Waterstreet FMS Privacy Statement

Last Updated: July 1, 2020 (Waterstreet Privacy Statement)

At Waterstreet, we pride ourselves on our commitment to protecting your privacy. Our Data Stewardship Principles reflect our company’s values and how we strive to maintain your privacy. This Privacy Statement describes in greater detail the privacy practices of Waterstreet Inc. and its affiliates and subsidiaries, meaning companies related by common ownership or control (“us,” “we,” “our”) responsible for collecting and maintaining certain information collected about you.

If you have questions or complaints regarding our Privacy Statement or practices, please contact us as detailed under the How to Contact Us heading below.

1. WHEN THIS PRIVACY STATEMENT APPLIES. If a Service you're using links to this Privacy Statement, this Statement applies to you.

This Privacy Statement (“Statement”) applies to our sites, products, and services (collectively, "Services") that link to this Statement. Waterstreet Inc. is the responsible entity for all Personal Information subject to this Statement for our Services targeted to US customers. We also provide Services in other countries and regions.

2. WHAT WE DO WITH YOUR INFORMATION. We do not sell or share your Personal Information with third parties for their own commercial uses without your consent.

How We Use Your Information. Unless prohibited by law, regulation, or a contractual obligation, we may use your information, including your Personal Information, for the following purposes:

  1. Account Registration. We may use your name, address, phone number, and email address to register your Waterstreet Account for certain Services we provide and to communicate important information to you.

  2. Communicate with You and Tell You About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that we think may be of use to you. Please see below under "What You Can Do to Manage Your Privacy" for the choices you have regarding these communications.

  3. To Improve Services and Develop New Services. We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of Waterstreet's Services.

  4. To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information.

  5. Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience. We also offer various Internet chat services, for example, to speak with a Waterstreet support representative or tax advisor. Internet Chat transmissions are encrypted but you should not supply more Personal Information, including tax data, than is required to address your specific issue. A transcript of the session is retained to resolve questions or issues related to our Services.

  6. Feedback. We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them. Answering any survey is optional.

  7. Research, Including Publishing or Sharing Combined Information from Many Users, But Only in a Way that Would Not Allow You or Any Other Person to be Identified. Only in a way that would not allow you or any other person to be identified, we may prepare and share information about our customers with third parties, such as advertisers or partners, for research, academic, marketing and/or promotional purposes. For example, we may share demographic data that describes the percentage of our customers who use mobile services or who use a particular operating system. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.



Waterstreet Single Sign-On (Waterstreet Account). Waterstreet Single Sign-on is a Service that allows you to sign-in to a variety of Waterstreet Services with a single Waterstreet Account. We will collect certain information for security purposes in order to verify your authorized access to an account or to reset your password if you cannot access your Waterstreet account. Some Services may require added security and you may be asked to provide additional information. The email address and password that you use to sign up for a Waterstreet account are your "credentials" that you will use to authenticate with our network. We assign a unique ID number to your credentials to track you and your associated information. Waterstreet Services do not allow sharing of accounts between users or individuals.

How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others.

Third Party Service Providers. We may share your information, including Personal Information and Usage Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they're providing to us or on our behalf.

Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.



Protection of Waterstreet and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products' Terms of Service and other agreements; or protect the rights, property, or safety of Waterstreet, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Statement.

Information Sharing Between Waterstreet Entities. We share your information, including your Personal Information, with and among our affiliates and subsidiaries, except where prohibited by law, regulation, or a contractual obligation. The protections provided in this Privacy Statement apply across all Waterstreet entities. Affiliates and subsidiaries means companies related by common ownership or control. The reasons why we share your information include for our everyday business purposes, such as to: process your transactions, maintain your accounts, operate our business, facilitate Waterstreet Single Sign On to your Waterstreet Account, etc. We will also share your information in order for us to be able to offer our products and services to you. We may also share information about your creditworthiness, your transactions and experience so that we can operate our business effectively, detect and prevent fraud, and improve our Services.

Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.

We work with other companies or developers to offer you products and services and you may choose to sync, link or connect other third party services with your Waterstreet Service. Sometimes Waterstreet may let you know about the service or product, or another company may let you know about a Waterstreet service or product. It will be clear who is referring the service or product, and who is providing the service or product. If you choose to accept these services, providing your consent to either the third party or to us, we may exchange your information, including your Personal Information, as well as information about how you interact with each company's service or product. This exchange of information is necessary to maintain business operations and to provide the ongoing service you've requested. By requesting or accepting these products or services, you are permitting us to provide your information, including your Personal Information, to the other party.

WHAT YOU CAN DO TO MANAGE YOUR PRIVACY. You can view and edit information that identifies you online through your Waterstreet Service. How you can access and control information that identifies you will depend on which Services you use.

Subject to your control, our mobile applications may send push notifications to your mobile device. If you are receiving push notifications and no longer wish to receive these types of communications, you may turn them off at the device level.

Updating Your Personal Information. In connection with your right to manage your Personal Information you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the "How to Contact Us" section of this statement.

Cookies and Similar Tracking Technologies. The following is a high level summary of our practices and your controls for cookies and other tracking technologies. For more information, please see our Cookies Policy.

In accordance with applicable law, Waterstreet and our service providers may use commonly-used tools to recognize your visit and track your interactions with our Services such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, "Cookies"). Sometimes this tracking is necessary in order for us to provide you the Service you requested. Other times, we combine Usage Data collected from Cookies with that of other customers to improve your and other customers' experience. You have control over some of the Usage Data we collect from Cookies and how we use it. Information on changing your browser settings to opt out of Cookies can be found in your browser settings.

In accordance with the Digital Advertising Alliance Principles, Waterstreet also uses advertising networks and other third parties to display advertising on our website or to manage our advertising on other sites. Our third party partners may place Cookies on our Services and unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests, and to determine the effectiveness of such advertisements. If you wish to opt out of interest-based advertising, click here, or if located in the European Union, click here.

Please note that even if you opt-out of such Cookies or otherwise opt-out of interest based advertising, you may still receive advertisements, they just won't be tailored to your interests. Also, if you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.

Social Media Features. Many of our Services may use social media features, such as Facebook sharing ("Social Media Features"). These features may collect your IP address and which page you are visiting within our Service, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing the relevant Social Media Features.

HOW TO CONTACT US. If you have questions or comments about this Privacy Statement, please contact us. We want your feedback and comments.

a) Via Email. If you have questions or complaints regarding our Privacy Statement or practices, please contact us by email at privacy@Waterstreet.com.

b) Via Direct Mail. Waterstreet Technology Group Inc. Suite 200 - 375 Water Street, Vancouver BC Canada V6B 0M9

CHANGES TO OUR PRIVACY STATEMENTS. From time to time we may change or update our Privacy Statements. We reserve the right to make changes or updates at any time. More information about how we will notify you is below.

If we make material changes to the way we process your Personal Information, we will provide you notice via our Service or by other communication channels, such as by email or community post. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you may close your account(s). All changes are effective immediately upon posting and your use of our Service after a notice of material change or posting of an updated Privacy Statement shall constitute your consent to all changes.

Waterstreet Services are intended for Clients of Waterstreet and directed to adults. Our Services are not directed to minors and we do not knowingly collect Personal Information from minors.

YOUR CALIFORNIA PRIVACY RIGHTS.

We do not share your Personal Information with third parties for their marketing purposes without your consent.



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