SECTION 1: INTRODUCTION
FSFP is a business advisory and information management consultancy dedicated to helping companies leverage their data to improve strategic decision-making, reduce risk, create operational efficiencies and fuel unprecedented business success. Founded in early 2007, FSFP’s vision is to enable organizations to turn their information into value.
1.2 Definition of Personal Data and Personal Information
“Personal data” is defined in Article 4(1) of the GDPR as follows:
“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
The California Consumer Protection Act broadly defines “Personal Information” as follows:
‘“Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Cal. Civ. Code § 1798.140(o)(1).
SECTION 2: HOW WE USE YOUR PERSONAL DATA
In this section, we detail the categories of personal data we may collect, and the purposes for which we may use the personal data.
We provide visitors to our website the opportunity to opt-in to receive communications from us to receive our monthly newsletter for industry news or information about educational conferences and webinars we participate in. In this case, we ask for the visitor’s email address.
We may also share your personal data with other third party service providers for other business purposes, including for example, the purposes outlined below:
- We may share your personal data with third party service providers that provide services to us, including customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
- To protect and defend the legal rights, safety, and security of FSFP, other users, or the public, including to protect against fraud and malicious activity; and,
We may also share your personal data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
You may opt out of receiving any, or all, of these communications by emailing us at firstname.lastname@example.org or by clicking on the “unsubscribe” link in any email we send to you, or by replying to any email we send you and entering the word “UNSUBSCRIBE” in the subject line.
FSFP will never ask you for more personal data than we collect to provide you with our communications. If you receive emails or other communications purporting to be from us which attempt to gather any additional information, especially sensitive personal data from you, please disregard them.
This website may also collect the following information via its contact and inquiry form features, which you may choose to complete. The inquiry data may be used for the purpose of offering, marketing and selling relevant services to you:
- First and Last Name (required)
- Company, Company Size and Title (optional)
- Email (required)
- Phone (optional)
- “How did you hear about us?” (optional)
- “What can we help you with?” (required)
Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics. This may include details of your visits to our website, the pages you view, and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section below for more information.
2.4 Sensitive Personal Data
We do not seek to collect sensitive personal data as defined below (also known as special categories within GDPR) through this website or otherwise. In the unlikely event where we may seek to collect such personal data, we will do this in accordance with data privacy law requirements and/or ask for your consent. The term “sensitive personal data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
SECTION 3: LAWFUL BASIS TO USE YOUR PERSONAL DATA
3.1 Lawful Basis to Process Your Personal Data
FSFP may process your personal data based upon the following lawful bases:
|Manage your request to receive newsletters and other communications from FSFP.||FSFP’s legitimate interest of ensuring that it manages appropriate communications with website users.
|Facilitate communication with you.||FSFP’s legitimate interest of ensuring proper communication within the organization and with you.|
|Perform administrative functions.||FSFP’s legitimate interest of ensuring that it performs appropriate administrative functions for use of your personal data.|
|Perform data analytics, including analysis of our website users in order to better understand who may be interested in receiving information from FSFP and performance of our website.||FSFP’s legitimate interest of ensuring that it continually improves its analytics processes.|
|Transfer your contact information, and other personal data, all as supplied by you in our system, to the FSFP marketing database that we maintain to notify you about new developments that may be of interest to you.||FSFP’s legitimate interest of ensuring that it manages appropriate communications with website users.|
|Perform any legally required reporting, and respond to legal process.||Compliance with a legal obligation.|
Where the above table states that FSFP relies on our legitimate interests for a given purpose, we did consider your potential interests, fundamental rights and freedoms and if those could be impacted by our processing activities. We did balance your interests, rights and freedoms against our interests, taking into account the purposes of the processing, the security of your personal data and our existing relationship with you. Based on this balancing test and with our efforts to inform you in a very transparent way of the processing activities, we are of the opinion that it does not materially impact any of your interests, rights and freedoms by processing your personal data.
SECTION 4: RETENTION, ACCESS AND STORAGE OF PERSONAL DATA
- FSFP retains your personal data as long as it has an ongoing relationship with you;
- FSFP retains your personal data where it is required to do so by a legal obligation to which it is subject; and,
- FSFP retains your personal data where this is advisable to safeguard or improve FSFP’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).
4.2 Access to Your Personal Data, Location of Storage
SECTION 5: COOKIES AND LINKS
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit the website that are sent by a web server to a browser in order to allow the website to recognize your device. Cookies may either be persistent (stored until expired or deleted) or session (expires at end of session). Cookies managed by FSFP only are called “first party cookies” whereas cookies from third parties are called “third party cookies” as explained below. Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience.
5.2 Cookies Inform Easier or Faster Access to Website Features
5.3 Managing Cookies
Web browsers allow for accepting or deleting cookies. For the most up-to-date information, please see the applicable support documentation for your specific browser and version. Please note that deleting and blocking cookies may have an impact on your user experience of FSFP’s website.
5.4 Links to Websites and Programs of Third Parties
Our website may include:
- Links to and from the sites of our partner networks, advertisers, and service providers; and,
- Certain programs (widgets and apps) of third parties, and if this is case, please note that such third parties may process your personal data collected through such programs for their own purposes.
SECTION 7: DATA SECURITY
We maintain organizational, physical and technical security controls for all the personal data we hold. These controls are implemented in order to maintain the security of your personal data, including the use of encryption, physical access controls, information access controls, anti-virus and anti-malware software, along with service infrastructure support and cloud hosting from leading information technology and security providers, including Microsoft. We also have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.
Please be aware that, despite our best efforts, no security measures or controls are perfect or impenetrable. Therefore, FSFP cannot guarantee or warrant the security of any data collected through the website or inquiry portal and cannot be responsible for the theft, destruction, loss or inadvertent disclosure of any data.
You may submit any questions you may have about our security procedures by emailing us at email@example.com.
SECTION 8: YOUR RIGHTS
8.1 Description of Rights
You have certain rights with respect to the processing of your personal data (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) as follows:
- The right to request access to your personal data: this right entitles you to request access to personal data we process about you, as well as to certain information on such processing;
- The right to request rectification of your personal data: this right entitles you to request the correction or completion of any of your personal data that would be inaccurate or incomplete;
- The right to request erasure of your personal data: this right entitles you to request the deletion of your personal data, including where such personal data would no longer be necessary to achieve the purposes;
- The right to object to the processing of your personal data: this right entitles you to request that we no longer process your personal data;
- The right to request the restriction of the processing of your personal data: this right entitles you to request that we only process your personal data in limited circumstances; and,
- The right to request a copy or the portability of your personal data: this right entitles you to receive a copy of personal data that you have provided to us.
CA Consumer Privacy Rights
California Civil Code Section 1798.83 (known as the “Shine the Light” law) requires certain businesses to respond to requests from California consumers about personal data or personal information disclosed to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for third parties’ direct marketing purposes. In the event we do so in the future, we will not disclose any of your personal information to third parties for third parties’ direct marketing purposes unless you consent at the time that you provide your personal information.
SECTION 9: HOW TO CONTACT FSFP