13 May 2022


Flatirons Solutions, Inc. ("Flatirons” or the “Company”) (a Delaware corporation with its headquarters at 5755 Central Avenue, Suite A, Boulder, Colorado 80301) together with its affiliates are committed to protecting your Personal Information, which is information that alone, or with other information, identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person (“Personal Information”). We have created this Privacy Policy (this “Privacy Policy”) to describe how we collect, use, store, and disclose Personal Information, including any Personal Information that we collect from the website on which this Privacy Policy is posted (“Website”). This Privacy Policy is incorporated into and made a part of the Terms of Service (the “TOS”) Agreement among us and the various customers and other visitors to our Website (collectively, “Visitors”). Capitalized terms used, but not otherwise defined in this Privacy Policy have the meanings given to them in the TOS. The purpose of this Privacy Policy is to describe for Visitors what Personal Information we collect, store, use, and disclose, and how we collect, store, use, and disclose that Personal Information. Flatirons is a “Service Provider” for its customers, and as such, the TOS describes the business purposes for which Flatirons collects and processes Personal Information (such purposes, the “Services”). To allow Flatirons to provide the Services, and for Visitors to use the Website, Flatirons must collect and be permitted to disseminate certain information as further described in the TOS and this Privacy Policy.

Please read this Privacy Policy carefully. By accessing or using this Website or otherwise providing us with Personal Information, you acknowledge, accept the terms of, and consent to our privacy practices as outlined in this Privacy Policy. If you do not want to acknowledge our privacy practices contained in this Privacy Policy, do not use the Website, or provide any Personal Information to us. We reserve the right, at any time, to modify, update or revise this Privacy Policy. We will post those revisions to our Website, and your continued use of the Website will constitute your consent to the modifications. You should review this Privacy Policy periodically to keep up to date on the most current versions.

If you are a California resident, additional information applicable to California residents is below in the Section titled, “Your California Privacy Rights.”

  1. Information We Collect

    The Personal Information we may request from you includes:

    • Your name;
    • Surname;
    • Email address;
    • Phone number;
    • Employer / company;
    • Region;
    • Information relating to your educational and professional experience, CV, and references;
    • Recruiting information required by applicable law;
    • Internet Protocol address; and
    • Physical Address.

    We may also take the Personal Information we receive from individuals responding to our surveys, remove any personally identifying information, such as names and phone numbers, to create anonymous profiles (“Profiles”), and combine (or aggregate) it with the other Profiles. These combined Profiles may contain information about the gender, age, education, employment, industry sector, or other demographic information of our customers, which we use to improve the quality of our services to you and to develop new services and products. These combined Profiles may be shared with third parties.

    If you seek to apply for employment with us via the Website, you will be redirected to our third party provider, Clear Company, and your application process will be governed by Clear Company’s privacy policy posted at https://www.clearcompany.com/privacy-policy. Any application data you share with Clear Company may be shared with us to consider your application.

    When you browse our Website, we also automatically collect and aggregate other information about you using cookies, tracking pixels and related tracking technologies, browser analytic tools, server logs, and similar technologies. These tracking technologies may be implemented and placed by us or by third party vendors on our behalf and they allow us to collect information by automated means. For example, information about how many web pages have you used, what hyperlinks you clicked, access times and number of visits may be collected. We also may collect geo-location information through your IP address and mobile devices. This information is anonymous and used for internal analysis only.

    We use Google Analytics to collect and process information about your use of the Website. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Website.

    To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

  2. Cookie Policy

    Cookies are small data files stored on your hard drive by the Website. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience.

    Cookies used on our Websites

    We use session cookies. These cookies are essential to enable users to move around our Website and use its features, such as accessing secure areas of our Website.

    We also use performance cookies. These cookies allow us to see which areas and features are popular and to count visits to our Websites. These cookies do not collect information that identifies an individual visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.

    We also use functionality cookies. These cookies allow the Website remember choices you make to (such as your language or the region you are in) and provide enhanced, more personal features to improve your experience. These cookies are required for basic site functionality and therefore they are always enabled. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

    We also use targeting cookies, which we use for web analytics purposes. All information these cookies collect is aggregated and therefore anonymous.

    Managing cookies

    Most website browsers automatically accept cookies, but you can change your browser settings. However, if you choose to disable the receipt of cookies from our Website, you may not be able to use certain features of the site. Visit www.aboutcookies.org to learn about how to delete and control cookies using the mail browser types.

    We also may collect information by periodically conducting business and individual customer surveys. These surveys help us to improve the types of products and services we offer and how we provide them to you.

    Do Not Track

    Because we automatically place and process cookies and other tracking technologies, we currently do not honor “Do Not Track” requests.

    Server Logs and Beacons

    Web server logs are activity records created when Visitors visit web pages, such as search terms, device information, browser information, IP address, access times, and pages viewed. Web Beacons are electronic files that allow us to recognize and count Visitors and can be used to determine response rates to our communications.

    Device Information and Location Information

    We may also collect information about your devices, such as location, hardware and software, operating system, device memory, advertising identifiers, application identifiers, browser type, language, time zone; device sensor information. We may ask for permission to collect images and other information from your device’s camera.

  3. The purposes for which we collect your Personal Information

    We collect your Personal Information for the following purposes:

    • enable your access and use of the Website;
    • operate and improve our services;
    • recruiting;
    • understand you and your preferences to enhance your experience and enjoyment using our services;
    • respond to your feedback, comments and questions and provide customer service;
    • provide and deliver products and services you request;
    • send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
    • communicate with you about products and services we offer;
    • after your submission of information and consent for this action, we create an individual profile for you so we can enhance your user experience;
    • to track and analyze activity on our Website;
    • detect fraud, spam, abuse, security incidents, and other harmful activity;
    • conduct security investigations and risk assessments;
    • send messages, marketing, advertising, and other information (including information about our partner campaigns and services);
    • measure, and improve our advertising; and
    • enable us to comply with applicable law, regulatory requirements, and contractual obligations.
  4. Customer Contact

    When you provide us with your email and other contact information, you authorize us to contact you in accordance with this Privacy Policy and the TOS. We may use the information we collect to contact you by email to provide you with news and updates related to our or our partners’ products and services, invitations to events hosted by us or other industry organizations, notices of new promotions, and information on other similar events. We may also contact you by email to respond to your comments and questions, notify you of any changes to your account, or to send you information regarding our services, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative message. You may opt out of receiving marketing emails from us by following the directions in the marketing email you receive.

  5. Disclosure

    We will not sell your Personal Information. We may share your Personal Information with any member of our group, which means our affiliates and subsidiaries.

    We may share your Personal Information with third parties and/or service providers that provide services for us. For example, we may share Personal Information with vendors to help us host and manage the Website, support and maintain our software, and deliver products for us.

    Business Partners. We may share information about you with business partners. Our Website may also contain third-party links, third-party integrations, or offer a co-branded or third-party-branded services. Flatirons is not responsible for the content and/or collection of data at websites other than our Website, even if linked to or from our Website. You must review the applicable privacy policies of any websites linked from our Website to assess your rights under those policies.

    Merger or Acquisition. If we become involved in a merger, asset sale, financing, liquidation or bankruptcy, or sale/acquisition of all or some portion of our business, we may share your information with the other company before and after the transaction closes.

    Marketing. We may share information about you with third party providers for their products or services. We also may use your information to send you email marketing, direct mail marketing and other marketing of our products and services (and those of our partners). We may let other companies, on our behalf, and for the purposes provided herein, use cookies, web beacons, and similar technologies to collect information about how you use our services over time. Some companies we use in our Services may use information to measure the performance of ads and deliver more relevant ads on our behalf. You can opt-out of marketing emails, by clicking the link labeled “unsubscribe” at the bottom of any marketing email we send you. Please note that even if you opt-out of marketing communications, we may still need to contact you.

    We may also share your Personal Information with third parties where it is necessary to: (1) conform to legal requirements or comply with a legal process, such as a search warrant, subpoena, or court order; or (2) protect and defend the rights or property of Flatirons; or (3) to enforce a license and services agreement or other contractual obligations; or (4) detect and resolve fraud or security concerns; (5) respond to claims by third parties that your use of the Website violates their rights (including intellectual property rights)or (6) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  6. Retention

    We will keep Personal Information for the period necessary to fulfil the purposes described in this Privacy Policy unless a longer retention period is permitted or required by law. For example, we reserve the right to maintain information on customers who have violated our Privacy Policy, the TOS or any other license and services agreement between our company and a customer.

  7. Access from Outside the United States

    If you access this Website from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.

  8. Social Media

    We are active on social media, including Facebook, Twitter, Vimeo, and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Website and our Social Media pages any comments or content that you post on our Social Media pages.

    Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Privacy Policy. We encourage you to review those policies and terms.

  9. Users in the European Union

    Despite recent changes in European law, we continue to strive to conduct our activities in accordance with the Privacy Shield Principles laid out by the EU-US and Swiss US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland as further reflected in this Privacy Policy. Flatirons Solutions, including Flatirons Solutions, Inc. and its wholly owned US subsidiaries listed at the end of this Privacy Policy, has certified that it adheres to the Privacy Shield Principles. Under the Onward Transfer Principle, Flatirons Solutions remains responsible for any of your personal information that is shared on our behalf with third parties acting as our agents for external processing as described in the “Disclosure” section above. Flatirons remains responsible if its agents process your personal information in a manner inconsistent with this Privacy Policy, unless we can provide that we are not responsible for the event giving rise to the damage. Flatirons is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).To learn more about the Privacy Shield program, and to view Flatirons Solutions’ certification, please visit the Privacy Shield website at www.privacyshield.gov.

    If you have an unresolved privacy or data use concern that relates to our Privacy Shield certification that we have not addressed satisfactorily pursuant to the processes below in “Where to Direct Questions about Our Privacy Policy”, you may contact our U.S.-based third-party dispute resolution provider (free of charge) at http://go.adr.org/privacyshield.html. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

    For purposes of this section the terms “personal data”, “processing” and “automated decision” have the same meanings set forth under the EU General Data Protection Regulation 2016/679 (“GDPR”). THIS SECTION ONLY APPLIES TO YOU IF YOU ARE LOCATED IN THE EU.

    Legal Basis for Processing. When Flatirons processes your personal data, it has a legal basis for doing so as required under GDPR. Flatirons will only process your personal data if: (i) it has received your express opt-in consent for such processing, (ii) the processing is necessary for performance of a contract, (iii) the processing is necessary for a legal obligation to which Flatirons is subject, (iv) the processing is necessary to protect your vital interests, (v) the processing is necessary for a task carried out in the public interest, or (vi) if Flatirons or a third party has a legitimate interest that is not overridden by your interests or fundamental rights and freedoms.

    Right to Withdraw Your Consent. In the event you provide your consent for us to process your personal data, you may withdraw your consent at any time by emailing [email protected] to request such change.

    Marketing. Flatirons does not process personal data for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of your personal data for marketing purposes at any time by contacting us at [email protected].

    Automated Decision Making. Flatirons does not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of personal data via automated decision making at any time by contacting us at [email protected].

    Your Rights and Choices. GDPR provides certain rights to individuals in relation to their personal data. Accordingly, you may have the following rights under GDPR, although some exceptions apply. We will comply with any requests made relating to the following rights if required by applicable law. We may require you to prove your identity before we modify, provide, delete, or transfer your personal data.

    • Right of Access - You have the right to be informed of and request access to the personal data we process about you. This allows you to receive a copy of the personal data we hold about you.
    • Right to Rectification - You have the right to request that we amend or update inaccurate or incomplete personal data.
    • Right to Erasure (Deletion) - Under certain circumstances, you have the right to request deletion of your personal data.
    • Right to Restrict - Under certain circumstances, you have the right to request that we temporarily or permanently stop processing all or some of your personal data.
    • Right to Object - Under certain circumstances, you have the right to object to Flatirons’ processing of your personal data, such as for direct marketing purposes or when automated decision making is used.
    • Right to Data Portability - You have the right to request a copy of your personal data in electronic format and further request that we send such personal data to another party.
    • Communication Preferences and Opt-Outs - You have the right to stop receiving communications from us at any time by contacting [email protected], at no additional cost.
    • Right to Lodge a Complaint - You have the right to lodge a complaint with the applicable supervisory authority. Although you are not legally required to do so, we ask that you first contact us so we can make reasonable efforts to address your complaint.

    Transfer to Third Parties and Countries. Flatirons will only transfer EU data subject's personal data to third parties located outside of the EU when it has ensured appropriate safeguards for such personal data, such as through the standard contractual clauses with such third party. Flatirons may also be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  10. California Residents.

    This section applies only to California consumers acting in their individual capacity. In this section only, any capitalized terms not defined in this Privacy Policy have the meanings set forth in the California Consumer Privacy Act of 2018 as it may be amended (the “CCPA”).

    Collection, Source, Purpose, and Sharing of your Personal Information

    Categories of Personal Information. We collect the following categories of Personal Information:

    • Identifiers
    • Customer Records
    • Internet Activity
    • Employment Information
    • Education Information

    Categories of Sources from which Personal Information is Collected. We collect Personal Information from the following categories of sources:

    • Directly from you
    • Automatically using cookies and other tracking technologies

    Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section III of this Privacy Policy.

    Categories of Third Parties / Service Providers with whom Personal Information is Shared. The categories of third parties and/or service providers with whom we share your Personal Information are described in Section V of this Privacy Policy.

    Categories of Personal Information Disclosed for a Business Purpose

    In the last 12 months we disclosed the following categories of Personal Information for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA:

    • Identifiers
    • Customer Records
    • Internet Activity
    • Employment Information
    • Education Information

    We Do Not Sell Personal Information

    In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. “Sold” / "Sell" has the definition set forth in the CCPA.

    Right to Know. California residents have the right to request access to the following information: (a) the categories of Personal Information we collected from you in the prior 12-month period, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or Sold your Personal Information, (d) the categories of Personal Information that we Sold to third parties or otherwise disclosed for a business purpose in the prior 12-month period, and (e) the categories of third parties to whom we Sold or shared your Personal Information.

    Right to Access. You have a right to request that we disclose to you the specific pieces of Personal Information that we have collected about you in the prior 12-month period.

    Right to Deletion. You have a right to request that we delete Personal Information we collected from you.

    How to Exercise Your Rights of Access and Deletion. To exercise your California rights described in this section, you may submit your request to us by contacting us at [email protected].

    Who May Exercise Your Right to Know, Access and Deletion? You may make a request to exercise the above rights to know, access, and deletion on behalf of yourself or on behalf of a child if you are a parent or legal guardian of the child. In addition, you may authorize an agent to exercise these rights on your behalf, if you provide the agent with written permission and, if the agent is a business, the agent is registered with the California Secretary of State. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent both to act as your agent and to submit the request to us, unless the agent is subject to a Power of Attorney under California probate laws.

    Verification of Your Request to Know, Access and Deletion. Once we receive your request, we will contact you to confirm receipt of your request. In addition, we may contact you to provide us with additional information to allow us to verify your identity based on the Personal Information we have in our systems. To verify your request, you must provide sufficient information that allows us to reasonably verify you are the person that is the subject of the Personal Information you have requested. This information may vary depending on the Personal Information we already have. Certain types of requests may require additional verification to ensure you are who you say you are. If you have used an agent to make your request, we will also need to verify the identity of the agent. Verification of your request may require you, or your agent if applicable, to sign a declaration under penalty of perjury verifying identity. We may deny your request as permitted by law, if we are unable to verify your identity, or if an agent makes the request on your behalf, if we are unable to verify their identity or proof of their authorization.

    When We Will Respond to Your Request to Know, Access, and Deletion. We will confirm receipt of your request within 10 business days. We will try to respond to your request within 45 calendar days. If we require additional time to respond, we will inform you of the reason and may take an additional 45 calendar days to respond. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

    Shine the Light. California residents have the right to receive, once a year, information about third parties with whom we have shared their Personal Information for marketing purposes during the previous calendar year, and a description of the categories of Personal Information shared. To make such a request, please email us by using the “Contact Us” section of the Website and include the phrase “California Privacy Request” in the subject line, along with your name, address, and email address. We will respond to you within thirty days of receiving such a request.

  11. Public Forums

    Please remember that any information you may disclose in any “Subscriber Directory”, or other public areas of our Websites or the internet, becomes public information. You should exercise caution when deciding to disclose Personal Information in these public areas.

  12. Our Company’s Commitment to Data Security

    We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

    You understand that no data transmission over the internet or device can be guaranteed, and you should not expect such transmission to be 100% secure or that your Personal Information will remain secure in all circumstances. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk. We cannot guarantee that your Personal Information will not be accessed, disclosed, altered, or destroyed because of an attack to our systems or any other event beyond our reasonable control. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing, or otherwise offering any definitive promise of security in connection with your Personal Information.

  13. Where to Direct Questions about Our Privacy Policy

    If you have any questions about this Privacy Policy or the practices described herein, you may contact us at [email protected], or at +1 (303) 544-0514.

    If you feel that your complaint has not been addressed incompletely, we invite you to let us know for further investigation.

  14. Revisions to This Privacy Policy

    Our company reserves the right to revise, amend, or modify this Privacy Policy, our Terms of Use and Service, and our other policies and agreements at any time and in any manner, by updating this posting. We will provide you with notice of any material changes to these policies and terms. Your use of this Website following such notice constitutes your acknowledgment and acceptance of their changes.

Website editor: Flatirons Solutions, Inc.
Registered address: 5755 Central Avenue, Suite A, Boulder, Colorado 80301, United States, registered agent address: The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801, United States
Telephone: +1 (303) 544-0514
Email: [email protected]
Publication Director: Stéphane Labadie
Hosting: WP Engine, 504 Lavaca Street, Suite 1000, Austin, TX 78701, United States, +1-877-973-6446
Subsidiaries: Flatirons Solutions Corporation, Flatirons Solutions, Inc., FSC Colorado Holdings, Inc.

Flatirons Solutions