FIRST RISK ADVISORS PRIVACY
Effective as of September 1, 2018
with how we collect, use and share your personal information if you visit FIRSTRISKADVISORS.COM (“the Website”) to view information about our company and products, services, and sign up for an e-mail newsletter (collectively, the “Services”);
- Personal Information We Collect
- How We May Use Your Personal Information
- How Your Personal Information May Be Disclosed
- Other Information
- International Data Use
- Your Choices and Access
- Tracking and Targeted Advertising
- Social Media Widgets
- Third Party Sites and Services
- User-Generated Content
- Use of Services By Minors
- Contact Us
- Additional Information For European Union Users
2. PERSONAL INFORMATION WE COLLECT
We collect personal information about you in the following ways:
Information you give us
Personal information that you may provide through the Services or otherwise communicate with us includes:
- Identity information, such as your first name, last name, username or similar identifier, title or role, date of birth and gender;
- Contact information, such as your postal address, email address and telephone number;
- Registration information, such as your company name;
- Feedback and correspondence, such as information you provide when you send us a message, report a problem with Services, receive customer support or otherwise correspond with us;
- Usage information, such as information about how you use the Services and interact with us;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with us; and
- Employment application information, such as your resume, LinkedIn profile, cover letter and online portfolio when applying for a job with us.
Information automatically collected
Our servers may automatically record certain information about how you use the Services, such as your Internet Protocol (IP) address, device and browser type, operating system, the pages or features of the Services that you browsed and the time spent
on those pages or features, the frequency with which you use the Services, search terms, the links that you click on or use, and other statistics. We collect this information in server logs and by using cookies and similar tracking technologies to
Sensitive personal information
Subject to the following paragraph, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics
or genetic characteristics, criminal background or union membership) on or through the Services or otherwise.
If you do not consent to our processing and use of such sensitive personal information, you must not provide it.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at firstname.lastname@example.org.
3. HOW WE MAY USE YOUR PERSONAL INFORMATION
We may use Personal Information for the following purposes or as otherwise described to you at the time of collection:
To provide the Services
We use your personal information:
- to operate, maintain, administer and improve the Services;
- for our business purposes, such as data analysis, audits; developing new products; and operating, maintaining, administering, enhancing, improving or modifying our Services; identifying usage trends; determining the effectiveness of our promotional
campaigns and operating and expanding our business activities.
- to manage and communicate with you regarding your Services, including by sending you Services announcements, technical notices, updates, security alerts, and support and administrative messages;
- to send administrative information to you, such as information regarding the Services and changes to our terms, conditions, and policies.
- to better understand your needs and interests, and personalize your experience with the Services; and
- to respond to your Services-related or employment-related requests, questions, and feedback.
To send you marketing communications
If you request information from us, use the Services or participate in our surveys, promotions or events, we may send you FRA-related marketing communications, which we believe may be of interest to you, as permitted by law but will provide you with the
ability to opt out.
To deliver you advertising and other FRA information
We and our partners may tailor ads based on your interests and browsing history or conduct retargeted advertising. See the Tracking and Targeted Advertising section below for more details.
For security, compliance, fraud prevention and safety
We may use your personal information as we believe appropriate to (a) investigate or prevent violation of the law or our Terms of Services; (b) secure the Services; (c) protect our, your or others’ rights, privacy, safety or property; (d) conduct
fraud monitoring and prevention activities; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
For compliance with law; legal claims
We may use your personal information as we believe appropriate (a) under applicable law, including laws outside your country of residence; (b) to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests
from government authorities; (c) where permitted by law in connection with a legal investigation; (d) to enforce our terms and conditions; (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (f) to
prosecute or defend legal claims; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
With your consent
In some cases, we may ask for your consent to collect, use or share your personal information, such as when you let us post your testimonials or endorsements in the Services.
4. HOW YOUR PERSONAL INFORMATION MAY BE DISCLOSED
- Service Providers. We may share your personal information with our third party service provides so that they may administer and provide the Services on our behalf, or provide other services such as marketing, billing, data analysis,
customer service, email delivery, auditing, and other services.
in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar disclose your personal information
as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government
authorities; (c) where permitted by law in connection with a legal investigation; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property,
and/or that of our affiliates, you or others; (g) to prosecute or defend legal claims; and (h) to allow us to pursue available remedies or limit the damages that we may sustain.
- Compliance with Laws and Law Enforcement; Protection and Safety. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the security, compliance, fraud
prevention and safety purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation;
and (d) to prosecute or defend legal claims.
5. OTHER INFORMATION
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information
- Aggregated information
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
How We May Collect Other Information
HOW WE MAY USE AND DISCLOSE OTHER INFORMATION
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information
as Personal Information as long as it is combined.
THIRD PARTY SITES AND SERVICES
Services does not imply endorsement of the linked site or service by us or by our affiliates.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure and we cannot guarantee
the security of your information.
7. INTERNATIONAL DATA USE
FRA is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in
the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
European Union users should read the important information provided here about transfer of personal information outside of the European Economic Area.
8. YOUR CHOICES AND ACCESS
Access, Update, Correct or Delete Your Information
All Website users who provide their personal information may review, update, correct or delete the personal information they provided by contacting us at email@example.com.
You may opt out of marketing-related emails by logging in and changing your account settings or by following the opt-out prompt in the email. You may continue to receive Services-related and other non-marketing emails.
If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us at firstname.lastname@example.org.
Choosing not to share your personal information
If you do not provide information indicated as required or mandatory within the Services, or that is otherwise necessary to provide a requested service or feature within the Services, that portion or all of the Services may be unavailable to you.
9. Tracking and Targeted Advertising
to manage our advertising on other sites. These advertisers may also provide you targeted ads based upon your interests on third-party sites. We also use third party website analytics services that help us analyze users’ interactions with the
Website. For more details, see the Cookies and Similar Technologies Notice. Some advertising networks allow you to opt out of targeted advertising. For more information, visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track or similar signals. To find out more about “Do Not Track,” please visit
In some of our communications, we track clicks on links in the communications to content in the Services to help us measure the effectiveness of our communications.
10. Social Media Widgets
Our Services may include social media features and widgets, such as “like” button and “share this” button. These features may collect your personal information and track your use of the Services. These social media features are
11. Third Party Sites and Services
The Services may contain links to other websites and services operated by third parties, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement of, or representation that we are affiliated
with, any third party. We do not control third-party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and disclosure of your personal
information. We encourage you to read their privacy policies to learn more.
12. User-Generated Content
We may make available in the Services, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information
online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information
online in public forums, you may receive unsolicited messages from other parties.
13. USE OF SERVICES BY MINORS
The Website and Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Information through the Services. If we learn that any user of the Services is under the age of 13, we will take appropriate
steps to delete that individual’s personal information and restrict that individual from future access to the Services.
14. YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits customers of FRA who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please
send an e-mail to: email@example.com. or write us:
67 West Court Street Doylestown, PA 18901
account linked to a valid email address) or another manner through the Services that we believe is reasonably likely to reach you.
16. CONTACT US
67 West Court Street Doylestown, PA 18901
Attention: David W. Opperman
17. ADDITIONAL INFORMATION FOR EUROPEAN UNION USERS
Controller and EU Representative
VeraSafe has been appointed as First Risk Advisors' representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to
firstname.lastname@example.org, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy- services/contact-article- 27-representative
Alternatively, VeraSafe can be contacted at:
Unit 3D North Point House
North Point Business Park
New Mallow Road
Keizersgracht 391 A
1016 EJ Amsterdam
Legal bases for processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how
we process your personal information, contact us at email@example.com.
To provide the Services
You have entered a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services.
To send you marketing communications; For security compliance; fraud prevention and safety; to prosecute or defend legal claims; to deliver advisements
These processing activities constitute our legitimate interests. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests.
We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
For compliance with law
Processing is necessary to comply with our legal obligations.
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Services or by contacting us at firstname.lastname@example.org
Use for new purposes
we will notify you and explain the applicable legal basis.
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes
for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive Services-related and other non-marketing communications.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process
your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information
or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and
processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States. In
certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.