Introduction

First In Corp. (“First In”, “we”, “our”, and “us”) recognizes the importance of protecting the privacy and the rights of individuals in relation to their personal information.

First In provides skip the line and user verification services to customers at participating venues.

This policy describes:

• How we collect, use, disclose and protect the personal information of individuals (the “user”, “you”, or “your”) who download, install, access, or use our First In mobile app (the “App”), access our website (available at ●, the “Website”), and/or use our services and products (collectively with the App and Website, the “Services”).
• The types of information we may collect from you or that you may provide when you use our Services; and
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law.

This policy applies only to information we collect, use or disclose when you communicate with us via email, text or when you use our Services. This policy does not apply to any personal information that is collected directly by participating venues; please review the privacy policies of the applicable participating venues to understand how they may process personal information they collect from you.

What is personal information?

Personal information means any information about an identifiable individual, including information that can be used to identify you. This includes your name, email address, telephone number and payment information.

Information we collect about you

If you download, install, access, or use our App, Website or Services, we may collect the following types of information from and about you, including:

• Personal information: We generally collect your personal information to provide you our services, to communication with you, and to manage our business. For more information on why we collect your personal information go to section 5 of this privacy notice.
  • name;
  • email address;
  • telephone number;
  • username, password, and any personal information that we obtain when you use our App or Website, including details of your preferences in receiving marketing information and your communication preferences;
  • the last four digits of your credit card via our mobile application and online booking provider, and/or other payment method details via Stripe, our third-party payment processor;
  • location information including real-time information about the location of your device for heat map functionality and to provide you with personalized location-based services and content; and
  • information about which events and venues you will be attending or have attended based on your purchases and use of our Services.
• Non-personal information – information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website or App feature.
• Technical information - your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website or App, and usage details.
• Non-personal details about your Website and App interactions - including details and information about how you use our App, Website, and Services, including events and venues you viewed or searched for, length of visits to certain pages, page interaction information (such as scrolling and clicks), methods used to browse away from the page.

How do we collect your personal information?

We use different methods to collect your information, including through:

• Information you provide to us – This information may include:
  • when you make an inquiry about our Services;
  • when you access or use our Services;
  • during communications between you and our representatives;
  • when you interact with us via social media;
  • when you ask to be placed on one of our mailing lists; or
  • when you become a customer or a debtor of ours.
• Information collected through automated technologies or interactions - as you navigate through and use our Website or App, we may automatically collect through cookies, web beacons, and other tracking technologies the following types of data: usage details, traffic data, logs, location data and information about your computer and internet connection, including your IP address, operating system, and browser type. Please see “Automatic Data Collection Technologies” below for more information.
• Third parties, for example, from our business partners or participating venues who have your consent to share your personal information with us.

How we use your information

We use information that we collect about you or that you provide to us, including any personal information used in the following ways:

• to provide and personalize our Services to you;
• to send communications requested by you;
• to share your information with partners, organizers, creators, owners or hosts of participating venues and events for the purpose of providing the Services;
• to send service confirmations and notifications;
• to analyze venue popularity through the use of location information and heat maps;
• to recommend relevant events, promotions and special offers;
• to answer inquiries, provide information or advice about existing and new services, and effectively respond to your customer service requests;
• to assess and improve our Website, App, products or services, marketing, or customer relationships and experiences;
• to process payment transactions via Stripe, our third-party payment processor;
• to conduct business processing functions;
• for administrative, marketing and advertising (including direct marketing, such as SMS text messages, emails, and newsletters), planning, product or service development, quality control, and research purposes;
• to promote our Services on social media;
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you;
• to carry out our obligations and enforce our rights arising from any agreements that we may have with you, including for billing and collection or to comply with our legal obligations; and
• for any other purpose with your consent or in compliance with applicable laws.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

How do we share your information?

We may disclose your personal information to:

• our partner venues and events for the purposes of providing our Services;
• contractors and service providers for the purposes of operation of our App and Website, including fulfilling requests by you, and to otherwise provide the Services to you (including, without limitation, web hosting providers, IT systems administrators, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors, event planners, and consultants);
• a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred; and/or
• any organization for any authorized purpose with your express consent.

We may also disclose your personal information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
• to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and/or
• if we believe disclosure is necessary or appropriate to protect our rights, property, or the safety of our users or others.

We may provide access to your personal information with the following categories of individuals within our organization: ■,■, and ■.

Getting and withdrawing your consent

We only collect information by lawful means. As part of using our Services or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes identified or as otherwise permitted or required by law. In compliance with our privacy obligations, we may obtain your permission based on implied consent (including through this privacy policy) or through other means (such as express consent). However, in some situations, the law allows us to collect, use or disclose personal information without your consent.

You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.

You may withdraw your consent to the collection, use or disclosure of your or your child’s personal information at any time by contacting the Privacy Officer (see ‘ Contacting information ’ below) and, subject to any legal constraints, we will comply with your request.

Direct marketing communications

We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax, and email, in accordance with applicable marketing laws, such as Canada’s Anti-Spam Legislation (CASL). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see ‘ Contacting information ’ below) or by using the unsubscribe mechanisms provided in our marketing communications.

We do not provide your personal information to other organizations for the purposes of direct marketing.

Automatic data collection technologies

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising, please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:

• estimate our audience size and usage patterns.
• store information about your preferences, allowing us to customize our website according to your individual interests.
• speed up your searches.
• recognize you when you return to our App or Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or your smartphone. You may refuse to accept browser cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see ‘ Choices about how we use and disclose your information ’.
• Web Beacons. Pages of our App and Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit First In, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see ‘ Choices about how we use and disclose your information ’.

Transferring your information

We may transfer personal information that we collect or that you provide as described in this policy to contractors and service providers we use to support our business (such as analytics and search engine providers that assist us with App and Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. You are welcome to contact us (see ‘ Contacting information ’ below) to obtain further information about our policies regarding service providers outside of Canada.

For Québec Residents, please note that before a transfer outside the province, a privacy impact assessment shall be conducted. A transfer will only be made if the assessment demonstrates that the personal information will be adequately protected in compliance with generally accepted data protection principles. The affiliates or other third-parties that will receive such information will be bound by a written agreement setting strict confidentiality requirements.

Security

The security of your personal information is very important to us. We may hold your information in either electronic or hard copy form. We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorized access, modification, or disclosure. [We store all information you provide to us behind firewalls on our secure servers. Any payment transactions [and [OTHER INFORMATION]] will be encrypted [using SSL technology].]

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App or Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk. We endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

Data retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Third-party links

Our App or Website may include links to third-party websites, plug-ins, services, social networks, or applications (collectively, “Third-Party Services”). Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a Third-Party Service, please note that these third parties have their own privacy policies, and we do not accept any responsibility or liability for these policies. We do not control these Third-Party Services, and we encourage you to read the privacy policy of every Third-Party Service prior to use.

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser or App settings to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our App or Website may not be accessible or may not function properly. For more information about tracking technologies, see ‘ Automatic data collection technologies ’ below.
• Location Information. You can choose whether to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location some parts of the App may be inaccessible or not function properly.
• Promotional Offers from the Company. If you have opted in to receive certain emails or texts from us but no longer wish for us to use your contact information to promote our own or third parties' products or services, you can opt-out by [OPT-OUT METHOD]. If we have sent you a promotional email or text, you may unsubscribe by clicking the unsubscribe link we have included in the email, or by [OPT-OUT METHOD FOR TEXTS]. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes [or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE]] .
• Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your data. You can also opt-out by [●] or by contacting us (see ‘ Contacting information ’ below).
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by [INSERT OPT-OUT METHOD].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Data Subject Rights

You may request access to any personal information we hold about you at any time by contacting us (see ‘ Contacting information ’ below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by emailing it to you).

If you believe that personal information we hold about you is incorrect, incomplete, or inaccurate, then you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it, together with your requested amendment. If we correct your personal information, we will, so far as is reasonably practicable, inform every other person to whom we have disclosed that information of the correction.

For Quebec residents, you are entitled to the following additional data subject rights in respect of your personal information, including:

• Your right to deletion – You have the right to ask us to delete your personal information in certain circumstances.
• Your right to be informed of and submit observations regarding automated decision making – You have the right to ask us for additional information on processing on automated decision making and the right to submit observations to a designated individual within the organization.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Right to be informed. You have the right to be informed on what personal information is collected, used, disclosed, retained, and deleted. Even if this is what this notice is meant to achieve, you may request additional information to clarify the extent of their consent.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or to give effect to other data subject rights you may be entitled. In certain situations, we may not be able to fulfil your request. If that is the case, we’ll explain the reasons for our decision when responding to your request. For example, in some cases the information you request access to may contain details about other individuals, or there may be legal, security, or commercial proprietary reasons why information is withheld.

Use of Services by minors

The Services that First In offers are not directed to individuals under the age of thirteen (13), or Québec residents who are under the age of fourteen (14), and we do not knowingly collect personal information from individuals under 13 or Québec residents under 14. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the Services without their permission. If you have reason to believe that a child under the age of 13 or a Québec resident under 14 has provided personal information to us through the Services, please contact us using the Contacting information below and we will endeavor to delete that information from our systems and databases.

Contacting information

We welcome your questions, comments, complaints and requests regarding this privacy policy and our privacy practices. Please contact our Privacy Officer at: +1 437-269-2245

Toronto, Ontario, Canada or

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above. Please note that we may need to confirm your identity or request additional details in order to process your request.

Changes to our privacy policy

We may change this privacy policy from time to time Any updated versions of this privacy policy will be posted on First In’s App or Website and will be effective from the date of posting. You are responsible for checking if any amendments have been made to this privacy policy. Your continued use of our App, Website, or our Services following a change to this privacy policy will constitute your consent to collection, use, and disclosure of your personal information as described in the amended privacy policy.