Privacy Policy

The developers of the FG New America website at “fgnewamerica.com” and other domain names managed by FG New America, have prepared this privacy statement to inform visitors of FG New America policy and commitment to privacy on the web. Below are the guidelines FG New America uses for protecting the information that you provide us during a visit to our web site. PLEASE CAREFULLY READ ALL OF THE FOLLOWING GUIDELINES PRIOR TO USING THIS WEB SITE (“SITE”). IF YOU DO NOT AGREE WITH THESE PRIVACY GUIDELINES, DO NOT USE THIS SITE.

FG New America only asks for specific types of information for those using the web. In a few areas on our web site, we ask you to provide information that will enable us to enhance your site visit or to follow up with you after your visit. It is completely optional for you to participate. For example, we request information from you when you:

• Register on fgnewamerica.com or other FG New America managed sites
• Provide feedback in an online survey
• Subscribe to a newsletter or a mailing list
• Purchase a product or service

In each of the instances above, we may ask for Personal Data, which may include your name, e-mail address, phone number, address, type of business, customer preference information, and customer number (if you have one), as well as other similar personal information that is needed to register or subscribe you to services or offers. In the case of newsletters or mailing lists, you will be able to “unsubscribe” or “opt-out” of these mailings at any time. In order to have access to certain products and/or to purchase certain items, you may be required to provide credit card data or other acceptable payment information to our payment service provider. Wherever we collect Personal Data, we will make an effort to provide a link to this Privacy Policy so you will be reminded of your rights to limit our use of your information.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us through the web site or in connection with any of our products or services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of FG New America and authorized third parties (more about them is described below) located in the United States.

Automatically Collected Data

When you interact with FG New America through our web site or by use of our products or services, we receive and store certain information, which is collected using cookies and log data as described below:
In operating the web site, we use “cookies.” A cookie is a piece of information that the computer that hosts our web site gives to your browser when you access the web site. These cookies help provide additional functionality to the web site and help us analyze web site usage more accurately. In particular:

• Our web site may set a cookie on your browser that allows you to access the web site without needing enter a password more than once during a visit to the web site;
• We use cookies from Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the web site, compiling reports on the web site activity and providing further services to us relating to the web site usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631. You can prevent your data from being collected by Google Analytics on our web site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en;

If you are based in the European Economic Area, when you first visit the web site, you will be asked to consent to the use of cookies on the web site in accordance with this Privacy Policy, and if you accept, we will store cookies on your computer.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

While we recommend that you leave cookies turned on, because they allow you to take advantage of some of the web site’s features, on most web browsers you may refuse the use of cookies by selecting the appropriate settings. Be aware, though, that if you do this you may not be able to use the full functionality of the web site. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Log Data

When you visit this web site or use our products or services, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the web site. This log data includes web pages visited, browser type and settings, length of visit, the date and time of your request, and product features you use. The web site also automatically captures your Internet Protocol (“IP”) address (from which we determine the country you are connecting from at the time you visit the web site). FG New America uses IP addresses to analyze trends, administer the web site, track user movement, ensure the security of your interaction with the web site and gather broad demographic information for aggregate use.

FG New America Use of Your Personal Data and Other Information
To Provide the Service and Respond to Requests

FG New America will only use the Personal Data you provide consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by Email, we will use the Personal Data you provide to answer your question or resolve your problem. If you provide Personal Data to purchase, register, or use a Product, we will use your Personal Data to conduct activities related to your request, including delivering to you the Product(s) that you purchased, maintaining your account, contacting you regarding your use of the products and services and/or the web site, or notifying you of important changes to our services and/or the web site. For EU data subjects, such use is necessary to respond to your request and to process any orders you may submit to us.

Marketing Purposes

We will send you information about our various products and services, or other products and services we feel may be of interest to you. Only FG New America (or agents working on behalf of FG New America and under confidentiality agreements) will send you these direct mailings. If you do not want to receive such mailings, simply tell us when you give us your personal information. Or, at any time you can easily opt-out of receiving further marketing information from FG New America by sending us an email to: [email protected]. In the subject line, simply put “opt-out”.

Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email if you consent to us doing so at the time you provide us with your Personal Data (and such consent will be our legal basis for processing your Personal Data for such purpose). When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated above.

To Analyze, Administer, Support, and Improve Use of the Web Site and Our Services

We use data relating to your use of and interaction with the web site and our products and services, including information that we obtain through cookies, to analyze, administer, support and improve your access to and use of the web site and our services. We often conduct research on our customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and FG New America may share this aggregate data with its affiliates, agents and business partners. FG New America may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners, and to other third parties for other lawful purposes. This aggregate information does not contain any of your Personal Data, and your name will not be provided to any third party. For EU data subjects, this use of your Personal Data is necessary for our legitimate interests in understanding how the web site and our services are being used by you and to improve your experience of it. For some cookies placed through our web site, we rely on your consent – please refer to the “Cookies” section for more information on how we use cookies and other tracking technologies.

If FG New America intends to use any Personal Data in any manner that is different from anything stated in this Privacy Policy, we will inform you prior to or at the time the Personal Data is collected, and if the law changes in any way, we will give you notice as required.

Our Disclosure of Your Personal Data and Other Information

FG New America will not sell any of your information, but under certain circumstances we may share your Personal Data as follows:

Affiliated Companies

We may also share your Personal Data with our affiliated companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Other Service Providers

From time to time FG New America hires other companies to perform certain business-related functions or work for us to provide our products and services to you. These companies may include Email automation services, hosting and cloud computing service providers, payment processors, customer service, website analytics companies, providers of CRM, and marketing and sales software solutions. We only give them with the limited information that they need to perform the specific task they are hired to do. Subject to our specific instructions, they may access, process, or store Personal Data solely in order to perform the services we have hired them to do.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your Personal Data may be part of the transferred assets.

Legal Requirements

FG New America may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of FG New America, (iii) act in urgent circumstances to protect the personal safety of users of our web site or our products or services or the public, or (iv) protect against legal liability.

European Union Data Subjects

Scope

This section only applies to European Union data subjects (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein, and Norway and, where applicable, Switzerland). Our Privacy Policy describes why and how FG New America collects, uses and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing (please see “Your Rights” section below).

Data Controller

FG New America is the data controller for processing your Personal Data. Please see the Contacting FG New America section below to find out how to contact us.

Your Rights

Subject to applicable law, you have the following rights in relation to your Personal Data:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details (this process requires that we confirm your identity and EU citizenship). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so: If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or If we are processing your Personal Data for direct marketing.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated in the Contacting FG New America section at the end of this document.

Legitimate Interest

“Legitimate interests” means the interests of FG New America in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how the web site and our products and services are being used by you, to prevent fraud or criminal activity, misuses of our products or services, to ensure the security of our IT systems, architecture and networks, and to meet our corporate and social responsibility objectives, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.

Data Transfers

FG New America uses service providers (described above) to operate our business and our relationship with you. When you use our web site and products and services, you acknowledge and agree that your Personal Data will be transmitted to our and our service providers’ servers in the United States to provide you with the services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EEA we will take steps to ensure that your rights continue to be protected.

Data Retention

We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by law, whichever is the longer.

Your Choices

You can visit certain parts of the web site and use certain portions of the products and services without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain portions of the web site or products and services.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by FG New America other than Personal Data collected through the web site or products and services. This Privacy Policy shall not apply to any unsolicited information you provide to FG New America through the web site or products and services or through any other means (without prejudice to your rights under the applicable law). This includes, but is not limited to, information posted to any public areas of the web site, such as forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and FG New America shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Your California Privacy Rights

California Civil Code section 1798.83 permits FG New America customers who are California residents to request certain information regarding FG New America disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties and in some cases affiliates for their direct marketing purposes. To make such a request, contact via email at [email protected]. Any such inquiry must include “California Privacy Rights Request” in the first line of the description. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address. 

Children

FG New America does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the web site or products and services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the web site or products and services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to FG New America through the web site or products and services, please contact us as indicated in the Contacting FG New America section at the end of this document, and we will endeavor to delete that information from our databases. 

Third Party Sites and Products

This Privacy Policy applies only to the FG New America web site and FG New America products and services. The FG New America web site or the FG New America products and services may contain links to or otherwise interact with other web sites or products not operated or controlled by FG New America, including third party add-ons, applications and other software that could track your usage or collect Personal Data. The information that you share with Third Party web sites will be governed by the specific privacy policies and terms of service of the Third Party web sites and not by this Privacy Policy. We suggest contacting those third parties directly for information on their privacy practices and policies.

Security

FG New America takes reasonable and appropriate steps to protect the Personal Data provided via the web site and products and services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, Email or messages sent to or from the web site or products and services may not be secure. Therefore, you should take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to FG New America via the Internet. 

Changes to FG New America Privacy Policy

The web site, our products and services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice, so please review this policy periodically, and especially before you provide us with any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the web site or products and services after any changes or revisions to this Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. 

Access to Information; Contacting FG New America

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the web site or products and services.

Please contact us if you have any questions about FG New America Privacy Policy or the information practices of the web site or products and services by Email at [email protected].