TYPES OF INFORMATION AND DATA WE COLLECT
When you sign up with the Service, you submit information that can be used to identify you and/or to communicate with you. We collect this “Personally Identifiable Information” or “PII.”
PII includes but may not be limited to the following:
Contact Information that allows us to identify and to communicate with you, such as name, e-mail address, business phone number, physical address, and location-based data.
Relationship Information that helps us understand who you are and what you want in order to offer you products and services that may interest you.
Transaction Information about how you interact with FCM and our Services, including service inquiries.
Non-PII Information That Is Collected
We may automatically collect certain information that is not PII, such as your browser type, platform/OS, device data, clickstream data and cookies.
HOW FCM COLLECTS INFORMATION & DATA
Directly From You:
We collect PII directly from you when you submit it to us, such as when you submit a request for service or information or register for our Services.
From Our Services:
HOW FCM MIGHT USE INFORMATION & DATA (THE “PURPOSES”)
FCM may use PII for a variety of purposes, including:
- Customer Service and Support: to fulfill requests for services and to deliver information such as product improvement;
- Marketing: to provide you with communications and offers for products and services from FCM or suppliers and partners, including offers based on your business characteristics and location unless you opt-out;
- Eligibility: to determine if you are eligible for certain products, services or offers;
- Communications: to provide you with information that may be of interest, such as FCM news, announcements, reminders, and technical service bulletins; and
- Manage Our Everyday Business Needs: such as product development, administration of the Services, analytics, reporting and legal compliance.
- Required by law: such as in response to a subpoena, including to law enforcement agencies and courts.
How FCM will not use PII:
- Not sell it or rent it: to a third party without your permission
- Not associate PII with non-PII
DISCLOSURE OF PII
We limit our sharing of PII as follows:
- We may share PII with our business partners and suppliers, which may use it for the Purposes listed above.
- We may also share PII with our service providers to fulfill the Purposes on our behalf. Our service providers are bound by law or contract to use PII only in accordance with our instructions.
- We may disclose PII where needed to effect the sale or transfer of business assets, to enforce our rights, protect our property, protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will also disclose PII when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts.
COOKIES AND SIMILAR COLLECTION TECHNOLOGIES
When you visit our website we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also may record the IP address of the device you use to connect to the Internet, our Site pages that you visit, the time and date of your visit. We may also collect information about the website you were visiting before you came to FCM and the website you visit after you leave our site.
In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to PII. For example, we use information we collect about website users to optimize our website and to understand website traffic patterns.
In some cases, we do associate the information we collect using cookies and other technology with your PII. This Policy governs how we use all of this information when we associate it with your PII.
FCM has relationships with third party advertising analytics companies to perform tracking and reporting functions for our web processing. These third-party advertising companies may place cookies on your computer so that they can display targeted advertisements to you. These third-party advertising companies should not collect PII in this process, and we do not give PII to them as part of this process.
EXTERNAL DATA STORAGE SITES
We may store your data on servers provided by third party hosting vendors with whom we have contracted.
YOUR CHOICES — OPT-OUT
You can limit the information you provide to FCM. You can also limit the communications that FCM sends to you. To opt-out of marketing emails, you can visit our website and communicate your choice to the relevant privacy contact.
You can manage cookie preferences and opt-out of having cookies and other similar collection technologies used by adjusting the settings on your browser or interface.
If you have any questions about your choices, please contact us via email at firstname.lastname@example.org. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.
ACCESS TO, CORRECTION AND DELETION OF PII
FCM complies with applicable law regarding your ability to access, correct and delete your PII. If you have an online account, you may be able to log into your account to access and update certain information you provided to us.
You may direct us to delete your PII by sending an email, asking us to terminate your account. We will not delete PII associated with an active account, nor information that is subject to current or reasonably anticipated legal process or retained for business purposes. We may keep information that is not PII indefinitely, regardless of the status of your account.
If you need assistance updating or deleting your PII, please contact us via email at email@example.com. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.
FCM uses industry-standard security measures to protect the loss, misuse, and alteration of the information under our control, and we make good-faith efforts to store PII in a secure operating environment. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, while we strive to protect PII, we cannot ensure or warrant the security of any information you transmit to, and you do so at your own risk.
YOUR PRIVACY RESPONSIBILITIES
To help protect your privacy, be sure:
- to log off the FCM website when you are finished; and
- to take customary precautions to guard against “malware” (viruses, trojan horses, bots, etc.), for example by installing and updating suitable anti-virus software.
LOCATION AND APPLICABLE LAW
The Service is designed for use only by persons located within the United States. All PII and other information is kept on servers located in the United States and subject to its laws. You waive all claims that your PII is, will, or should be collected, processed and/or used in accordance with the laws of any country other than the United States.
PRIVACY POLICIES OF THIRD PARTIES
This Policy only addresses the use and disclosure of information and data collected by FCM. Other websites that may be accessible through this website have their own privacy policies and practices. We encourage you to familiarize yourself with third parties’ (companies not under our control, individuals not employed or managed by us) privacy statements directly prior to providing them with information or taking advantage of an offer or promotion.
CHANGES TO THIS PRIVACY STATEMENT
We may update this Policy from time to time to reflect new or different privacy practices. We may place a notice on our homepage when we make material changes to this Policy. We may also notify you about the change by sending a notice to you.
HOW TO CONTACT US
Flatirons Capital Management, LLC
C/O Legal Department 3356
Ironbound Road Suite 304
Williamsburg, VA 23188
LAST REVISED December 05, 2016