Privacy and Data Collection Policy
Last Updated on May 21, 2018 (To view previous version click here)
FranConnect, LLC. (FranConnect) is committed to protecting the privacy of the people who use the internet systems that we provide. This document describes our policies and practices regarding the collection and use of personally identifiable information. Personally identifiable information that we may collect may include domain names, Internet Protocol (IP) addresses, e-mail addresses contact information (such as name, address, and telephone numbers) and any other information that you otherwise provide and/or we receive through our systems (“information”).
IF YOU DO NOT WANT FRANCONNECT TO COLLECT, STORE, AND PROCESS YOUR INFORMATION AS DESCRIBED IN THIS POLICY, THEN YOU HAVE THE OPTION TO OPT-OUT USING OUR CONTACT INFORMATION BELOW.
COLLECTION OF YOUR INFORMATION
We only collect and use information from you for the purpose of providing the information and services that you request. We will not sell or rent information that we collect. Information collected is only used for a proper business purpose and at no time will be used outside that scope.
Personal data processed by FranConnect shall not be kept for longer than is necessary for the intended process or purposes. You have the right to request that your information be deleted, once the request has been verified the data will be deleted within a reasonable timeframe.
Information You Give Us. We collect your name, postal address, email address, phone number, fax number, username, password, demographic information (such as your gender and occupation) as well as other information you directly give us.
Information We Get From Others. We may receive additional information about you, such as demographic information, from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may use to supplement the information that we collect directly from you.
- Save user preferences and settings,
- Customize the content for individual users,
- Track session information (for example, determining if you are logged in or have visited before), and
- Facilitate and enhance your interaction with the contents of the website.
We may also use methods such as Google Analytics to track usage of our websites so that we can continue to improve them.
When we send emails, we may track behavior such as who opened the emails and who clicked the links. We do that to measure the performance of email campaigns and to improve our features for specific segments of customers. To do this, we include single pixel Gifs in emails we send. Gifs allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Gifs in the emails we deliver for you. We use the data from those Gifs to create the reports about how your email campaign performed and what actions your recipients took. Reports are also available to us when we send email to you, so we may collect and review that information.
Information from the use of our Mobile Apps
When you use our mobile apps, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you opt in to these notifications and no longer want to receive them, you may turn them off through your operating system. We don’t access or track any location-based information from your mobile device unless you’ve given us permission. We may use analytics software (such as intercom.io) to help us better understand how people use our application. We may collect information about how often you use the application and other performance data.
We follow an opt-in permission-based text message (SMS) enrollment policy. We will not send unsolicited, bulk or commercial offers or advertisements without your permission. All SMS messages contain information on how to unsubscribe from the list. You may leave our lists at any time for any reason. If you have any questions or feel that you received unsolicited email or an unsolicited SMS message please contact us.
USE OF PERSONAL INFORMATION
We may use your information as follows:
- to operate, maintain, and improve our sites, products, and services;
- to respond to comments and questions and provide customer service;
- to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners;
- to process and deliver contest entries and rewards;
- to link or combine user information with other information;
- to provide and deliver products and services at customer’s request.
SHARING OF INFORMATION
We may share information as follows:
- We may share information with your consent. For example, you may let us share information with others for their own marketing uses. Those uses will be subject to their privacy policies.
- We use third-party web analytics services (e.g., Google Analytics) on our services to collect and analyze the information discussed above, and to engage in auditing, research and reporting.
- We may share information if FranConnect merges or is combined with any other organization, or if it transfers all or substantially all of its assets or operations to another organization, it may disclose information it collects from you to the other organization so that the other organization can continue to provide services to you while maintaining your information rights of both access and choice. The other organization will be bound by this policy.
- We may share information for legal, protection, and safety purposes.
- We may share information to comply with laws.
- We may share information to respond to lawful requests and legal processes.
- We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
- We may share information with those who need it to do work for us.
We may also share aggregated and/or anonymized data with others for their own uses. We may use such data for any legal purpose, including without limitation for research and marketing purposes, and may also share such anonymized data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others. By using the services, you consent to such use.
THIRD PARTY PROVIDERS
We may contract with other companies to provide various services to our customers on an outsourced basis rather than performing the services directly. For example, we may contract with a cloud hosting provider to host some or all of the processing and communication services that we provide. By continuing to use our services, you consent to our use of these third-party providers.
FranConnect processes the personal information it receives according to Privacy Shield Framework best practices and subsequently transfers any and all liabilities to third parties acting as an agent or on its behalf. FranConnect complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA region, including the onward transfer liability provisions.
GOOGLE GMAIL AND CONTACTS INTEGRATION
Users of the FranConnect Gmail Chrome Extension (Chrome Extension) must “opt-in” and provide authorization for the Chrome Extension to connect to Google services for (a) uploading attachments with emails, and (b) adding FranConnect contacts to Google Contacts. FranConnect does not save any user’s Google Contacts. FranConnect does not save any Gmail-based email messages, except those specifically stated by the user to be uploaded into the user’s FranConnect Sky account.
The information (including your IP address) collected by various analytics technologies will be disclosed to or collected directly by these Service Providers, who use the information to evaluate your use of the services, including by noting the third-party website from which you arrive, analyzing usage trends across FranConnect products, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
We’ll retain information for only so long as needed to provide services to our customers or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
When you give us information, we take steps to ensure that it’s treated securely through the use of strong security and encryption.
Information collected by our website or transferred to us from other sources will be processed in the United States.
DISCLOSURE AS REQUIRED BY LAW
We may need to disclose certain information of users when we have a reasonable and good-faith belief that the disclosure is necessary to enforce the Terms of Service, comply with a judicial proceeding, court order or other legal process, or to otherwise enforce or protect our rights under applicable law. In this situation we will use reasonable efforts to provide notice of this disclosure to all affected users, to the extent reasonably possible under the circumstances.
We will use at least industry-standard security measures to protect against the loss, alteration, misuse and unauthorized disclosure or access of the information under our control. The servers that we use to store information are kept in secure data center environments with physical access restrictions and continuous monitoring. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and thus we cannot ensure or warrant the security of that information.
Safeguarding Your Information
FranConnect has put in place certain technological and procedural security functions in order to protect the personal information it collects, uses or transfers from loss, misuse, alteration or destruction. FranConnect uses firewalls to help prevent outside parties from accessing our database server through the Internet, and physical access to the servers is restricted to authorized individuals. The data center housing the personally identifiable information is compliant with all relevant data security standards including SOC1, SOC2 and SAS70.
When transferring personally identifiable information to and from third parties FranConnect uses SSL encryption and limits exposure through the use of fully trained employees and industry standard data monitoring practices.
Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Distribution Lists, then FranConnect will notify you as soon as possible and later report the action we took in response. FranConnect’s security procedures and data warehousing security ensure that potential intrusions are monitored and reported in a timely manner consistent with current data privacy regulations.
INFORMATION CHOICES AND CHANGES
If you no longer wish to receive our communications, you may opt-out of receiving them by following the instructions included in each communication or by emailing us at email@example.com, please include your email address and/or cell phone number in the message along with the client you wish to unsubscribe from as well as write the word, “unsubscribe” in the subject line. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You can typically remove and reject cookies from our website with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our website works for you.
You have the right to access the information that we hold about you. This may be called a ‘Subject Access Request’. If you make a request for your information we will provide it to you or your designated agent free of charge within a reasonable timeframe.
Before providing information to you or your designated agent on your behalf, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your information.
You have the right to object to us processing your information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long, or have its processing restricted in certain circumstances.
If any of the information we hold about you is inaccurate or out of date, you may ask us to correct it. Unless it’s prohibited by law, we’ll remove any information about an individual from our servers at their request. There is no charge for an individual to access or update his or her personal information. If you would like to exercise any of these rights or lodge a complaint, please contact us as set out below.
DATA STORAGE IN THE UNITED STATES AND INDIA
Our servers and offices are located in the United States and India, so your information may be transferred to, stored, or processed in those two countries. By using our services, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and India and those third parties with whom we share it as described in this policy.
All inquiries, complaints, and questions concerning this Policy or related issues may be sent to firstname.lastname@example.org, or by postal mail to:
ATTN: Privacy Administrator
11800 Sunrise Valley Drive, Suite 900
Reston, VA, 20191