Effective Date: 28 December 2020
Please read this Policy carefully. By accessing or using this Website or otherwise providing us with Personal Information, you acknowledge our privacy practices as outlined in this Policy. If you do not want to acknowledge with our privacy practices contained in this Policy, do not use the Website or provide any Personal Information to us.
If you are a California resident, additional information applicable to California residents is below in the Section titled, “Your California Privacy Rights.”
I. Information We Collect
The Personal Information we may request from you includes:
• Your name;
• Email address;
• Phone number;
• Employer / company;
• Information relating to your educational and professional experience, CV, and references;
• Recruiting information required by applicable law;
• Internet Protocol address; and
• Physical Address.
When you browse our Website, we also automatically collect and aggregate other information about you using cookies, tracking pixels and related tracking technologies. These tracking technologies may be implemented and placed by us or by third party vendors on our behalf. For example, information about how many web pages have you used, what hyperlinks you clicked, access times and number of visits may be collected. 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.
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.
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 http://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.
III. The purposes for which we process your Personal Information
We collect your Personal Information for the following purposes:
• operate and improve our services;
• understand you and your preferences to enhance your experience and enjoyment using our services;
• respond to your comments and questions and provide customer service;
• provide and deliver products and services you request;
• to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• communicate with you about products and services offered by Flatirons Solutions;
• after your submission of information to Flatirons Solutions 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; and
• enable us to comply with regulatory requirements.
IV. Customer Contact
We will not sell your Personal Information to anyone. 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.
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 Solutions; or (3) to enforce a license and services agreement; or (4) with trusted third party business partners, suppliers or sub-contractors; (5) in the event of sale, merger, joint venture, merger, reorganization, or (6) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
VII. 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.
VIII. 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 Policy. We encourage you to review those policies and terms.
IX. Users in the European Union
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@example.com 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 firstname.lastname@example.org.
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@example.com
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 firstname.lastname@example.org, 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.
X. 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 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:
• 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
Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section III of this 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 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:
• 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@example.com.
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 particular 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. In order 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.
XI. 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.
XII. 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 to be 100% secure. 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.
If you feel that your complaint has not been addressed incompletely, we invite you to let us know for further investigation.
XIV. Revisions to This Policy
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
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.