FN AMERICA, LLC (doing business as FNH USA)
EFFECTIVE AS OF DATE OF LAST MODIFICATION: October 8, 2014
A. INFORMATION WE COLLECT
Our websites may collect two kinds of information about you: (1) information that you provide that personally identifies you; and (2) information that does not personally identify you.
1. Personally Identifiable Information:
Personally identifiable information (“PII”) is any information that may be used to specifically identify or contact you, such as your name, mail address, phone number, etc. We do not automatically collect your PII when you visit our websites, but in some circumstances, we may request, allow or otherwise provide you an opportunity to submit your PII in order to use a feature, program, promotion or some other aspect of our websites. For example, you may provide PII when registering with our websites, using our online store or in connection with a contest entry, and you may provide certain demographic information about yourself (e.g., age, gender, purchase preference, usage frequency, etc.) when participating in a survey or poll. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become personally identifiable when combined with other information (e.g., your age and name). You may choose whether to provide this information, but at times the information is required to participate in the particular activity, to access to certain content on our websites, or to accept a benefit we offer.
2. Non-Personal Information:
Non-personal information is any information that does not personally identify you. Non-personal information can include certain PII that has been de-identified; that is, information that has been rendered anonymous. We and/or our third party service providers obtain non-personal information about you from information that you provide us, either separately or together with your PII. We and/or our third party service providers also automatically collect certain non-personal information from you when you access our websites.
B. HOW WE USE & SHARE YOUR INFORMATION
1. Personally Identifiable Information:
2. Non-Personal Information:
We and our service providers may use technologies that automatically collect certain web site usage information whenever you visit or interact with the websites. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information. We may use this information for a variety of purposes, including to enhance or otherwise improve the websites. In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a “Device Identifier”). A Device Identifier is a number that is automatically assigned to your computer, and we may identify your device by its Device Identifier. When analyzed, usage information helps us determine how our websites are used, such as what types of visitors arrive at the websites, what type of content is most popular, what type of content you may find most relevant and whether users are interested in particular kinds of content and advertising. We may associate your Device Identifier or web site usage information with the PII you provide, but we will treat the combined information as PII. We may also acquire and use information from other sources about your visits over time and across other third party web sites, in order to serve more targeted advertising to you. Third party service providers, as well as advertisers, may collect and use information about your visits over time and across the other third party web sites.
Web site usage information may be collected using various methods, such as the following:
Cookies - A cookie is a data file placed on a computer when it is used to visit the websites. Cookies may be used for many purposes, including tracking user preferences and web pages visited while using the websites. You may be able to remove, reject and/or disable some types of cookies using your browser’s preferences or other programs. Some features of the websites may not function properly if you disable, delete, or refuse to accept cookies. Some of the cookies we use may be “Flash” cookies. A Flash cookie is a data file placed on a computer. While they are harmless, depending on your browser, these cookies may not be deleted when your cookies are deleted or disabled and, in some instances, they may cause your cookies to reappear in your browser. Please check your browser to determine where these types of cookies are stored and how they may be deleted or disabled.
Web Beacons – Web beacons are small graphic images or other web programming code (also known as “clear GIFs”). These may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail message can act as a web beacon. Web beacons or similar technologies may be used to count visitors to the websites, to monitor how users navigate the websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed, among other things.
Mobile Device Identifiers - Some mobile service providers uniquely identify mobile devices and we may receive such device information if you access the websites through mobile devices. Some features of our websites may require collection of mobile phone numbers, and we may associate that phone number to mobile device identification information. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we may receive this information.
Embedded Scripts - An embedded script is programming code that is designed to collect information about your interactions with the websites, such as the links you click on. The code is temporarily downloaded onto your Computer from our web server or a third-party service provider, is active only while you are connected to the websites, and is deactivated or deleted thereafter.
We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and to improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives, but the aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.
C. OTHER USES
1. E-mail Communications:
If you send us an e-mail, we may use your PII to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public PII, such as passwords, social security numbers or bank account information, to us by e-mail. We may send you e-mail: (a) if you request a particular service or sign up for a feature that involves e-mail communications; (b) if it relates to purchases you have made with us (e.g., product updates, customer support, etc.); (c) if we are sending you information about our other products and services; (d) if you consented to being contacted by e-mail for a particular purpose; (e) if you send us an e-mail or otherwise submit information to us electronically, we may e-mail you to follow-up or otherwise communicate with you with respect thereto; (f) to provide you legal notices or notices with respect to your use of the websites; or (g) to otherwise facilitate a transaction between us. You may “opt out” of receiving future commercial e-mail communications from us by clicking the “unsubscribe” link or following the other instructions included at the bottom of most e-mails we send, or as provided below in Section H. We reserve the right to send you transactional e-mails such as customer service communications.
2. Transfer of Assets:
If another entity acquires us or all (or substantially all) of our assets, the PII and non-personal information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Notwithstanding anything herein to the contrary, we reserve the right to disclose any PII or non-personal information about you if we are required to do so by law, and/or if we believe that such action is necessary to: (a) fulfill a government request; or (b) conform with the requirements of the law or legal process.
4. Sweepstakes Contests and Promotions:
We may offer sweepstakes, contests, and other promotions through the websites that may require registration. By entering any promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion. If you choose to enter a sweepstakes, contest or other promotion, personally identifiable information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.
5. Your California Privacy Rights:
California’s "Shine the Light" law, Civil Code section 1798.83, provides residents of the State of California the right to request a list of all third parties to which the we have disclosed certain PII as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please provide a current California address for our response. You may request the information in writing from FNH USA, LLC, Webmaster, P.O. Box 9424, McLean, VA 22102, or by email to email@example.com.
6. Browser Do Not Track Signals
Some third party browsers provide “do not track” machine readable signals for websites which are automatically applied by default and therefore do not necessarily reflect visitors’ choices as to whether they wish to receive advertisements tailored to their interests. As a result we do not respond to these signals.
7. Third Party Ad Server Networks:
Our websites are not intended for children. We do not knowingly collect PII from children under the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed PII to us, please contact us at firstname.lastname@example.org. A parent or guardian of a child under the age of thirteen (13) may review and request deletion of such child’s PII as well as prohibit the use thereof.
E. KEEPING YOUR INFORMATION SECURE
We use security measures to protect against the loss, misuse and alteration of the information under our control. While we strive to protect your PII and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your PII. In the event that your “personally identifiable information” (as such may be defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (in our sole discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
F. OTHER SITES/LINKS
Our websites may link to or contain links to other third party websites that we do not control or maintain, such as in connection with purchasing products referenced on our websites and banner advertisements. We are not responsible for the privacy practices employed by any third party websites. We encourage you to note when you leave our websites and to read the privacy statements of all third party websites before submitting any personally identifiable information.
G. THIRD PARTY APPLICATIONS
Third party applications may be available via the websites. The owners of these applications (“Third Party Owners”) may collect PII from you and may have their own policies and practices. We are not responsible for the policies or the practices of Third Party Owners or how they or their applications use your PII. These Third Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. You should review any available policies before submitting any PII to a third party application.
H. CONTACT & OPT-OUT INFORMATION
I. CONSENT TO TRANSFER INFORMATION TO THE UNITED STATES
The websites are operated in the U.S.A. and are intended for users located in the U.S.A. If you are located in the European Union, Canada or elsewhere outside of the U.S.A., please be aware that information we collect will be transferred to and processed in the U.S.A. By using the websites or providing us with any information, you consent to this transfer and processing of your information in the U.S.A.