PRIVACY POLICY

 

Last updated: August 1st, 2016 -  Friends and Family (“Friends and Family”) is strongly committed to protecting and respecting your privacy rights. This privacy policy (the “Privacy Policy”) sets out the basis on which Friends and Family collects and uses personal data from visitors to our website located at www.Friends and Family.com (the “Site”) and subscribers to our newsletter and services available through the Site. Use of the Site constitutes your consent to the terms of this Privacy Policy. Please review it carefully before submitting any information to Friends and Family through the Site. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

Safe Harbor Certification

In light of the international nature of our business, Friends and Family complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Friends and Family has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For more information about the Safe Harbor program, please visithttp://www.export.gov/safeharbor.

What Personally Identifiable Information is Collected?

Friends and Family collects data, such as name, address, e-mail address, fax and telephone numbers, employer and credit card information (collectively, “Personally Identifiable Information”), from you, through the registration forms on the Friends and Family Sales Site. Friends and Family may keep a record of any correspondence with you until it is no longer necessary. Friends and Family may retain copies of all information that you provide through the Site, both during your use of the Site and any services available through the Site and after termination or expiration of such use. Friends and Family may also ask you to complete surveys for research purposes and may keep a copy of your responses. Please note that you are not obliged to respond to such surveys.

Are Cookies and Log Files Used?

Friends and Family may collect information about your computer and browsing preferences, including, where available, your IP address, operating system and browser type. In some circumstances, Friends and Family uses cookies to enhance the functionality of the Site. A cookie is a small data file on the hard drive of your computer. Friends and Family uses cookies to identify a customer and to store registration details so that the customer is no longer required to re-enter these details on subsequent visits. In addition, Friends and Family uses cookies to indicate the number of computers used by each customer to log-in to the Site, and to prevent abuse of the Site and logins. Friends and Family also collects information on referring websites, IP addresses and web browsers used by customers when they access the Site, and uses such information for the same reasons mentioned above. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts or functionality of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, the Site will issue cookies when you log on to the Site. Please note that Friends and Family may use technology service providers to help monitor Site usage. Some of these service providers may collect non-personally identifiable information through cookies on Friends and Family’ behalf.

Uses Made of Personally Identifiable Information

Friends and Family may use information collected from you for the following purposes:

  •     For direct marketing campaigns, as permitted by law; Friends and Family will give you the option to opt out of each commercial email communication that it sends to you;

  •    To provide you with information and services that you request from Friends and Family or which Friends and Family feels may interest you, where you have consented for such purposes;

  •     To customize the Site to your preferences;

  •     To provide you with services available through the Site, for which you register;

  •    To develop new features of the Site and services available through the Site, and for         testing and other development purposes that do not involve disclosure to third parties;

  •      To carry out Friends and Family’ obligations under any contracts with you;

  •      To allow you to participate in interactive features of the Site, when you choose to do so;

  •      To notify you about the changes to the Site or any services available through the Site, including new product announcements, and;

  •      To conduct internal administration of Friends and Family’s business.

Does Friends and Family Disclose Personally Identifiable Information to Third Parties?

Friends and Family may disclose your Personally Identifiable Information to third party vendors used by Friends and Family for customer relationship management purposes, including the distribution of email communications. Friends and Family does not permit third party vendors to use Personally Identifiable Information for any purpose outside of those disclosed within this Privacy Policy. Friends and Family may disclose the names of Users of the Site to enquiring parties only if the enquiring party is from the same organization as the User. In addition, Friends and Family may disclose your personal data to third parties under the following circumstances:

  •      In the event that Friends and Family sells or buys any business or assets, in which case Friends and Family may disclose your Personally Identifiable Information to the prospective seller or buyer of such business or assets;

  •     If Friends and Family or substantially all of its assets are acquired by a third party, in which case Personally Identifiable Information held by it about its customers will be one of the transferred assets;

  •      If Friends and Family is under a duty to disclose or share your personal data in order to comply with any legal obligation;

  •      To protect the rights, property or safety of Friends and Family or its customers, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Friends and Family may use all Dashboard Usage Data, including that which is specific to User, and the Business Data for the purpose of creating aggregated and anonymized statistics on the Friends and Family customer base (the “Aggregate Data”). Friends and Family shall be the sole owner of the Aggregate Data and, notwithstanding anything to the contrary, shall be free to use and disclose the Aggregate Data at its discretion. Aggregate Data shall not include the User’s Business Data unless it has first been aggregated with data belonging to other Friends and Family clients, shall not identify User as the source of any specific piece of data, and shall not include any Personally Identifiable Information or data specific to any individual identified in User’s Business Data.

Securing Your Personal Data

Friends and Family takes reasonable steps to protect your Personally Identifiable Information as you transmit such information from your computer to the Site, and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration or destruction. You should keep in mind, however, that no internet transmission is 100% secure or error-free. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to the Site via e-mail or other electronic means. Where Friends and Family has given you a username and/or password which enables you to access certain parts of the Friends and Family website, you are responsible for keeping such username and/or password confidential.

Links to Third Party Sites

The Site may, from time to time, contain links to external websites. Friends and Family encourages you to review the privacy and security policies of any externally linked websites that may be accessed through the Site. Friends and Family assumes no responsibility or liability for the information, collection and disclosure practices of any external websites that a User can access through the Site. Please check the privacy policies of these external websites before you submit any Personally Identifiable Information or other information to them.

Can I Change My Information?

To keep your Personally Identifiable Information accurate, current and complete, please contact us via the email address on the About Us page. Friends and Family shall use commercially reasonable efforts to respond to your data access request within 30 days of receiving your request. If Friends and Family is unable to respond to your request within such period Friends and Family shall use commercially reasonable efforts to notify you of the reason why Friends and Family is so unable. Should you choose to unsubscribe from any mailing lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all Friends and Family communications.

Important Notice to Non-U.S. Residents

Friends and Family abides by the principles set forth in the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union member countries and Switzerland. However, it is important to note that the servers that store the information are operated in the United States or at one of our other data centers located outside the United States. If you are located outside of the United States, please be aware that any information provided to us may be transferred to the United States. Unless you are a resident of the European Union or Switzerland, your use of the Site and your provision of information to us in any manner will be construed as consent to such transfers. In order to comply with the Safe Harbor framework, Friends and Family commits to the resolution of complaints about your privacy and our collection or use of your information. We have committed to resolve any complaints by European Union and Swiss citizens relating to this Privacy Policy, which cannot be resolved directly by our company, through the Council of Better Business Bureaus, Inc.’s Safe Harbor Privacy Dispute Resolution Procedures. If you have any questions regarding this Privacy Policy, please contact us as set forth in the “Contact Us” section below. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Changes to This Privacy Policy

Friends and Family reserves the right to amend this Privacy Policy at any time and from time to time. You should check this Privacy Policy each time you use the Site to determine if any changes have been made. If you use the Site after the amended Privacy Policy has been posted, you will be deemed to have agreed to the amended Privacy Policy.

About Children

Friends and Family does not knowingly collect information from children under the age of 13 through the Site. If you are under the age of 13, please do not provide any information through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide any information on this Site or any other web site without their permission. If you have reason to believe that a child under the age of 13 has provided information to Friends and Family through the Site, please contact us using the information in the About Us section of the Site, and we will endeavor to delete that information from our databases.

Contact Us

If you have any queries about the privacy statement or to report a privacy issue, please contact us.