Information We Collect And Receive
FNE may collect and receive Customer Data, other information and data (“Other Information”) in a variety of ways. When you visit or use our Website or Services in any way, we collect and process different types of information about you:
- Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorized Users”) routinely submit Customer Data to FNE when using the Services. Such information can vary depending on your use of the Website or Services. Such information may include your customers or employees personal data such as:
- Identity Data including first name, last name, gender, birthday, username or similar identifier, and titles.
- Identificators Data including loyalty card number and national ID code.
- Contact Data including billing address, delivery address, email address, webpage, social media identificators, fax and telephone numbers. Such information can also include contact persons and representatives data.
- Professional Data including your authorization level, job title, company information, workplace, and other management and sales related data and goals.
- Financial Data including bank, bank account, additional payer person, deadlines, penalties, and credit details. Other financial information can include reward points, coupons, and gift cards.
- Transaction Data including details about payments and sales documents to and from you and other details of products and services you have purchased from us.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences with your Customers.
- Custom information which the Authorized User can add to the person via attributes, extra parameters or attached files.
- Other Information. FNE also collects, generates and/or receives Other Information:
- Log Data may include the Internet Protocol (IP) address, the date and time the Services were used, User identificator, and what processing was done. Our servers automatically collect information when you access or use our Websites or Services and record it.
- Services Metadata may include logs about features, content and links you interact with and what Third Party Services are used (if any). When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work.
- Technical Data includes internet protocol (IP) address, time zone setting and location, Services extension (“Plug-ins”) types and versions, and other technology you use to access for processing purposes of Services.
- Profile Data includes account purchases or orders made by you, your preferences, feedback, communications and survey responses, and your login username and password.
- Custom information which can vary depending on extra developed functionalities, active Plug-ins or other Customer self-made Plug-Ins and functionalities.
- Third Party Services. Customer can choose to permit or restrict Third Party Services. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Workspace. Once enabled, the provider of a Third Party Service may share certain information with FNE. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to FNE. When a Third Party Service is enabled, FNE is authorized to connect and access Other Information made available to FNE in accordance with our agreement with the Third Party Provider.
- Third Party Data. FNE may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data.
- Additional Information Provided to FNE. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with FNE.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services. Moreover, certain information provided by Customer to FNE can vary depending on the agreed-upon contractual obligations of both parties and hence this list of data being processed by FNE can differ. FNE is not obligated to know about the data which the Customer inserts into the FNE Services and Websites, and Customer is 100% owner of their data, hence Controller to their data and obligated to follow the current Data Protection Law.
Links to Other Websites
Our Websites and Services may, from time to time, contain links to third party websites. If you follow a link to any of those third party websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those practices. Please check those policies before you submit any personal data to those websites.
To the extent prohibited by applicable law, FNE does not allow the use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information. Insertion of Customer Data containing personal data of individuals younger than 16 years old into FNE is prohibited without parental or other guardians lawful permission.
How We Use The Information
Customer Data will be used by FNE in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by Data Protection Law or other applicable law. FNE is a processor of Customer Data and Customer is the controller.
FNE uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, FNE uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide additional features. FNE tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about FNE. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. FNE may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
How We Share And Disclose Information
This section describes how FNE may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and FNE does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. FNE will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users.
- Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business.
- Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, FNE may share Other Information with Third Party Services. Third Party Services are not owned or controlled by FNE and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
- Corporate Affiliates. FNE may share Other Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to FNE’s Business. If FNE engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of FNE’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of FNE or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. FNE may share Other Information with third parties when we have consent to do so.
FNE takes the security of data very seriously. FNE works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. FNE has signed confidentiality agreements with our personnel. The personnel will receive training when onboarding and as well as on an ongoing basis. FNE transfers your data over secure protocols and data is kept only on dedicated environments which FNE fully owns at our hosting partners. The environment that hosts the FNE services maintains multiple certifications, including ISO 27001 compliance. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, FNE cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.
How Long Do We Store Your Data?
We store your personal data during the time that you are a Customer of the FNE Services, and for up to ten years after you cease to be a Customer or User. If you have never been a Customer or registered User of FNE, but have consented to receive marketing inquiries or other information from FNE, we may store your data until you have opted-out from marketing subscription. We reserve the right to store or delete your personal data earlier or later than set forth herein if required to do so by applicable law or regulation, including the current Data Protection Law and for the exercise or defence of legal claims.
FNE is committed to ensuring that you have control and visibility to your personal data and its processing. Below is a summary of your rights and additional commitments from FNE. You may exercise your rights by contacting us at [email protected] FNE will only process requests from individuals directly associated with FNE Services, hence will only process requests about Personal Data for which FNE is controller party. It is your responsibility to ensure that any information you have provided to us is accurate and up-to-date.
- Right of Access.You can request a copy of the personal data we hold about you.
- Right to Erasure (‘Right to be Forgotten’). You have the right to request that your personal data be deleted in certain circumstances including:
- The personal data are no longer needed for the purpose for which they were initially collected;
- You withdraw your provided consent for processing (Only applicable for processing where consent was required);
- You object to the processing and there are no overriding legitimate grounds justifying us processing the personal data;
- The personal data have been unlawfully processed; or
- To comply with a legal obligation.
- Right to Restriction of Processing. You can ask us to restrict use of your personal data where:
- The accuracy of the personal data is contested;
- The processing is unlawful but you do not want it erased;
- We no longer need the personal data but you require it for the establishment, exercise or defence of legal claims; or
- You have objected to the processing and verification as to our overriding legitimate grounds is pending.
- We can continue to use your personal data:
- Where we have your consent to do so;
- For the establishment, exercise or defence of legal claims;
- To protect the rights of another; or
- For reasons of important public interest.
- Right to Data Portability. Where you have provided personal data to us, you have a right to receive such personal data back in a structured, commonly-used and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in each case only where:
- The processing is carried out by automated means; and
- The processing is based on your consent or on the performance of a contract with you.
- Right to Object. You have a right to object to the processing of your personal data in those cases where we are processing your personal data in reliance on our legitimate interests. In such a case we will stop processing your personal data unless we can demonstrate compelling legitimate interests which override your interests. You also have the right to object where we are processing your personal data for direct marketing purposes.
If you do not want to receive newsletters, announcements, or other communications and/or services from the FNE, please do not opt-in for those communications or services at the time of registration. FNE only exercises two types of consents which of first is required for us to provide Services to Customer and such consent can be only opted-out once legal agreement and obligations between FNE and the Customer has ended. If Customer has opted-in to direct marketing consent, the Customer is given option to discontinue receiving future communications (i.e., unsubscribe) from FNE via e-mail. Simply follow the unsubscribe process or directions provided at the bottom of the e-mail.
- Automated Decision-Making. In FNE no such functionality exists in our standard Services and we do not exercise any automated decision-making for our business or other processes. If any of our Customers exercises such decision-making to process the individual´s personal data, such individual should contact the Customer with such requests.
- Right to Complain. You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you are unhappy with how we are processing your personal data. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to dpo[email protected]
International Data Transfers Privacy Shield And Contractual Terms
FNE keeps all European Customer data in EU data centres only. FNE may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if FNE transfers Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:
- E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. To comply with European Union and Swiss data protection laws, FNE only discloses your data to partners who are certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. To learn more about the Privacy Shield Program, please see https://www.privacyshield.gov/welcome.
- European Union Model Clauses. FNE utilizes European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data to third party entities that process your data in countries that don´t have implemented same data protection standards with EEA region and hence don´t provide adequate level of protection by its local legislation.
Data Protection Officer
To communicate with our Data Protection Officer, please email [email protected]
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, FNE is the processor of Customer Data and the controller of Other Information. Different FNE entities provide the Services in different parts of the world.
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