FGA PARTNERS PRIVACY POLICY

1. FGA Partners, LLC values its visitors’ privacy and we are committed to safeguarding it. This privacy policy is effective as of August 1, 2020 and it summarizes what information we might collect from a registered user or other visitor (“You”), and what we will and will not do with your personal information.

2. Please note that this privacy policy does not govern the collection and use of information by companies that FGA Partners, LLC does not control, nor by individuals not employed or managed by FGA Partners, LLC. If you visit a website that we are mentioned in or linked to, be sure to review its privacy policy before providing such website any personal information.

3. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.

What we do with your personally identifiable information:

It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to provide you with any products or services. “Personally identifiable information” means information that can be used to identify you as an individual. The following types of personal information may be collected, stored, and used:

• Information about your computer including your IP address, geographical location, browser type and version, and operating system;
• Session data for your login session, so that our network can communicate with your computer or device while you are logged in;
• Information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
• Information, such as your email address, that you enter when communicating with FGA Partners, LLC;
• Information that you enter when you contact FGA Partners, LLC, for example, your name, company name and employment details;
• Information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
• Information that you enter while communicating with FGA Partners;
• Information that is generated while using our applications or website, including when, how often, and under what circumstances you use it;
• Information relating to any upgrades that you make, services that you use, or transactions you make through our applications or website, which includes your name, address, telephone number, email address, and credit card details (if applicable);
• Information contained in any communications that you send to us by email or through our applications or website, including its communication content and metadata;
• Any other personal information that you send to us.

If you do provide personally identifiable information to us, either directly or through a reseller or other business partner, we will:

• Not sell or rent it to a third party; we may use your contact information to provide you with information we believe you need to know or may find useful, such as news about our services and products and modifications to the Terms of Service;
• Take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
• Not use or disclose the information except:
• 3.1. As necessary to provide services or products you have ordered, by providing it to a carrier to deliver products you have ordered;
• 3.2. In other ways described in this privacy policy or to which you have otherwise consented;
• 3.3. In the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
• 3.4. As required by law in response to a subpoena or search warrant;
• 3.5. To outside auditors who have agreed to keep the information confidential;
• 3.6. As necessary to enforce the Terms of Service;
• 3.7. As necessary to protect the rights, safety, or property of FGA Partners, LLC, its users, or others; this may include exchanging information with other organizations for fraud protection and/or risk reduction.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

Personal information submitted to us through FGA Partners, LLC will be used for the purposes specified in this policy or on the relevant pages of FGA Partners, LLC’s web, desktop or mobile applications. We may use your personal information for the following:

• Administering our website and business;
• Personalizing FGA Partners’ website for you;
• Enabling your use of the services available on FGA Partners;
• Supplying services purchased through FGA Partners;
• Sending statements, invoices, and payment reminders to you, and collecting payments from you;
• Sending you non-marketing commercial communications;
• Sending you email notifications that you have specifically requested;
• Sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
• Sending you marketing communications relating to our business or our family of brands and companies carefully—we will never share your personal information or contact details with third parties;
• Dealing with inquiries and complaints made by or about you relating to FGA Partners, LLC;
• Keeping FGA Partners website secure and preventing fraud;
• Verifying compliance with the terms and conditions governing the use of FGA Partners’ web, desktop and mobile applications. We will not monitor private messages or save such data on our network; all communication from one user to another is private and confidential.

If you submit personal information for publication on FGA Partners’ website, we will publish and otherwise use that information in accordance with the license you grant to us. Your privacy settings can be used to limit the publication of your information on FGA Partners, LLC and can be adjusted using privacy controls on FGA Partners. We will never share your personal information with any third party for their or any other third party’s marketing purposes or otherwise.

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, or subcontractors as reasonably necessary for the purposes set out in this policy. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy. We may disclose your personal information:

• To the extent that we are required to do so by law;
• In connection with any ongoing or prospective legal proceedings;
• In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

1. Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

2. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, Asia, IndoAsia, the United Kingdom and India.

3. Personal information that you may publish on FGA or submit for publication on our applications or website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

4. You expressly agree to the transfers of personal information described in this and Section F.

1. This Section H sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.

2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

3. Without prejudice to article G-2, we will usually delete personal data falling within the categories set out below at the date/time set out below: (a) personal data type will be deleted daily.

4. Notwithstanding the other provisions of this Section H, we will retain documents (including electronic documents) containing personal data: (a) to the extent that we are required to do so by law; (b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and (c) in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

1. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.

2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

3. All electronic financial transactions entered into through our website will be protected by encryption technology.

4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

5. You are responsible for keeping the password you use for accessing FGA Partners website confidential; we will not ask you for your password (except when you log in to our applications or website).

We may update this policy from time to time by publishing a new version on FGA Partners. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on FGA Partners website.

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following: (1) the payment of a fee; and (2) the supply of appropriate evidence of your identity such as a color photocopy of a government issued photo identification or other that would be deemed acceptable proof of identity. We may withhold personal information that you request to the extent permitted by law.

Please let us know if the personal information that we hold about you needs to be corrected or updated.

FGA Partners, LLC uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from session cookies.

1. Most browsers allow you to refuse to accept cookies—for example:

• In Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools,” “Internet Options,” “Privacy,” and then “Advanced”;
• In Firefox (version 24) you can block all cookies by clicking “Tools,” “Options,” “Privacy,” selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
• In Chrome (version 29), you can block all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Content settings,” and then selecting “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all the features on FGA. You can delete cookies already stored on your computer—for example:

• In Internet Explorer (version 10), you must manually delete cookie files (instructions at support.microsoft.com);
• In Firefox (version 24), you can delete cookies by clicking “Tools,” “Options,” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies,” and then clicking “Remove All Cookies”; and
• In Chrome (version 29), you can delete all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Clear browsing data,” and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data.”

Deleting cookies will have a negative impact on the usability of many websites.