Privacy Policy - FS Vector

Last Updated: November 22, 2024

FS Vector (“FSV,” “we,” or “us”) understands the importance of privacy and we take our responsibility to protect your privacy seriously. This Privacy Notice explains how we collect, use, disclose, and otherwise process personal data in connection with operating our business and providing services, including through our Approved platform. We may collect personal data when you access our websites, blogs, mobile sites, applications, widgets and other interactive features, when you register or attend an event organized or hosted by us, when you use or services, or when you otherwise contact us (collectively, “Services”). We may be required by law to provide specific disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.

This Privacy Notice does not address our privacy practices relating to FSV job applicants, employees and other employment-related individuals, or data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

Our Role in Processing Personal Data

For the purposes of this Privacy Notice, “personal data” is any information that relates to an identified or identifiable individual. Some privacy laws differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions. In connection with the Services, we act as a “controller” with respect to your personal data. This Privacy Notice describes our privacy practices when acting in that capacity.

Our Collection and Use of Personal Data

Information You Provide To Us

We collect personal data about you when you access, use, or receive the Services, or otherwise voluntarily submit personal data to us. This includes personal data you provide to us when you submit an enquiry through our website, interact with our websites, register for and/or attend an event, correspond with us by phone, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or provide information requested by us to comply with our legal or contractual obligations. If you choose not to provide personal data, we may not be able to provide some or all of the Services or to respond to your requests.

The categories of personal data we may receive from you directly in connection with the Services include the following.

Contact Information – including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to perform the Services, fulfill your requests or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
Business Information – including the name of your business, contact details for the relationship and billing representatives at representatives at your business, the products or services your business is interested in, purchased, or have otherwise used, and other information necessary to provide Services to your account. We use this information primarily to administer our relationship with your business, provide your business with our Services, communicate with you regarding your account, facilitate your transactions, assist your use of our Services, and for customer support purposes.
Communication Information – including any comments and opinions, files, documents, or communications you choose to provide to use in connection with the Services or on any online forms we may offer. We use this content primarily to provide you Services, to improve our Services, determine the Services that may be of interest, and address any questions or concerns.
Employment Information – including information about the business for whom you work, your business unit, you manager and the management structure, your job title, and the nature of your job duties and responsibilities.
Location Information – Other than information you choose to provide us, we do not collect information about your precise location. Your device’s IP address, however, may allow us to determine an approximate location.
Security-Related Information – including name and contact information of visitors to our premises, video recordings of videos on our premises, and electronic login records and access details when a visitor utilizes company technology on our premises. We use this information primarily to protect the security of our premises, employees, and our company.

These categories are further described in Annex 1 below, which also discusses the purposes for which we use each categories of personal data and the legal basis we rely on for our processing of that data. Note, as described below, we a may also collect personal data from you automatically, as well as from other sources and third parties.

Personal Data Automatically Collected

We, and our third-party partners, may automatically collect information from you when you access and use our Services, including our websites. We typically collect this information with our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources. The categories of personal data we receive from you using automated data collection technologies include the following:

Information About Your Access and Use of the Services – including the website from which you came to any of our websites, the website you visited after leaving our website, the frequency with which you use our Services, the time you spent accessing our Services, whether you open or click links in emails sent to you by us or on our behalf, whether you access the Services from multiple devices, and other actions you taken online with respect to the Services.
Information About Your Device – including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We may employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.

The information automatically collected through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, and to monitor and improve our Services. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:

Employers: If you interact with our Services in connection with your employment, we may obtain personal data about you from your employer or another company for which you work. For example, we may obtain your contact information from your employer to allow us to communicate with you about your employer’s customer relationship with us.
Social Media: When you interact with our Services through social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.
Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

Additional Uses of Personal Data

In addition to the purposes described above, we may also use personal data we collect to:

Fulfill our contractual obligations, ensure payment for our Services, deliver the Services, and otherwise facilitate our relationship with your business;
Manage our organization and its day-to-day operations;
Communicate with you, including via email, social media, and/or telephone calls, including to market our Services;
Create and maintain accounts for users of our Services;
Identify and analyze how you use our Services;
Improve and customize our Services to address the needs and interests of our customers;
Maintain and enhance the safety, security, and integrity of our Services and business;
Defend, protect, or enforce our rights or applicable contracts and agreements, as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of FSV and others;
Comply with contractual and legal obligations and requirements;
Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

Our Disclosure of Personal Data

As necessary to support our uses of your personal data described above, we may share your personal data with the following groups or in the following circumstances:

Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.
Affiliates. FSV’s parent company and other affiliates with common ownership, so that they can provide you with legal updates, information and marketing messages about products or services that may interest you.
Social Media Networks. If you interact with us through social media, the content that you share through social media may be shared with your social media account provider and your friends, followers or contacts on the connected social network.
Law enforcement, regulators and other parties, for purposes required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) enforce the terms of our agreement, and pursue available remedies or limit the damages that we might sustain; (e) protect the security or integrity of our Services or business; and/or (f) exercise or protect our rights, privacy, safety or that of our affiliates, clients, you or others
Your Employer: If you interact with our Services in connection with your employment, we may disclose personal data to your employer or another company for which you work. For example, we may provide information to your employer about your usage of our services in connection with your work for them.
Marketing Providers: We coordinate and share personal data with our marketing providers in order to advertise and communicate with you about the products and services we make available.
In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.]
With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.

Your Privacy Choices

The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal data depending on your location or residency. Please refer to our Region-Specific Disclosures below for information about additional privacy choices that may be available to you.

Marketing Communication Preferences

We may send you updates, newsletters, emails, and mailings, or contact you via phone, in connection with Services, events, or opportunities we think may be of interest to you. Typically, we will do so by email. For some communications, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of Service-related email communications (such as, account verification, transaction confirmation, or service update emails).
Phone Communication Preferences: You can stop receiving promotional phone communications from us by informing the caller you no longer wish to receive promotional phone calls from us. Please note we may need to continue to communicate with you via phone for certain Service-related messages.

If you are in the EEA, we will only send you marketing messages if you have given us your consent to do so. If you do not want to receive messages from us, you will be able to inform us of your wishes when we first collect your contact details or by refusing or withdrawing your consent. You can also change your preferences at a later date by clicking on the unsubscribe link at the bottom of our messages or by emailing us at privacy@fsvector.com.

Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications necessary for us to provide the Services.

Withdrawing Your Consent

Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.

Automatic Data Collection Preferences

You may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:

Google Analytics: Google Analytics allows us to better understand how our customers interact with our services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/.
Interest Based Advertising: We permit certain third-party services to collect information about your use of website so that they may display personalized or interest-based ads to you on other websites, services, or devices you may use. Frequently, the information used for interest-based advertising is collected through cookies or similar data collection technologies, which we described above. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions:

In the United States, please visit: https://youradchoices.com/, or https://optout.networkadvertising.org/
- In the EEA, please visit: http://www.youronlinechoices.com/
- In Canada, please visit: https://youradchoices.ca/

When you elect to opt-out through these sites, they will place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again. And some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again. If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at https://youradchoices.com/appchoices.

Please note that when you opt-out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-party opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Children’s Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 16. If an individual is under the age of 16, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 16, we will promptly delete that personal data.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. Despite these controls, however, we cannot completely ensure or warrant the security of your personal data.

Retention of Personal Data

We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. If necessary, however, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.

Third-Party Websites and Services

Our website may include links to third-party websites or applications. If you follow such a link, please note that these websites and applications have their own privacy notices and that we do not accept any responsibility or liability for those notices. This Privacy Notice does not apply to any personal data practices of third parties

Region-Specific Disclosures

We may be required to provide additional disclosures relating to our processing of personal data pursuant to the data protection laws in the country, region, or states where you are located. Please refer below for disclosures that may be applicable to you.

European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please click here for additional privacy disclosures, including a description of the personal data rights made available to individuals located in those jurisdictions under applicable law.]
California: If you are a resident of the California, please click here for additional privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time and so you should review this page periodically. When we change this Privacy Notice in a material way, we will update the “Last Updated” date at the top of this Privacy Notice. Changes to this Privacy Notice are effective when they are posted on this page.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@fsvector.com or call us at toll-free phone number (844) 381-1666.

FS Vector
Attn: Privacy
1307 New York Aenue NW
Washington, DC 20005

ANNEX 1 – PERSONAL INFORMATION WE COLLECT THROUGH THE SERVICES

Category of personal information	How we use it (purpose of use)	Legal basis for the processing
Contact information. Personal information, such as your name, phone number, address, email address.	We use this information to deal with enquiries and complaints made by or about you relating to the Services.	The processing is necessary for our legitimate interests, namely administering the Services and dealing with enquiries and complaints relating to the Public Services.
	We use this information to operate, maintain and provide to you the Services.	The processing is necessary to perform our contract with your business and for our legitimate interests, namely administering the Services and dealing with enquiries and complaints relating to the Services.
	We use this information to communicate with you, including sending service-related communications.	The processing is necessary for our legitimate interests, namely administering the Services and communicating with you in connection with the Services.
	We use this information to send you statements and invoices in relation to any agreement between us to provide you with any part of the Services.	The processing is necessary for the performance of a contract and/or to take steps at your request prior to entering into a contract.
	We use this information to send you news, alerts and marketing communications in accordance with your preferences.	If you are in the EEA, or if the relevant data controller using your personal information for this purpose is in the EEA, we will only process your personal information in this way to the extent that you have given us consent to do so.
		If neither you nor the data controller are in the EEA, the processing is necessary for our legitimate interests, namely for marketing purposes.
Employment information. Such as information about your employing entity, business unit, manager and management reporting structure, job title, function and the nature of your duties and responsibilities.	We use this information to tailor content provided to you through our Services, including notifications, news, alerts and marketing communications.	The processing is necessary for our legitimate interests, namely to tailor our service to the user.
	We use this information to monitor and improve the Services.	The processing is necessary for our legitimate interests, namely to improve our Services.
Communication information. When you contact us directly, e.g. by email, phone, mail, when you post on message boards, blogs or complete an online form, we will record your comments and opinions.	We use this information to address your questions, issues and concerns.	The processing is necessary for our legitimate interests, namely administering the Service and dealing with enquiries and complaints relating to the Services.
	We use this information to improve our Services.	The processing is necessary for our legitimate interests, namely to inform the development of new features of the Services and the improvement of the Services generally.
	We use this information to determine products and services that may be of interest to you.	The processing is necessary for our legitimate interests, namely to inform our direct marketing.
Location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location.	We may use an approximate location to ensure content made available to you through our Services is relevant to the city or country you are using your device in.	The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.
Information provided by social networks you connect to the Public Service. If you connect a social network, such as LinkedIn or Facebook, to our Public Services we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, Facebook ID, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you have agreed it can share or that the social network provides to us.	We will use the personal information provided to allow you to assist you in sharing content from our Services, or your experiences on our Services, with your friends, followers or contacts on the connected social network.	The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.
Preferences. Preferences set for notifications, marketing communications and how our websites are displayed.	We use this information to provide notifications, send news, alerts and marketing communications and provide our Services in accordance with your choices.	The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications.
	We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.	The processing is necessary for compliance with a legal obligation to which we are subject.
Information provided by third parties. From time to time, we may receive information about you from third parties and other users. We may obtain information from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available.	We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials or to personalize the Services, to pre-populate forms, and to better understand the demographics of our users.	The processing is necessary for our legitimate interests, namely to tailor our service to the user and to improve our service generally.
All personal information set out above.	We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Services, to communicate with you, to monitor and improve the Services and business, and to help us develop new products and services.	The processing is necessary for our legitimate interest, namely to administer and improve the Services.

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information	How we use it (purpose of use)	Legal basis for the processing
Information about how you access and use the Services. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access our website and Services, the time you access our website and Services and how long you use them for, whether you open emails or click the links contained in emails, whether you access the websites or Services from multiple devices, and other actions you take on the websites and Services.	We use this information to present our websites to you on your device.	The processing is necessary for our legitimate interests, namely to tailor our websites and Services to the user.
	We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes.	The processing is necessary for our legitimate interests, namely to inform our direct marketing.
	We use this information to monitor and improve our websites and Services and business, and to help us develop new products and services.	The processing is necessary for our legitimate interests, namely to improve our websites and Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.
Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our websites and Services. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our websites or Services through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).	We use this information to present our Service to you on your device.	The processing is necessary for our legitimate interests, namely to tailor our websites and Services to the user.
	We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes.	The processing is necessary for our legitimate interests, namely to inform our direct marketing.
	We use this information to monitor and improve our websites and Services and business, and to help us develop new products and services.	The processing is necessary for our legitimate interests, namely to improve our websites and Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.

ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

Scope of Notice

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you“).

This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (together, the “CCPA”). This CA Notices is limited to our activities when we are acting as a “business,” as defined by the CCPA. Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

For the purposes of this CA Notice, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, consumer or household. Personal information does not include:

Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.
Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Information relating to our job applicants, employees, contractors and other FSV personnel.

Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the section in the Privacy Notice titled “Our Collection and Use of Personal Data,” as well as Annexes I and 2 to that Notice.

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your name, address, phone number, email address, or other similar identifiers.
Commercial Information, such as your use of our Services.
Protected Classification Characteristics, such as age, gender, religion, and disability information.
Internet/Network Information, such as your IP address, or browser or device information.
Geolocation Data, such as information about your approximate physical location collected from geolocation features on your device, including your IP address.
Sensory Information, such voicemails or similar audio recordings.
Biometric Information, such as fingerprint scans.
Professional/Employment Information, such as your employing entity, business unit, manager and management reporting structure, job title, function and the nature or your duties and responsibilities.
Other Personal Information, such as information you provide to us when you register for or attend an event organized or hosted by us, information you permit us to see when interacting with us through social media, or comments and opinions you provide to us such as when you post on message boards, blogs or complete an online form, and any health screening information you provide to us.

Sources of Collecting Personal Information

We collect this information from a variety of sources including, but not limited to:

Directly from you;
From your browser or device;
From information generated from your online browsing and usage activity;
Service providers;
Business partners and affiliates; and
Third parties you direct to share information with us.

Purposes for Collecting Personal Information

The business and commercial purposes for which we collect your personal information are described in the sections of the Privacy Notice titled “Our Collection and Use of Personal Data” and “Additional Uses of Your Personal Data,” as well as Annexes I and 2 to that Notice. For the purposes of the CCPA, we may collect, use or disclose personal information about you for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry.
To deal with enquiries and complaints made by or about you relating to our Services.
To communicate with you, including through email to provide you updates, alerts, news and mailings relating to Services we think may be of interest to you.
To operate, maintain, and provide to you the features and functionality of our Services.
To market to you, including through email.
To send you statements and invoices in relation to any agreement between your company and us to provide any of the Services.
To better understand the demographics of our users.
To personalize your experience and to deliver custom content and product and service offerings relevant to your interests.
To recognize you and remember your information when you return to our websites and Services.
To help maintain the safety, security, and integrity of our services, technology assets, and business.
To protect the health and safety of our personnel and visitors to our premises.
For testing, research, analysis, and to develop and improve our Services.
To assist you in sharing content from our services, or your experiences on our services, with your friends, followers or contacts on a social network.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Disclosure of Personal Information

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the Collection and Use of Personal Information section of this CA Notice, to third parties for a business purpose.

The categories of third parties to whom we disclose your personal information for a business purpose are described in the Our Disclosure of Personal Data section of our Privacy Notice.

Selling or Sharing for Targeted Advertising

In the prior 12 months, we have not (1) “sold” personal information to third parties for monetary or other valuable consideration or (2) “shared” personal information with third parties for the purposes of cross-contextual behavioral advertising. Likewise, FSV does not have actual knowledge that it “sells” or “shares” the personal information of consumers under 16 years of age.

Your Privacy Choices

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The Right to Know. The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you in the last 12 months, including:
- The categories of personal information collected;
- The categories of sources of the personal information;
- The business and commercial purposes for which the personal information were collected;
- The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
- The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
- The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
The Right to Access and Portability. The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.

Consumers in California also have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). California consumers also have the right to limit the use or disclosure of sensitive personal information by the business if such information is used or disclosed for certain purposes, as required by the CCPA. Because FSV does not engage in any of the foregoing activities, these rights are not available.

How to Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request by:

Filling out our emailing us at privacy@fsvector.com with the subject line “Data Subjects Rights Request,” or
Calling (844) 381-1666.

Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request to know twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. Specifically, for requests to know, delete, or correct personal information, we require the following for verification purposes:

a power of attorney valid under the laws of California from you or your authorized agent; or
sufficient evidence to show that you have:
1. provided the authorized agent signed permission to act on your behalf; and
2. verified your own identity directly with us pursuant to the instructions set forth in this U.S. Notice; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:

Denying you goods or services.
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Data Disclosures for Direct Marketing Purposes

California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Updates to This CA Notice

We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to privacy@fsvector.com.

ADDITIONAL EUROPEAN ECONOMIC AREA, UNITED KINGDOM, AND SWITZERLAND PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individuals who access our services or otherwise interact with us from the European Economic Area (“EEA”), United Kingdom (“UK“), and Switzerland. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Notice. As stated explained in the section of our Privacy Notice titled “Our Role in Processing Personal Data,” FSV is the “controller” with respect to personal data processed regarding individuals located in the EEA, UK, or Switzerland. You may contact FSV by emailing us at privacy@fsvector.com.

Additional Questions or Complaints

If you have a concern about our processing of personal data, you have the right to lodge a complaint with the Data Protection Authority where you reside, where you work, or where an alleged violation of the law has occurred. Contact details for applicable Data Protection Authorities can be found using the links below:

European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en
United Kingdom: https://ico.org.uk/global/contact-us/
Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

We would, however, appreciate the chance to handle your concerns directly prior to a complaint being filed, so please contact us directly at privacy@fsvector.com if you have any concerns.

Purposes and Legal Bases of Processing

The types of personal data we process, the purposes of that processing, and the lawful basis for our processing of that personal data are described in Annexes 1 and 2 to the Privacy Notice.

You are not required to provide personal data to us, but we do rely on your personal data to provide our Services. For example, we need your personal data to facilitate our transactions with your business. If you choose not to provide us with your personal data, we may not be able to provide you with the Services requested.

Automated Decision-Making and Profiling

We do not conduct automated processing of personal data, including profiling, for the purposes of making decisions about you.

Retention of Personal Data

The duration for which we retain personal data is described in the section of the Privacy Notice titled “Retention of Personal Data.”

The criteria used to determine the period of time for which personal data about you will be retained varies depending on the legal basis under which we process your personal data:

Contract: Where we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Legitimate Interest: Where we are processing personal data based on legitimate interests, we generally will retain the information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.
Legal Obligation: Where we are processing personal data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfill the legal obligation plus some additional limited period of time that represents the statute of limitations for legal claims that could arise from the legal obligation.
Consent: Where we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to fulfill the purposes for which you have provided your consent.

In certain circumstances, we may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved. In all cases, in addition to the purposes and legal bases identified above, we consider the amount, nature and sensitivity of personal data, as well as the potential risk of harm from unauthorized use or disclosure of personal data, in determining the relevant retention period.

International Transfers of Personal Data

We may transfer personal data about you outside of the EEA, UK, and Switzerland, including to the United States. The country to which personal data is transferred may not provide the same level of protection for personal data as the country from which it was transferred. When we transfer personal information from the EEA, UK, or Switzerland, we rely on appropriate or suitable safeguards recognized under applicable law, including standard contractual clauses that have been approved by the European Commission, UK’s Information Commissioners Office, or other appropriate data protection regulators.

Your Additional EEA, UK, and Swiss Privacy Choices

Subject to certain limitations at law, you may be able to exercise the following rights:

Right to Access: The right to obtain confirmation of whether we are processing personal data about you, access to and a copy of the personal data we are processing about you, and information relating to its processing, including:
- The categories of personal data being processed;
- The purposes of the processing;
- The categories of the sources of the personal data;
- The categories of recipients to whom the personal data have been or will be disclosed;
- The envisaged period for which the personal data will be stored, or the criteria used to determine that period;
- Any automated decision-making or profiling performed in connection with your personal data; and
- The safeguards relied upon for the transfer of personal data to any third country.
Right of Portability: The right to obtain a copy of the personal data we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal data to another controller without hindrance.
Right to Rectification: The right to correct or update any personal data about you that is inaccurate or incomplete.
Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right to Object to Processing: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal data. Please note withdrawing your consent will not affect the lawfulness of our use of your personal data before your consent was withdrawn, nor our processing of personal data pursuant to a different lawful basis for processing.
Right to Erasure: The right to have us erase your personal data if the continued processing of that personal data is not otherwise justified.

If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death. Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our services to you, or otherwise engage with you in the same manner.

Submitting Privacy Rights Requests

If you wish to exercise one of these rights, please contact us at privacy@fsvector.com. Before processing your request to exercise certain rights (taking into account the confidential nature of any personal data we maintain), we will need to verify your identity and confirm you are accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland. In order to verify your identity, we will generally either require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal data or locate your information in our systems, or where you are not accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland.