Effective Date and Date of Most Recent Revision: June 11, 2019
Compliance Statement. Notwithstanding any other term or condition of the TOU, and to the extent required by applicable law, FGS complies with the applicable provisions of (i) the General Data Protection Regulation of the European Union regarding personal data collected from Users, including individuals who reside in the European Union, and (ii) the California Consumer Privacy Act.
Data Controller. FGS is the controller of the personal data and personal information (collectively referred to as “personal data”) that is collected by FGS from Users and/or about consumers.
Chief Privacy Officer. The Chief Privacy Officer of FGS is Frank Aparicio, who can be reached by email at firstname.lastname@example.org and by phone at 323-582-0671.
Description of Personal Data and Information
(a) FGS collects the following categories of personal information and personal data for the following purposes, and only to the extent that the collection and processing of personal data is adequate, relevant and not excessive in relation to these purposes:
- User-Provided Information. FGS collects information that is provided by the User during the registration process at the ICF Website(s) (collectively, the “User-Provided Information”). Such information may include, but is not limited to, name, address, phone numbers, email addresses, and other contact information. All of the User-Provided Information (with the sole exception of financial data, such as credit card numbers, provided by the User in connection with the on-line donations) is intended by the User to be used by FGS in its communications and dealings with the User.
- Credit Card Transactions. If the User provides credit card and other financial information in connection with on-line purchases of goods and services from FGS, such information shall be used by FGS (and/or third-party services engaged by FGS) only for the purpose of processing the payments and will not be maintained on file by FGS.
- Cookies. The Website(s) may employ “cookie” technology to keep track of a User’s activity and usage of the Website(s) and to collect and store information between a User’s visits to the Website(s). Cookies are small text files stored on the User’s computer that a website can use to recognize repeat users and to facilitate each user’s ongoing access to and use of a website. Generally, cookies work by assigning a unique number to the user that has no meaning outside of the assigning site. FGS cannot control the use of “cookies” by advertisers or third parties hosting data or facilities for the Website(s). Users who elect to remove or disable the “cookies” on their computers may impair the functionality of the Website(s). As set forth in the notice that appears on the landing page of the Website(s), any User who enters the Website(s) after landing on the landing page is consenting to the use of “cookies” as described above.
- Release of Information Under Other Circumstances. FGS reserves the right to disclose information whenever required to do so in order to comply with applicable law and/or legal process, and/or to enforce the terms of the TOU or any other agreement between the User and FGS, and/or the protect or enforce the rights, property, safety, or security of FGS, its advertisers and affiliates, and its employees, contractors, vendors, agents and representatives.
(b) FGS uses its best efforts to assure that personal data is accurate when collected and updated when and where necessary to meet that objective.
(c) FGS takes every reasonable step to correct or delete personal data that is inaccurate or incomplete.
(d) Personal data collected by FGS is kept for no longer than is necessary for the purposes for which the data was collected or for which it is further processed, and is deleted if and when it is no longer necessary for these purposes.
(e) FGS utilizes appropriate technical and organizational measures to protect against loss, alteration and/or unauthorized disclosure of, and/or access to, personal data and/or the unauthorized processing of personal data.
Rights of User. As may be required under applicable law, the rights of the User may include: (i) the right to be notified of the personal information collected from them, and the purpose for collecting each category of information, at or before the point at which the information is collected; (ii) the right to receive copies of specific personal information collected; (iii) the right to withdraw their consent to the collection and processing of personal data and/or the use of “cookies”; (iv) the right to access the personal data and rectify, erase or block the data, (v) the right to receive the personal data that FGS has collected and to transmit the personal data to another data controller; (vi) the right object to the processing of their personal data without express consent, that is, the right to “opt out.” Users may exercise any such applicable rights by contacting the Chief Privacy Officer.
Rights of Consumers. Consumers whose personal information has been collected by FGS may have rights set forth by applicable law even if they are not Users. Consumers may exercise any such applicable rights by contacting the Chief Privacy Officer.
No Sale or Other Disclosure of Personal Data. FGS does not sell the personal data or personal information of Users or consumers to third parties, and does not disclose such data to third parties except as described in the TOU.
User Authorization. By clicking on the I AGREE button, however, Users are also acknowledging and agreeing that (a) FGS is authorized to transfer their personal data outside the European Union, and (b) because FGS is explicitly authorized to make the personal data of some Users to third parties, FGS will be able to rectify, erase or block the data that remains under its direct control but may not be able to do the same for personal data that has already been made available to third parties with the consent of the User.
Children’s Online Privacy. FGS does not target, solicit the participation of, and/or provide services directed to children under the age of 18. Any User who is under the age of 18 must secure and submit to FGS verifiable written consent from his or her parent or guardian before accessing or using the FGS Website(s). Please direct any such submissions to the Chief Privacy Officer.
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