Definitions

Fable Tech Labs Inc. (“Fable”) is committed to protecting your privacy and ensuring that you have a positive experience on our website and in using our products and services (collectively, “Products”). Fable’s “Customers” are companies that want to use our Products to (i) connect with Testers for the purpose of completing surveys, user testing, accessibility testing, or other similar research and user testing services (“Test Requests”) in order to improve the accessibility of the Customer’s products and services or (ii) to access training modules .

This Policy covers the Fable website, web applications, mobile applications, proprietary software and desktop clients and is applicable worldwide.  For the purposes of this Policy, “you”, “your”, “user” refers to the individual accessing the Products or our website, including Testers, Respondents, Customer employees, and Website Visitors. This Privacy Policy (“Policy”) outlines our Personal Data handling practices, what Personal Data we collect from you, and how we use your Personal Data.

We collect varying levels of Personal Data depending on your relationship with us. The following are how we define the groups of individuals that we collect Personal Data from:

Customer Personal Data” means the Personal Data we collect from our customers or prospective customers’ employees that access and use the Products.

Personal Data” means any information that relates to an identified or identifiable individual.

Respondents” means the individuals with disabilities who Fable engages with to complete surveys.

Testers” means the individuals who Fable engages to provide accessibility testing services for Fable.

Website Visitors” means any individual browsing or visiting our Products.

Your Rights and Choices

Choice 

You can choose whether to provide Personal Data to Fable.

Please note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided.

You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this Policy. 

Data Subject Rights and Choices

You may review and edit your account information in the platform at any time by logging into and updating your account. Where you have provided consent for us to use your information, you may request to withdraw that consent for future uses of your information.

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this Policy.

Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.

Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.

Right to File Complaint: You have the right to lodge a complaint about Fable’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. 

Purposes for Collecting and Using Data About You

Purposes for collecting and using your Personal Data

We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section below.

Some jurisdictions require us to disclose the legal grounds we—as a controller—rely on to process your information. The legal grounds we rely on, as described in this Privacy Policy, include:

(i) your consent to processing your information for one or more purposes;

(ii) where the processing is necessary to enter into or perform a contract you have entered into with us;

(iii) processing required to meet our legal obligations; or

(vi) where processing is necessary for the purposes of our legitimate business interests, unless such interests are overridden by your interests or fundamental rights and freedoms; or

(v) the legitimate interest of others (e.g. our users) such as:

  • Personalizing, improving or operating our Products and business
  • Better understanding your needs and interests
  • Fulfilling requests you make related to the Products
  • Providing you with information and offers from us or third parties
  • Complying with our legal obligations, resolving disputes with users, enforcing our agreements
  • Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity

We collect, process and disclose your Personal Data in connection with the below activities related to our Product:

  • Account registration, personal profile creation and administering your account
  • Use and support of Products, including features, service requests, and generating reports from product usage
  • Performing any contract or other transaction we enter into with you
  • Engagement activities such as attending seminars/webinars, participating in surveys, discussion groups, and forums
  • Marketing and communication efforts, including newsletter subscriptions, advertising customization, promotional events and updates on product announcements and offers
  • Conducting Test Requests
  • Conducting surveys related to accessibility and preferences of individuals with disabilities
  • Other online surveys
  • Promotional activities such as contests and sweepstakes
  • Enhancement of Products, and personalization of Products and marketing communications and content based on user preferences and interactions
  • Financial transactions such as billing and collection payment for products and services
  • Customer service provisions such as niche testing, support, order processing, product delivery, and customer feedback
  • Recruitment support and referral contact management
  • Performing data analytics for internal business and Product improvements
  • Communicating with you about our Products, Services, Test Requests or any other customer service related matters
  • Participating in discussion groups or forums
  • Registering for newsletter subscriptions Customizing the advertising and content you see
  • Registering to attend events, webinars and similar activities
  • To identify our users and enhance our service security
  • To facilitate seamless access to and enhanced security of our Products
  • To protect against unauthorized access and authenticate accounts and activity, detect, investigate, and prevent malicious conduct or fraudulent activity, address security threats
  • To meet contract or legal obligations

What Data We Collect About You

Collection of your Personal Data

Our data collection practices encompass Personal Data from a variety of groups of individuals, including:

  • Testers: We collect your personal information as a Tester when you apply to be a Tester, throughout your use of our platform, providing testing services, and through your interactions with us and/or the Customer via our Products.
  • Respondents: We collect your personal information as a Respondents when you contact us about opportunities with Fable and when we engage with you for the purposes of completing surveys.
  • Customers: We collect personal information of our Customer’s employees when they interact with Fable personnel or the Products.
  • Website visitors: We collect Browsing Data from you when you are visiting our website.

We may collect the following categories of Personal Data about you when you use or otherwise interact with our Products or personnel. The scope of Personal Data we collect depends on the nature of your engagement and interactions with us:

  • Identity and Contact Data: This includes information on how we identify and contact you, including full name, address, employment, business information, title, email address, phone number, mailing address.
  • Test Request Data: Any personal information you provide during a request. This may include data such as your assistive technology, modifications you use in completing Test Requests, voice, voice print, image and anything visible during a video-based request. Any Personal Information you disclose during these requests is collected by us and may be used and disclosed in accordance with this Privacy Policy. You provide your express consent for us to disclose this information to our Customers when we deliver the Test Request results to the Customer.
  • Device Data: We collect information with respect to your assistive technology.
  • Survey Response Data: Survey Response Data are additional Personal Data that we may collect from you through the form of surveys. Your choice to provide this information may impact what request opportunities are provided to you, but will not limit your ability to self-select for opportunities that may be posted in the Fable platform.
    We may contact you for optional participation in surveys where we may collect a variety of personal information that could include: financial information, product usage information, product preference information, financial/retail preferences and behaviours, general consumer preferences and behaviours, socio-economic and demographic information, languages spoken, travel preferences and similar types of personal information, feedback on experiences and access needs/barriers. The types of Personal Information collected in a survey will be communicated to you prior to you choosing to complete the survey.
  • Browsing Data: IP addresses, browsing behaviours (such as data on the pages you visit, the time spent on each page, the links you click, and other actions taken while browsing our website), and usage data such as information on how and when you access our website, including timestamps and interaction patterns.
  • Authentication Data: SSO profile information (such as your name, email address, and organization, which is necessary to authenticate and manage your access to our services through SAML SSO)
  • Self-Disclosed Data: This includes any personal information that is disclosed by you voluntarily in your interactions with us, that is not otherwise captured in other categories.

Website Visitor Data we may collect:

  • Browsing Data

Customer Personal Data we may collect:

  • Identity and Contact data,
  • Product Usage Data,
  • Authentication Data,
  • Self-Disclosed Data

Tester and Respondent Personal Data we may collect:

  • Identity and contact Data,
  • Device Data
  • Browsing Data
  • Product Usage Data
  • Test Request Data (as applicable to Testers)
  • Survey Response Data, and
  • Self-Disclosed Data

Passive Collection

Fable and our third-party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Products.

In addition, when you use some of our Products, network information is transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.

Geolocation

We collect information about where you are located when you are using our Products. We use this information for purposes such as optimizing your connection to our data center and suggesting customizations to your experience with our Products (e.g. your language preference). We share this information with parties such as our data center provider and our advertising partners. If you do not wish to allow us to share your information in this manner, please opt-out by contacting us using the information in the “Contact Us” section of this Policy.

Cookies and Tracking Technologies

Fable and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. Users can control the use of cookies at the individual browser level.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Products do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Products and after you leave our properties.

Who May See Your Data

Sharing of Your Personal Data

We share Personal Data within Fable, and with vendors that support our business operations, Products and service delivery. 

We may share Personal Data with our Customers as needed to provide the Services. For example, if you choose to complete a video-based Test Request, a copy of the video will be made available to the Customer. As a Tester you expressly consent to the disclosure of Personal Data to the Fable Customer as a result of your choice to complete a Test Request. Fable undertakes to limit the amount of Personal Data shared with Customers.

Sometimes your Personal Data will be shared with vendors (or sub-processors) for processing to manage resources and access best-in-class products to fulfill their contractual obligations with us. Examples of these may include but are not limited to cloud infrastructure & data storage, single sign on authentication, analytics and performance tracking, and video communication capabilities. Fable puts in place data protection agreements with these vendors to ensure that they meet the same privacy and security compliance requirements that we must meet when collecting and using your Personal Data. In certain countries, sharing Personal Data across international borders is governed under privacy law. For more information on how we comply with these obligations, please see “Global Privacy Regulations” section of this Policy.

We may share Personal Data in the event of a business transfer, such as selling some or all assets of our business as part of a purchase, transfer, merger reorganization, dissolution or similar event. In these types of transactions, Tester and Customer Personal Data is typically one of the transferred business assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this Policy.

Third-Party Video Solutions Provider 

All video conferencing and related communication with Fable relating to the use of Products and/or when Fable is providing Services will be through the third-party video solutions provider Zoom Video Communications, Inc. (“Zoom”). Such video conferencing solutions will be subject to the terms and conditions of use as stipulated by Zoom. We encourage you to review Zoom’s privacy statement at https://explore.zoom.us/en/privacy/.  

Zoom may collect on our behalf, recordings of your face and likeness, along with your voice print. These recordings are necessary for the purposes of providing services to our Customers with respect to the Engage product testing requests that Fable receives. You will be given the opportunity to consent to the recording within the Zoom platform. If you do not wish to consent, please do not participate in recorded testing sessions. Your choice to opt-out of one session does not limit your ability to participate in a future testing session where recording may occur. In other words, you can make this choice on a case-by-case basis in real time, when presented with testing opportunities through Fable’s Products.

Disclosure of Your Personal Data 

We may disclose your Personal Data as follows:

As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims. 

We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Fable’s terms of service, or as otherwise required by law. 

We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so. We will provide you with notice and will receive your consent prior to any use of Personal Data in this manner. 

Newsgroups/forums 

If you participate in a Fable discussion forum or chat room, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside Fable, who have access to that discussion forum or chat room. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Fable. 

Linked websites and third-party services 

While navigating Fable’s website or Products, you may be directed to content or functionality that is hosted by a third-party. When information is collected on behalf of Fable exclusively, Fable’s Privacy Policy will be referenced and will govern how your information is used. For other, non-Fable sites or services, the site/service owner’s privacy notice will be referenced. You should review such third party’s privacy and security policies prior to use.

 Interest-Based Advertisements 

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third-party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites to provide you advertising based upon your browsing activities and interests. With respect to our interest-based ads, we adhere to self-regulatory principles for online behavioral advertising.  You can opt out of receiving interest-based ads from members of the Digital Advertising Alliance at http://www.aboutads.info/choices/ for web properties or at https://youradchoices.com/appchoices for mobile apps. And in Canada at: https://youradchoices.ca/en/tools.

How Long We Keep Your Data

Data Retention 

Once collected, your personal data is retained for as long as needed to perform the Services or engage you as a Tester or Respondent as permitted by applicable law, and as necessary to comply with our legal obligations, resolve disputes or enforce our agreements. In some cases, a retention period will apply once the initial purpose has ceased. For example, finance related records (such as payments) are kept for 7 years.

We may also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this case, we may use this personal data indefinitely without further notice to you however you will not be identifiable in this instance.

If you wish for us to no longer retain your Personal Data, you may request we delete it before it reaches our usual retention & deletion timelines. To fulfil this type of request, please contact us via the “Contact Us” section of this Policy.

How We Aim to Keep Your Data Safe

Security of your Personal Data

Fable is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.

We validate the effectiveness of our safeguards by obtaining third-party assessments and certifications of our organization’s practices and Products’ adherence to best practice standards. It is important that you understand that these measures reduce risks but may not eliminate them completely.

We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us by using the information in the “Contact Us” section of this Policy.

Global Privacy Regulations

Global Privacy Regulations

If you reside in the European Union (“EU”), United Kingdom (“UK”), Liechtenstein, Norway or Iceland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, Liechtenstein, Norway or Iceland, and in the case of the UK, the UK GDPR. 

Fable processes Personal Data both as a Controller and Processor as defined in the GDPR. We are the Controller of Tester and Respondent Personal Data, and with respect to Customer Personal Data Fable is the Processor.

If you have any questions about whether any of foregoing applies to you, please contact us using the information set forth in the “Contact Us” section of this policy. 

Transfer and Storage of Personal Data 

Our Products are hosted and operated in the United States (“U.S.”) through Fable and its service providers. We may transfer your Personal Data to the U.S., to any Fable affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers. 

With respect to Testers and Respondents, Fable may have Customers in geographic locations outside of Canada and the U.S. As such, we may transfer your data to our Customers in these locations, solely in accordance with this Privacy Policy and applicable privacy laws.

Standard Contractual Clauses 

In certain cases, Fable will transfer Personal Data from the EU in accordance with the European Commission-approved Standard Contractual Clauses or the UK’s Information Commissioner’s Office Standard Contractual Clauses or as governed by an adequacy decision or similar valid mechanism for international data transfers.

Updates

Privacy Policy Updates

This Policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website. If there is a change to this Policy that impacts any specific new collection, uses or technologies that may impact your active consent to interact with Fable and our Products, we seek to communicate these changes to you.

How to Contact Us

Contact Us

To address your individual rights or if you have any privacy-related questions or comments related to this Privacy Policy or if you would like to exercise any of your privacy rights, please send an email to privacy@makeitfable.com or contact the applicable appointed representative listed below.

UK General Data Protection Regulation (GDPR) – UK Representative

Pursuant to Article 27 of the UK GDPR, Fable has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Fable has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

Complaints

If your concern or issue related to personal information management cannot be resolved with Fable, you may wish to contact the appropriate regulatory authority in the region that applies to you.