Last updated: 09/08/2023
What information does FTFC collect, and how is it used and shared?
We explain here what categories of personal information we collect, where we get it from, and with whom we share it:
1. Contact information:
such as name, address, email address, and phone number.
Source: Users of our Services.
Purpose for Collection: To allow our users to access various aspects of our Services, to communicate with and respond to our users about our Services, or to meet legal obligations, and provide you with the products, promotions, services, newsletters, and information you request.
Categories of Recipients: We may share this information with our affiliates, select marketing or other service providers and partners that perform services for us (such as for hosting the Services, or providing other customer service functions).
2. Browsing information:
such as your IP address, MAC address or other device identifier, your device type or mobile carrier, standard server log information, the kind of browser or computer you use, pages and content that you visit on our Services, what you click on, the state and country from which you access the Services, date and time of your visit, and web pages you linked to our Services from.
Purpose of Collection: To evaluate usage of the Services and improve performance; to protect the security and integrity of the Services and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations.
Categories of Recipients: Our service providers who help us with fraud protection and service analytics.
3. Recruitment and job application information:
such as name, address, and phone number, or information on a resume or a curriculum vitae.
Purpose of Collection: Visitors of our Services or job applicants.
Source: To consider you for an employment position or to respond to an employment inquiry.
Categories of Recipients: Our service providers who help us with employee matters or job fulfilment.
In connection with business transfers: In the event that a division, a service, or all of FTFC is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To comply with laws: FTFC may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose personal information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, our clients’ customers or employees or others, in accordance with or as authorised by law.
What are cookies and how do we use them and other technology?
The Services use certain technologies such as cookies, beacons, tags and scripts. A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. FTFC does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.
FTFC may use Google Analytics or other analytics providers to evaluate use of the Services for our internal purposes such as evaluating usages of the Services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at google.com/policies/privacy/partners.
Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognisable DNT signals, and therefore FTFC and the Services do not recognise DNT.
How does FTFC protect personal information?
Where applicable, FTFC uses reasonable and appropriate technology in connection with the Services to help protect personal information from loss, misuse and unauthorised access, disclosure, alteration and destruction. However, you should know that no website operator, including FTFC, can fully eliminate security risks associated with personal information. While FTFC has endeavoured to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the Services or via e-mail cannot be guaranteed.
How long does FTFC retain my personal information?
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise authorised or required by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or de-identified.
What are my choices concerning my personal information?
FTFC may, subject to applicable laws, use personal information from users of our Services to contact them about our Services, including to provide them with information on additional products or services from FTFC that may be of interest to them. You may exercise choices regarding these communications as follows:
Mail marketing, telephone marketing, surveys, and quality control communications: You may decide that you prefer FTFC not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting us using the information detailed in the Contact Us section below.
Emails/commercial electronic communications: You can always limit the communications that FTFC sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.
What is FTFC’s policy on children’ privacy?
Under Age 13
Our Services are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If FTFC learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13 without verifiable parental consent, please contact us using the information detailed in the Contact Us section below.
Under Age 18
Minors under 18 years of age may have the personal information that they have provided to FTFC through the Services deleted by sending an email to the email address in the Contact Us section below requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.
Access, objection, deletion, and correction
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion.
Cross-border transfer of personal information
In some cases, personal information that we process of users located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Services may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand and expressly agree that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.
Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in the United States. For information on how you can file a privacy complaint with the Federal Trade Commission, please visit: ftccomplaintassistant.gov.
This policy is effective August 9, 2023.
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