Last Updated: September 27, 2011
The Information That We Collect
Personally Identifiable Information. You do not have to provide us with your PII to use this Site. However, certain services to which you may subscribe through this Site (e.g.,FGIS event announcements) may require you to provide PII. We collect PII from you only when you voluntarily provide it to us. Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site. Aggregated Personal Information does not personally identify you or any other user of the Site, (for example, we may use aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code.
IP Addresses. When you visit and interact with the Site, FGIS and third parties with whom FGIS has contracted to provide services to FGIS may collect Internet Protocol ("IP") addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. This number is identified and logged automatically whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
How We Use the Information We Collect
- Personally Identifiable Information. FGIS may use PII in the following ways:
Fulfillment of Requests. We process PII to comply with your requests, respond to your inquiries, and send you newsletters or publications that you request, to provide services, including the provision of seminars and other events, or to register you for events. If you contact us by email through the Site, we may keep a record of your contact information and correspondence, and use it to respond to you. We will further use PII to fulfill any other purposes for which it was provided, and as disclosed at the time the data are collected.
Administrative Communications. We may send you important administrative or transactional information regarding the Site. Because this information may be important to you, you may not opt out of receiving these communications.
Other Communications. We may use PII about you to send you FGIS mailings relating to FGIS that we think may be of interest to you, in accordance with applicable law. If you decide at any time that you no longer wish to receive mailings from us, please refer to the paragraph below, headed Opting Out. Please note that some of these mailings may be provided by FGIS affiliates. If you are a Californian user of the Site, and would like more information regarding FGIS provision of your PII to these other legal entities of FGIS, please refer to the paragraph below headed Special Notification for FGIS California Users."
Internal Business Purposes. We may also use PII about you for FGIS internal business purposes, such as data analysis, audits, and other similar purposes.
Site Usage Data. Because Site Usage Data does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Site Usage Data, which does not personally identify you, with third parties, for any purpose. As an example, we may use aggregated Site Usage Data to help us improve FGIS Site and the services that we provide through FGIS Site. Please note that to the extent any Site Usage Data is linked with PII, such linked information will be treated as PII as long as it is linked.
How Is Personally Identifiable Information Disclosed?
Disclosures to Affiliates. As mentioned above, we may share PII provided to us with FGIS affiliates, consistent with FGIS goal of providing the highest level of global service. Subject to local requirements, this information may be used to provide services offered by FGIS affiliates and for all the purposes outlined in this policy. FGIS remains responsible for jointly used PII.
Emails to Friends. Subject to local requirements, we may provide functionality to permit you to send messages regarding Site-related content to a friend through the Site. If you wish to use this feature, you may be required to provide us with, and we may use, your friend's email address so that we can facilitate your sending of such message to your friend. By using this functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address. Please note that any PII you provide in connection with sending messages regarding Site related content to anyone through the Site, such as your name and your email address, will, of course, be disclosed to that party.
Third-Party Service Providers. We may provide PII about you to FGIS contractors, agents, and designees to the extent necessary to enable them to perform certain Site related services (e.g., providing web hosting, improving Site related services and features, or providing maintenance services) on FGIS behalf.
Business Transfers. FGIS may transfer any and all PII to third parties (whether affiliated or unaffiliated with FGIS), in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
By using the Site, you acknowledge and consent to the fact that PII provided by you or collected by us through your use of the Site may be stored and processed by us in the United States, which may provide a different level of data protection than that provided by your country of residence. You also acknowledge and consent to the fact that we may, at FGIS discretion, store and process such data in other countries and will endeavor to protect the PII under FGIS control wherever it is processed or stored.
How We Use and Disclose Other Information
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as PII under applicable law, then, in addition to the uses listed in the "The Information That We Collect" Section above, we may use and disclose Other Information for all the purposes for which we use and disclose PII.
In some instances, we may combine Other Information with PII (such as combining your name with your geographical location). If we combine any Other Information with PII, the combined information will be treated by us as PII as long as it is combined.
Information Collected by Third Parties
Your Choices :
Opting Out. We may from time to time send you mailings relating to FGIS that we think may be of interest to you. If you would prefer not to receive marketing mailings from us, you may unsubscribe from these marketing mailings by following the unsubscribe instructions in any such message or by contacting us by email at firstname.lastname@example.org.
Reviewing, Changing, or Suppressing PII. To the extent permitted by the laws of your country, you may request to review, correct, update, suppress, or otherwise modify any PII that you have previously provided through the Site, or object to the use of such PII by FGIS. You may exercise these rights by logging on to your subscriptions account on the FGIS Site at or by contacting us at email@example.com.
Additionally, you may also oppose the processing or transferring of PII to the extent the laws of your country require if you have a legitimate reason to do so.
In your request, please make clear what information you would like to have changed, whether you would like to have your PII suppressed from our database or otherwise let us know what limitations you would like to put on our use of your PII.
For your protection, we will only implement requests with respect to the PII associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will endeavor to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within FGIS databases and other records, which will not be removed therefrom. We may, from time to time, re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared PII about you.
Special Notification for Individual California Users
Freeh Group International Solutions, LLC
3711 Kennett Pike, Suite 130
Wilmington, DE 19807
Within thirty (30) days of receiving such a request, we will provide a list of the categories of PII disclosed to third parties (i.e., other affiliated legal entities of FGIS) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve FGIS right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
Security. FGIS seeks to adopt commercially reasonable security measures consistent with industry practice to assist in protecting against the loss, misuse, and alteration of PII that is under FGIS control. Unfortunately, no data storage system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. As a result, we cannot guarantee the security of FGIS servers, the means by which PII is transmitted between your computer and FGIS servers, or any PII provided to us or to any third party through or in connection with the Site. If you believe your connection to FGIS site is no longer secure, please notify us as soon as possible.
Use of the Site by Children. The Site is not directed to children under the age of thirteen (13), and FGIS does not knowingly collect PII from children. If you are younger than thirteen (13) years old, please do not provide any PII while using the Site.
Jurisdictional Issues. FGIS does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time, without prior notice to you, and in FGIS sole discretion. By using the Site and submitting any PII, you consent to the transfer of PII to other countries outside of your country of residence, including the United States, which may provide a different level of data security and data protection rules than that provided in your country of residence.
Freeh Group International Solutions, LLC
3711 Kennett Pike
Wilmington, DE 19807
Please note that email communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us.
Sensitive Information We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise to us.
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