PRIVACY POLICY

FINANCIALLY FIT EMPLOYEES, INC.
PRIVACY STATEMENT
Last Updated: August 21, 2018

Financially Fit Employees, Inc. and its related companies (“Company” or “FFE”) is committed to protecting the privacy of individuals who visit the Company's web site and individuals who use the Services as defined below ("Customers"). This Privacy Statement (“Statement”) describes Company’s privacy practices in relation to the use of the Company's web sites and the related applications and services offered by FFE (collectively, the "Services").

Our principle guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to third parties. The prime purpose of collecting your data is to assist you in using our financial wellness platform.

This Statement explains the personal information we collect from you, either directly or indirectly, and how we use it. Personal information is any information that is related to an identifiable individual. It typically includes such information as your name, e-mail address, or mailing address. This Statement also covers the choices you can make about the data we collect, and how you can control these decisions. Please read this Statement carefully to understand how FFE may collect, use, and share your personal information. The terms 'we' and 'us' are each intended as reference to FFE.

THE TYPES OF PERSONAL INFORMATION WE COLLECT
We get information about you in a range of ways.

Information You Provide Us. We collect information you voluntarily provide to us, such as your name and email address; for instance, when you want to update your profile or when you contact our customer care department for assistance.

Information Provided by Other Sources. We may receive information about you from other sources, including third parties, such as FFE partners and partners with whom we offer co-branded services or engage in joint marketing activities. We may also receive information about you from FFE partner websites, for instance, when you interact with us on those sites. We protect data obtained from third parties according to the practices described in this Statement and we also apply any additional restrictions imposed by the source of data.

Information We Collect Automatically. We automatically collect information about you, such as data about your use of Our services. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.

Cookies. We may log information using "cookies." Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience using Our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

Information on Children. FFE does not target and is not intended to attract children under sixteen. Although visitors of all ages may navigate through our websites, we do not knowingly collect or request personal information from those under the age of sixteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under sixteen has improperly accessed or used our Services by using false information, we will delete the child's personal information from our records.

CUSTOMER INTERACTIONS WITH FFE
To make the information in this Policy easy to understand, we have highlighted different occasions when FFE could potentially collect personal information from Customers. The Customer interactions with FFE are broken down into the following segments:

Learning about FFE.
As you gather more information about FFE, you may virtually or physically visit or interact with a site that we own or operate. Examples include browsing our website, calling our sales representatives, or attending FFE-sponsored events. To learn more about FFE Services, you may voluntarily provide personal information, such as your name and email address during these interactions. We may also collect information about you online when you visit our websites.

We collect: name, email address, phone number, company, and IP address.

Why: We use this information to share news about events, and Services offered by FFE. Additionally, the IP address helps us to understand geographic information about our websites’ visitors better so that we can improve our websites for everyone. It is our legitimate interest to process your personal data for these purposes.

Updating your profile
When you update your profile, we allow you to enter or modify certain information. You may voluntarily provide personal information such as your first name, last name, and email.

We collect: first name, last name, email address, and image.

Why: We use this information to notify you of activities and events within Our Services depending on your notification preferences, identify your associated content, such as files and videos, identify you to other authorized coaches and users through Our system, properly display content in Our Services, and authenticate access to content based on associated roles and privileges. Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.

Submitting communication
The FFE Service is a financial wellness platform, with core functions that include submission of communications by coaches and advisees, acquiring incentives to engage with services, viewing financial wellness videos, posting and reading others financial goals and goal ideas, answering questions to build and review private financial wellness reports, and answering questions to build and review aggregated company wellness reports. We use the communication and viewing to facilitate enhanced financial wellness.

We collect: Video data, question response data, incentive accumulation data, and one-on-one communication data.

Why: We use this information to facilitate scientifically sound and clinically tested support services to improve employees’ financial wellness. Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.

Getting Help from FFE
From time to time, you may decide to contact our customer care department for assistance with the FFE Services, such as if you are having issues with the operation of your video playback or your submission of question responses. To be able to offer you the best service possible, we may collect certain data from you.

We collect: This may include contact information, such as your name, email address, phone number, and the content of your chats and other communications with FFE customer care.

Why: We collect this information to give you the best and most efficient customer support possible. For instance, for Customer inquiries and technical questions, we use contact information to respond to the Customer in their preferred channel (e.g., phone or email). Processing your personal data for this purpose is necessary for the performance of the agreement we have with you.

HOW WE USE PERSONAL INFORMATION

FFE uses the data we collect to provide you with the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about, new Services available, security, and other types of updates.

FFE uses the data for the following purposes:

Providing our Product Experience. We use data to provide, operate, support and improve the Services we offer to ensure our Customers can learn, grow, and collaborate as efficiently as possible. This processing is necessary for the performance of our agreement we have with you.

Customer Support. We use data to respond to Customer inquiries, diagnose problems using the Services, address technical issues, and provide other customer care and support services. This processing is necessary for the performance of our agreement we have with you, as well as to serve our legitimate interest.

Service Improvement. We continually use data for research purposes and to develop and improve Our Services, including maintaining and improving the performance of Our Services, developing and adding new features or capabilities, such as using verification to improve security, and using usage data to determine what new features to prioritize. This processing is necessary to serve our legitimate interest.

Security, Safety, and Dispute Resolution. We use data to protect the security and safety of Our Services and our Customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.

Business Operations. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.

Communication, Marketing, and Advertising. We use the data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means of electronic communication to inform you about new FFE Services, to update you on a support issue or to invite you to take part in a survey. This processing is necessary to serve our legitimate interest. We also may use cookies and similar technologies to provide the most relevant FFE advertising to you. For information about managing email subscriptions and promotional communications, please see below.

SHARING OF PERSONAL INFORMATION

FFE does not and will not sell personal information about our customers.

We may share personal information as follows:
•  We may share personal information with your consent. For example, you may let us share personal information with others for research purposes. Those uses will be subject to their privacy policies.
•  We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
•  We may share personal information for legal, protection, and safety purposes.
    •  We may share information to comply with laws.
    •  We may share information to respond to lawful requests and legal processes.
    •  We may share information to protect the rights and property of Financially Fit Employees, Inc., our agents, our independent contractors, Customers, and others. This includes enforcing our agreements, policies, and terms of use.
    •  We may share information in an emergency. This includes protecting the safety of our employees and agents, our independent contractors, our Customers, or any person.
•  We may share information with those who need it to do work for us.

From time to time, we may also share de-identified, aggregated, and/or anonymized data with others.

THE LEGAL BASES FOR USING PERSONAL INFORMATION

There are different legal bases that we rely on to use your personal information, namely:

Performance of a contract. The use of your personal information may be necessary to perform the agreement you have with us, such as, to process your submission of a questionnaire, to search for coaches, to post responses to a coach, to help with technical issues, and to respond to your requests.

Legitimate interests. We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyze and improve FFE Services, to send you notifications about FFE Services, or to use your personal information for administrative, fraud detection or legal purposes.

Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you on our website, you may exercise your right to object by sending an email to legal@financiallyfitemployees.com.

SECURITY, STORAGE AND RETENTION OF PERSONAL INFORMATION WE COLLECT

Security

FFE is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.

We use a variety of appropriate technical and organizational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. We ensure that our data center has adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transmission over the Internet. You can only access your information and our service through the use of an individual user login and password. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Additionally, always log out and close your browser when you finish using the Services. Please note, we will never ask you to disclose your password.

If you have any questions about the security of your personal information, you can contact us at legal@financiallyfitemployees.com.

Storage

Personal data collected by FFE will be stored and processed in the United States (for instance in our data centers). FFE does not transfer personal information internationally.

Retention

FFE will retain your personal information for as long as we deem it necessary to enable you to use the website and FFE Services, to provide services to you, to comply with applicable laws (including those regarding document retention), and resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to legal@financiallyfitemployees.com.

OUR USE OF COOKIES AND OTHER SIMILAR TECHNOLOGIES

We may use cookies and similar technologies from time to time to help us personalize our websites for you, remember your preferences, understand how users are using our websites or app, and help customize our marketing offerings.

Cookies
A 'cookie' is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. FFE uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website.
•  Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, services like enrollment services cannot be provided.
•  Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate.
•  Functional cookies. These cookies allow our websites to remember choices you make and personalize your experience. We may store your geographic location in a cookie, for instance, to ensure that we show you the websites relevant to your area.
•  Third Party cookies. Third-party cookies are those placed by websites and/or parties other than FFE. These cookies may be used on our websites to improve our products or services or to help us provide more relevant advertising. These cookies are subject to the respective privacy policies for these external services.
•  Analytics cookies. We use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our websites, what pages they find most useful and how they arrived at financiallyfitemployees.com. To learn more about Google Analytics and your data, visit this Google webpage.

How to control cookie settings
Most web browsers allow you to control cookies through their settings preferences. However if you limit the ability of websites to set cookies, you may impact your overall user experience. Some browsers offer a “Do Not Track” (“DNT”) signal whereby you may indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognizes DNT signals, we will only process your personal data in accordance with this Privacy Statement. Below you can learn about how to control cookie settings on popular web browsers: •  Google Chrome
•  Internet explorer
•  Safari
•  Firefox

YOUR RIGHTS AND CHOICES

Your Rights

We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:
•  you can ask us for a copy of the personal information we hold about you;
•  you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
•  in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
•  in certain situations, you can also ask us to send the personal information you have given us to a third party.

Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.

We rely on you to ensure that your personal information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting legal@financiallyfitemployees.com.

We will respond to your request as soon as possible but certainly within 30 days.

We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.

Your Choices

Service data submissions. If you wish to access, edit or remove a your content, change your password, or request deletion of your personal data, you can do it by sending an email to legal@financiallyfitemployees.com. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days. Note that some data requests will require authorization from the customer company that provisioned your account, as it is typically the case they have an ownership interest in the data.

Your Communication, Marketing and Advertising Preferences. You can opt out of receiving direct marketing communications from FFE by following the instructions included in every email sent to you via the “Unsubscribe” link. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.

Please note we will continue to communicate with you regarding changes to terms of use, policy updates, FFE Service updates, routine customer service messages such as information about service interruptions, data breaches, or other significant information about your use of the Services.

CONTACT INFORMATION.
If you have any questions about the use of your personal information, please send an email to legal@financiallyfitemployees.com.

When accessing the FEE Services via www.financiallyfitemployees.com, FEE, is a data controller for personal data we collect subject to this Privacy Statement.

In many cases, the FEE customer provisioning your account, such as your employer, may be a data controller subjecting you to different privacy policies. You can contact your provisioning FEE customer or FEE directly for more information.

Our address is PO box: 75 McCabe Dr. #18081, Reno, NV 89511

CHANGES TO THIS PRIVACY STATEMENT. We will update this Statement when necessary to reflect legal changes, Customer feedback, and changes in our Services. When we post changes to this Statement, we will revise the last updated date at the top of the Statement and may describe the changes in a change history. If there are material changes to the Statement or in how FFE will use your personal information, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Statement to learn how FFE is protecting your information.