian resident, you acknowledge that by providing your consent to the transfer to servers located outside Australia, we are not required to take reasonable steps to ensure your personal information is handled in accordance with Australian privacy law.

If you are a resident of China, if you notice any personal information leakage or otherwise have any complaint about the protection of your personal information, please contact privacy@figure1.com. We will respond within fifteen (15) days of the receipt of your email.

 

(iv) Additional Terms for Residents of Lebanon

 

If you are a resident of Lebanon, by tapping the “GET STARTED” button, or accessing or using the Application, you are confirming your approval to have this Privacy Policy drafted in the English language.

 

(v) Additional Terms for Residents of South Korea

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If you are a resident of South Korea, we will collect and use your User-Provided Case Information and Automatically Collected Information (hereinafter collectively referred to as “Personal Information”) after you provide your express prior consent.

It is not mandatory for you to provide us with any of your Personal Information. However, if you do not provide the information that we ask for, you may not be able to access and use all or parts of the Application’s features available to users.

The Personal Information Protection Act and Act on Promotion of Information and Communications Network Utilizations and Information Protection permit you to request that we tell you what Personal Information we hold about you, how we process it, and that we provide you with a copy of that information. You are also entitled to access, rectify, change, update, delete, revoke, or improve upon your Personal Information at any time. You can exercise this right free of charge. To make an access and/or correction request, please send an email to privacy@figure1.com or write to us at:

200 Wellington St. West, Suite 900, Toronto, Ontario, Canada M5V 3C7

The contact details of Figure 1’s Privacy Officer in charge of protecting and managing your Personal Information, and handling inquiries and complaints concerning Personal Information, are as follows:

 

All of your Personal Information will be stored, processed, and transmitted after encryption.

You may block cookies by activating settings on the browser that allow you to refuse the settings of all or some cookies. Click here for more information about cookies.

We may transfer your Personal Information to servers located in other countries for purposes of providing the Application, after your express prior consent. Figure 1’s servers are currently located in the United States of America.

We do not disclose your Personal Information to any third parties, including service providers.

When we destroy Personal Information, we will take commercially reasonable and technically possible measures to ensure that the information is not restored or regenerated. If we need to retain Personal Information instead of destroying it, we will store and manage such Personal Information or the Personal Information file separately from other Personal Information, to the extent technically possible. If the Personal Information that needs to be destroyed is in the form of an electronic file, we will permanently delete such information in an irrevocable manner. Any other document, printout, letter, and other recorded media will be destroyed by incinerating or shredding.

If you use the Application to invite colleagues to join the Application and/or Website or to share cases with a colleague, you must first have their consent to use their email address for this purpose. Figure 1 will rely on your obtaining that consent. The Application will allow you to directly share information and/or send invitations to your colleagues. Figure 1 will not collect or store the email addresses of your colleagues during this process. 

ABOUT FIGURE 1
LEGAL
HOW  FIGURE 1 WORKS
PRESS