Effective Date of Current Policy: October 1, 2019
3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It
The types of Personal Information we may collect from you and our privacy practices depend on the nature of the relationship you have with FTLG and the requirements of applicable law. Some of the ways that FTLG may collect Personal Information include:
- You may provide Personal Information directly to FTLG by becoming a client who uses our Services or interacting with our Sites.
- As you navigate the Sites and use our Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to only collect information that is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
FTLG collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Sites, Services, or engage in certain activities, such as signing up for a newsletter, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Becoming a client of FTLG. When you become a client of FTLG, we collect basic contact information from you such as your name, email address, mailing address, and phone number.
- Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for FTLG’s newsletter, download or access FTLG information, papers, or tools, or otherwise communicate with us.
- Making Submissions. FTLG may offer publicly accessible web pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in or on FTLG’s web pages, blogs, private messages, and community forums, the information associated with your submissions will be collected, including any Personal Information.
- Automatic Data Collection. We may collect certain information automatically through our Sites and Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, hardware type, operating system, Internet service provider, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Sites and Services, and other actions taken through use of the Sites and Services such as preferences.
3.2 How FTLG Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Products, Services, or Information Requested. FTLG may use information about you to fulfill requests for Services, or information, including information about potential or future Services, including to:
- Generally, manage an Individual’s information, matter(s), and account;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functions, and features of FTLG’s Sites
- To interact with an individual regarding specific Services; and
- Allow you to register for events.
- Administrative Purposes. FTLG may use Personal Information about you for its administrative purposes, including to:
- Measure interest in FTLG’s Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Process payment Services;
- Prevent potentially prohibited or illegal activities; and
- Enforce any Agreement between us.
- Expanding the Use of FTLG’s Sites, Products and Services. FTLG may use Personal Information to provide you with materials about offers from FTLG for its own products and Services that may be of interest to you, including new content or Services. FTLG may provide you with these materials by phone, postal mail, or email, as permitted by applicable law. Such uses include:
- To tailor content;
- To notify you about offers from FTLG for its own products, and Services that may be of interest to you;
- To provide content, information, and Services to you;
- For other purposes disclosed at the time Individuals provide Personal Information; or
- Otherwise with your consent.
FTLG does not use your Personal Information for marketing to Third-Parties.
- Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information may receive periodic emails, newsletters, mailings, or phone calls from us with information on FTLG’s products and Services or upcoming special offers/events we believe may be of interest to you. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
- Other Uses. FTLG may use Personal Information for which we have a legitimate interest, such as direct marketing, research (including marketing research), network and information security, fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Sites or Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular article or advertisement.
- Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Sites and Services and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of these Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or cookies and web beacons to deliver content on our Sites that may be of interest to you. This content includes using technologies to understand the usefulness to you of the content that has been delivered to you.
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites and Social Media Platforms
Our Sites and Services may contain links to other websites and other websites may reference or link to our Sites. These other domains and websites are not controlled by us, and FTLG does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
FTLG’s Sites and Services may include publicly accessible blogs, community forums, or private messaging features. The Sites and Services may also contain links and interactive features with various social media platforms such as Facebook, LinkedIn, and Twitter, among others, (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Sites or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.
4. Onward Transfer—FTLG May Disclose Your Information
4.1 Information We Share
- Your Employer. When you signed up to use FTLG’s Services, you may have done so because your employer instructed you to do so. Please be aware that if your interactions with FTLG are on behalf of your employer, your employer will have access to the information that you share with FTLG. Please check separately with your employer about its privacy practices and information handling standards.
- We Use Vendors and Service Providers. We may share any information we receive, with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Sites.
- Business Partners. FTLG may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service you have requested. FTLG requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which FTLG provided them.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content, if we believe doing so, is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce FTLG policies or contracts; (v) to collect amounts owed to FTLG; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
4.2 International Data Transfers
You agree that all Personal Information submitted to, or collected by FTLG may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on the servers of our affiliates or the servers of our service providers in order to provision the Sites. Personal Information submitted in connection with other Services is securely stored using Microsoft’s cloud services and the servers are control and maintained by Microsoft.
4.3 Redress/Compliance and Accountability
5. Opt Out (RIGHT TO OBJECT TO PROCESSING)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to FTLG’s Processing of your Personal Information you may withdraw that consent at any time and opt out to further Processing by contacting firstname.lastname@example.org. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites, Services, and/or information from the advertisements on Third-Party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.
5.2 Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or Services you have requested or used.
5.3 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
You can choose not to be included in Google Analytics here.
To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
6. Rights of Access, Rectification, Erasure, and Restriction
Although FTLG makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which FTLG is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question, where the request is manifestly unfounded or excessive, or where it is commercially proprietary. If FTLG determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, FTLG will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Sites and Services, or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Sites and Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. Children’s Privacy
The Sites and Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and FTLG does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
10. Other Rights and Important Information
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, FTLG will endeavor to comply with the law or contract.
10.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third-Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information, disclosed to those parties. FTLG does not share Personal Information with Third-Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, FTLG or to which FTLG discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Services” means any legal service provided by FTLG to a customer under an engagement letter or agreement.
- “Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, FTLG or FTLG’s Agents.
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