Effective Date: July 20, 2018
I. Notice of Compliance to California Residents: Your California Privacy Rights Under the California Online Privacy Protection Act and the California Business and Professions Code
We do not maintain a process for individual Visitors or Subscribers to review and request changes to any of his or her Personal Information.
Under California Law SB 27, 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, the domain name of the website you are inquiring about, along with your name, address, and email address. We will respond to you within thirty days of receiving such a request.
II. Information We Collect
We obtain Personal Information which you disclose to us via the Website. The Personal Information we may request from you includes:
* Your name;
* Email address;
* Phone number;
* 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.
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.
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 www.aboutcookies.org to learn 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.
Because we automatically place and process cookies and other tracking technologies, we currently do not honor “Do Not Track” requests.
IV. The purposes for which we process your Personal Data
We collect and process your Personal Data 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.
V. 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 subsidiaries.
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; or (5) in the event of sale, merger, joint venture, merger, reorganization.
VII. Non-US Users As described in our Privacy Shield certification, we comply with 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, respectively. Flatirons Solutions, including Flatirons Solutions, Inc. and its wholly-owned US subsidiaries listed at the end of this policy, has certified that it adheres to the Privacy Shield Principles. Flatirons Solutions remains responsible for any of your personal information that is shared under the Onward Transfer Principle with third parties for external processing on our behalf, as described in the “Disclosure” section. To learn more about the Privacy Shield program, and to view Flatirons Solutions’ certification, please visit the Privacy Shield website.
VIII. Your Rights
Data Protection Law in certain jurisdictions gives rights to an individual in respect of Personal Information that organizations hold about them. Where the local laws permit, you may:
* request the copy of Personal Information which we hold about you;
* request that we correct, update, delete or block your Personal Information in our records; and
* object at any time to the processing of your Personal Information for direct marketing activities. by email to firstname.lastname@example.org
or in writing to 5755 Central Avenue, Boulder, Colorado, 80301, United States
IX. 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.
X. Our Company’s Commitment to Data Security
We have implemented technical measures intended to protect against the risks of unauthorized access to, erroneous disclosure of, and unlawful interception of Personal Information submitted via the Services. However, your email transmissions and/or other communications containing Personal Information may be unlawfully intercepted or accessed by third parties and/or the Website may be subject to hostile network attacks. We cannot and do not guarantee the security of any information transmitted over the
Internet. Once we receive your Personal Information, we take steps that we believe are adequate to limit access to your Personal Information to only those employees and service providers whom we determine need access to the Personal Information to provide the requested products, services, offers or opportunities that may be of interest to you. However, even after we receive your Personal Information, we cannot guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed as a result of an attack to our systems or as a result of any other force majeure event beyond our control. Accordingly, we cannot and do not guarantee that your Personal Information is completely secure and safe from such risks. For the avoidance of doubt, we expressly and to the strict extent permitted by law, 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 or Usage Information.
XII. Revisions to This Policy
XIV. Dispute Resolution
If you have an inquiry regarding our privacy practices in relation to our Privacy Shield certification, we encourage you to contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Policy.
Flatirons is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please 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. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
Website editor: Flatirons Solutions Inc.
Registered address: 5755 Central Avenue, 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.