Last Updated: April 2020
We do process some personal data in the course of our day to day business. In certain circumstances, we may share your data with third parties (for example, pursuant to a court order, if we are part of a merger, or with our business partners and service providers who support our business or collaborate with us). We take the privacy and security of your information very seriously and we have implemented a number of safeguards to keep your information secure. For a detailed explanation of our Policy, please read the full Policy below or contact us if you have any questions.
We value your privacy and we will always remain committed to protecting it. This Policy provides details about the type of information that we collect (collected from you or that you provide) as well as how we use, secure and disclose that information.
Please read this Policy carefully. By accessing or using any FedData Technology Services site, service or product (including email communications with us), you provide consent to this Policy. Please note that this Policy may change over time which may affect how we use the data described herein. Please remember to check this Policy periodically for any updates or changes.
Use and Security of Data
In the course of our business, we collect different types of information which include but are not limited to:
Information you provide to us. We may request or you may decide to provide us with your information. This information may include information that can be used to personally identify you (“personal information”) including, but not limited to, your name, employer, email address, telephone number and records of your correspondence with us.
Information collected from forms on our websites. This is the information you provide when you contact us through our website. We may also ask you for certain information if you are reporting a problem with our website.
Usage details, IP addresses and cookies. When you visit and browse through our website, we may automatically collect some information about your computing equipment, browsing actions using industry acceptable techniques like cookies and web beacons. The information collected may include detailed information about your visit to our website which may include details of your connectivity, IP address, browser information, location data, logs and your activity on our website.
Email marketing. As a current, previous or prospective customer or user of our products or services, you may, from time to time, receive emails from us regarding our products and services. This type of processing may include the placing of beacons which will tell us if the email was opened. We undertake these activities to determine if you are receiving our emails and if you find them to be useful. Such processing may include the placing of beacons, or pixels, that let us know if you have opened our email and how long the email was open. We do this in order to see which emails are effective and which are not, so that we can improve our content and services. We will never track your location or device information in doing this processing or data collection.
General business-related information. We may also receive other personal information from or about you in the ordinary and customary course of our business.
The information that we collect or that you provide to us about you is used:
- To present our websites, products and services to you
- To improve our products and services
- To provide information you request about products and services
- To provide notice(s) to you about our products, services, changes to our products and services, new products and services, changes to our website, promotions and events
- To continually improve and maintain the security of our website, products and services
- To sell the products and services of third parties that we believe may be of interest to you, subject to your opportunity to opt-out of those communications
- To process information related to transactions you enter into with us, including your purchase of our products and/or services
- For our ordinary business operations, including human resources, recruiting, investments, and business research and outreach
Legal basis for the processing. We only process personal data if we have a legal basis to do so. The legal basis of our process includes one or more of the following:
- You have provided consent to processing your information for one or more specific purposes
- Processing is necessary to perform a contract or obligation on your behalf or to take steps, at your request, prior to entering into a contract or obligation
- For compliance with a legal obligation
- Necessary to protect the vital interests of you or another person
- Necessary to carry out a task that is in the public interest
- Necessary for our legitimate interests as long as it does not unduly affect your interest, fundamental rights or freedoms
To the extent that we process any special categories of your information, we do so because:
- The information is in the public domain;
- Processing is necessary to establish, exercise or defend a legal claim;
- Processing is necessary for reasons of substantial public interest; or
- You have explicitly given your consent to process the information (where legally permitted).
Disclosing Your Information to Others
The protection of your information is very important. We will not rent or sell your information. We may however disclose your information that we collect, or you provide as described in this Policy, including:
- To a successor in interest as the result of the merger or acquisition of all or substantially all of our stock or assets or as the result of the merger, acquisition, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, in which personal information about our websites’ users is included in the assets transferred or acquired
- To our subsidiaries, affiliates, agents, contractors, service providers and other third parties that we use within our business or with whom we collaborate and are contractually bound to keep your personal information secure and use it only for the purposes of providing services for or with us
- To comply with any court order, law or legal process, including to respond to any legitimate government or regulatory request
- To enforce or apply our terms and conditions and/or any other agreements that govern the sale or use of our products and services
- To protect our rights, property or security, including that of our employees, users and/or others.
International Transfer of Your Information
In the ordinary course of our business and in compliance with applicable laws, we may from time to time, transfer and/or access your personal information from our offices, subsidiaries, and affiliates in the various locations in which we conduct business including the United States, the EEA and non-EEA countries.
If we transfer or access your personal information outside the EEA, we will ensure that safeguards are in place so that the transfer and/or access is compliant with applicable laws.
To do so, we may utilize a data transfer agreement or other data transfer mechanism with such third party recipients based on the Model Clauses published by the European Commission, enforce that transfers are subject to an adequacy decision of the European Commission or is subject to the EU-US and/or Swiss-US Privacy Shield framework. You may exercise your rights to request additional information or receive a copy of these safeguards.
Integrity and Extent of Collection
We will only collect and store your personal information as necessary for the specific purposes identified in this policy. We will not use your personal information in any way that does not comply with this policy.
Your Rights and How to Exercise Them
You may have a right to access and obtain a copy of your personal data that we store and processed. If you believe that any of your information that we hold about is incorrect or incomplete, you are entitled to request the correction of your personal data.
You may also have the right to:
- object to the processing of your personal data;
- request the erasure of your personal data;
- request restriction on the processing of your personal data; and/or
- withdraw your consent where we obtained your consent to process personal data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).
We assure you that we will honor these requests, withdrawal or objection as required under applicable laws but please understand that these rights are not absolute; these rights do not apply in all circumstances and exemptions/exceptions may be applicable. Typically, in response to a request, we will ask you to verify who you are and possibly for additional details necessary to fully understand your request. If we are not able to comply with your request, we will tell you why.
How to Exercise Your Rights
In order to exercise your rights described in the Policy, please send an email to firstname.lastname@example.org. If you are dissatisfied with how we process your data or if you have any concerns, please send an email to email@example.com.
If you are not satisfied with our response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen. The contact details of each Data Protection Authority can be found at the following website: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
California Consumer Privacy Act
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing this additional information which supplements the disclosures and information throughout this Policy. This section only applies to individuals covered by the CCPA, and are subject to certain statutory exceptions contained in the CCPA itself.
The personal information we collect, use, and disclose regarding California residents, and the categories of the sources of such information, is described above in the section, “Use and Security of Data.” We certify that we do not sell the personal information of California residents and we will not do so without providing you with the opportunity to opt-out as required by the CCPA. The disclosure of such information to any third party in the 12 months preceding this policy have been in full compliance with the above section titled “Disclosing Your Information to Others”. We do not sell the personal information of minors under the age of 16.
Under the CCPA, covered individuals have a right to request that we disclose what, if any, information we collect, use, disclose and sell about you as well as to request that we delete the information we have collected about you. If you are entitled to such a right and would like to exercise it, please submit a request to firstname.lastname@example.org referencing “CCPA Request” in the subject line of your email. Please include all specific details of your request including what information you would like to know or have deleted. We may request additional details to confirm your identity and/or to fully understand your request. We will respond to all request in compliance with the CCPA. You also have the right to use an authorized agent to submit your request. We will not discriminate against you in any way because of your decision to exercise your rights under the CCPA.
We have gone to great length to implement security measures within our company to protect your information against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure, access or other forms of unlawful processing. Although we have gone to great length to protect your information, we cannot guarantee the security of information transmitted to our website. Any transmission of your data over the internet cannot be completely secure and we cannot and do not warrant that the information you submit to us will be secure. We also take no responsibility for your circumventing of any privacy settings of our website.
We retain your data only as long as necessary for us to fulfill the purpose for which we collected it in the first place and to comply with applicable legal, regulatory and internal policy.
Changes to This Policy
In order to comply with evolving laws, regulation and other internal policies, we may amend this Policy from time to time. Any changes to this policy will be published on our website so please review this policy periodically for any updates. Please contact email@example.com with any questions, concerns or complaints.
Children Under the Age of 13
Our website, products and services are not intended for anyone under the age of 13. If you become aware that your child has provided us with any of their information, please contact firstname.lastname@example.org and we will make efforts to delete it. We will never knowingly collect personal information of individuals under the age of 13.
Data Protection Officer
Our Data Protection Officer can be contacted via email at email@example.com.
Please contact us at firstname.lastname@example.org with any questions, concerns or comments about this Policy or its application.
You may also contact us in writing by sending correspondence to:
FedData Technology Solutions
Attn: Data Protection Officer
7055 Samuel Morse Drive, Suite 200
Columbia, MD 21046