Existing clients, prospective clients, and their agents or other authorized representatives (collectively, "Clients"), who have submitted consultation requests or other related information to us by any means, including electronically or in person, in connection with our business ("Business");
Contractors, vendors, and other service providers (collectively, "Service Providers"); and
Visitors of our Website (collectively, "Site Visitors").
2.4 Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 11 (Your Choices Regarding Your Personal Information; Opting Out).
3. The Information We Collect.
The information that we collect about you falls into certain categories as further described in this Section 3 (The Information We Collect). This information consists of the following:
3.1 Personal Information. We may collect certain information that identifies you as an individual (collectively, "Personal Information"). The Personal Information we collect may include the following:
Your name and email address;
Your other contact information, including a mailing address and phone number; and
3.2 Online Activity Information. We may also collect technical and device-related information through our Platform (collectively, "Online Activity Information"). Online Activity Information is typically collected automatically by technical means and, subject to Section 3.4 (Treatment of Combined Information), for purposes of our Platform, may consist of the following:
Device identifiers, such as cookies;
Device information, such as hardware and software settings;
IP addresses and log information, such as your device's name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
Tracking information that we, or a third party, may collect.
To the extent that statutes, regulations, and any other laws that apply to the Services (collectively, "ApplicableLaw") establish that Online Activity Information constitutes Personal Information, and such Applicable Law applies to information we collect from you, then we will treat the relevant Online Activity Information as Personal Information. In addition, sometimes Online Activity Information can be associated with your Personal Information, in which case we will treat it as Personal Information (as described in Section 3.4 (Treatment of Combined Information)). Otherwise we consider, and treat, Online Activity Information as Anonymous Information.
3.4 Treatment of Combined Information. To enable us to better understand the characteristics of our users and/or to conduct the Business, we may link your Personal Information with Online Activity Information associated with you or other Anonymous Information. If we combine or associate Online Activity Information or other Anonymous Information with your Personal Information, then we will treat the resulting combination as Personal Information.
4. How We Collect this Information.
We collect the above information through the following means and technologies:
4.1 Contacting Us. You can contact us with questions or comments. In order to communicate with us, you must provide certain Personal Information. By communicating with us for these purposes, you may provide us with your email address and other Personal Information. In these instances, we use any information you provide to us for the purposes for which you submit the information.
4.2 Questionnaires and Surveys. We may allow you to participate in surveys and questionnaires, which we may post on the Website or otherwise provide to you from time to time. You are free to choose whether you participate in a survey or questionnaire. We may ask that, in addition to providing your responses, you also provide Personal Information. In these instances, we use any information that you provide to us for the purposes for which you submit the information. Survey and questionnaire information may be used for the purposes of monitoring or improving our Business. As further set out in Section 11(Your Choices Regarding Your Personal Information; Opting Out), please understand that you will not be allowed to "opt out" of formal notices related to our Business, such as the operation of the Website, and legal, and other related notices concerning your relationship with us.
4.3 Job Applications and Inquiries. You may submit to us Personal Information in connection with job applications and if you have questions for us. In each case, we collect the information you submit to us for various purposes, including to respond to your inquiries or to consider your candidacy for our employment opportunities.
4.4 Newsletters. We may offer newsletters and other content that we believe may be of interest to you. We will use your Personal Information to provide you with this content. You can opt-out of receiving this content by following the instructions set out in Section 11 (Your Choices Regarding Your Personal Information; Opting Out).
4.5 Submitted Content. As further set out below, we may provide you with the ability to submit content to us for our internal use or to submit content to us for public consumption (collectively, "Submitted Content"). If you include any Personal Information relating to others in your Submitted Content, then you represent that you have full permission and authority to do so.
4.5.2 Submitted Content Provided to Us for Public Consumption. We may give you the ability through our Website or a third party social media platform, to engage with us and others in public exchanges by providing Submitted Content. For example, we believe that your experiences with us can often act as the strongest promotion for our Services. To promote and illustrate our Services, we may wish to incorporate in our success stories or otherwise post on our Website or elsewhere, your endorsements or your other descriptions of experiences with us, as well as comments, feedback, and other information that you wish to share. Please understand that, if you include Personal Information in such Submitted Content, others will be able to read, collect, re-publish, and otherwise freely use such Personal Information. We are not responsible for Personal Information that you decide to include in such Submitted Content, and we will not take down, remove, or edit Submitted Content, except as required by applicable law.
4.6 Cookies.A cookie is a small amount of data that is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may choose not to accept cookies; however, you may need to enable cookies if you wish to access certain personalized features of our Website.
4.7 IP Addresses; Logs. We may automatically receive and record information in our server logs from your browser or mobile device, including your IP address (the Internet address of your computer), your computer's name, the type and version of your web browser or mobile device operating system, referrer addresses, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes.
4.8 Tags. We may use so-called "pixel tags" – small graphic images (also known as "web beacons" or "single-pixel gifs") – to tell us what parts of our Website have been visited or to measure the effectiveness of searches you perform on our Website. Pixel tags also enable us to send email messages in a format that you can read and they inform us whether emails have been opened. Pixel tags also help us ensure that our messages are of interest to you.
4.9 Click-Throughs. We may send email messages, which use a "click-through URL" linked to content related to our Business. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We may track this click-through data to help determine interest in particular topics and to measure the effectiveness of our customer communications.
4.10 Configuration. In order to determine whether your computer or mobile device is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, the presence of any software that our Website may require to operate with your computer or mobile device, or other third party software on your computer or mobile device.
4.12 Information Provided to Third Parties. As explained further in Section 7.1 (Our Service Providers), we may engage third parties to perform certain services for us or on our behalf. The forms on our Website may be managed by such third parties, and we may obtain from the applicable service provider the information that you provide using such forms.
5. How We Use The Information We Collect.
To provide you with the Services you request and to communicate with you regarding our Services;
To use, and to allow you to provide us with, Submitted Content for purposes set out in Section 4.5 (Submitted Content);
To respond to your inquiries;
To customize and enhance your use of our Platform, such as by personalizing your experience with use
To provide communications that might interest you, including marketing messages and to inform you of services that we think would be appealing to you, whether the services are provided by us or by others, and whether the services are available via Faber or a third party;
To perform analytics, quality control, market research, and to determine the effectiveness of our Services and promotional campaigns, to improve our Platform, and to develop new services;
To perform internal administration, auditing, operation, and troubleshooting; and
6. Other Essential or Internal Uses of Information.
We may also use the information that we collect as we believe to be necessary or appropriate for certain essential purposes, including:
To comply with applicable law and legal process;
To respond to requests from public and government authorities, including public and government authorities;
To detect, prevent, or investigate potential security incidents or fraud;
To facilitate the functionality of our Platform;
To enforce our terms and conditions;
To protect our operations or those of our affiliates;
To protect our rights, privacy, safety or property, security and/or that of our affiliates, you or others; and
To allow us to pursue available remedies or limit the damages that we may sustain.
7. How We Disclose this Information.
We value your privacy, and we share the information we collect only in the manner set out below.
7.1 Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Platform, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personal Information, Online Activity Information, and Anonymous Information (as applicable). The following are examples:
Our Platform may include links to third party websites offering services that augment those Services offered on our Platform.
We may use service providers to: (i) provide customer service (where applicable); (ii) process and distribute email and newsletters; (iii) manage marketing and similar activities; (iv) provide you with access to various forms and platforms on which to perform activities, including registering for webinars and other events that we may provide or make available; and (v) assist in organizing and hosting events and programs. These service providers generally require access to your Personal Information in order to perform these services.
We may use analytics service providers to assist us in understanding and using Online Activity Information and other information that we collect via the Platform.
We may use service providers to anonymize and aggregate Personal Information in order to generate Anonymous Information.
We require our service providers to contractually commit to protect the privacy and security of the Personal Information they process on our behalf.
7.2 Questions of Harm; Legal Process. We may disclose your Personal Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigators, where it is necessary, or where we have a good faith belief that it is necessary to: (i) comply with legal process; (ii) protect and defend our rights and property, including the Platform, Services, and associated content; (iii) protect against misuse or unauthorized use of our Platform, Services, and associated content; (iv) protect the personal safety or property of Platform users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and (v) cooperate with public and government authorities including, where required, authorities outside your jurisdiction.
While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, then we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.
8. How We Safeguard the Information We Collect.
We recognize the sensitivity of our users' Personal Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law.
9. Our Retention of Data.
We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
10. Accuracy and Minimization of Data.
We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.
11. Your Choices Regarding Your Personal Information; Opting Out.
11.1 Discretionary Account Information. To allow appropriate control over Personal Information, you can view, change, or update discretionary information that you have previously submitted either by contacting us as provided in Section 17 (Contact Us) below.
11.2 Opt-Out of Marketing Communications. If we choose to send to you, or you have elected to receive, bulletins, updates, or other marketing-related materials, we will provide you with the ability to decline – or "opt out" – of receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. For example, if you no longer wish to receive email messages from us, you can opt out of this Service by either: (i) following the "unsubscribe" instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 17 (Contact Us) below. Please understand that we may still communicate with you in connection with administrative notices concerning any transactions, operation of the Platform and legal notices.
11.3 State-Specific Notices Regarding Your Privacy Rights.
11.3.1 California Shine the Light Disclosure. California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for their own direct marketing purposes. The California "Shine the Light" law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their own direct marketing purposes.
11.3.3 Nevada Disclosure. For Nevada residents, please note that we do not sell personal information as defined by Nevada law. You can submit a request to us as set out in in Section 17 (Contact Us) below.
12. Advisory Regarding Participation by Children and Teens.
Under U.S. Federal Law (as reflected in the Children's Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONAL INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.
14. Third Party Sites.
If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 17 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state's consumer protection authority.
17. Contact Us.
If you would like to contact us, please call us at 1-781-795-4700 during our business hours or via email at [email protected].
18. Effective Date.