Frisco take data privacy very seriously. This Privacy Policy sets out the principles governing Frisco’s use and protection of personal information that individuals and clients share with us (“Personal Data”) as well as describing the rights of individuals regarding their Personal Data.This Privacy Policy applies to Frisco’s data collection and use through this website and through its business operations.
For individuals and clients residing outside of the United States who seek to transfer Personal Data from the EEA, the Isle of Man, Switzerland or the United Kingdom to the United States, please refer to our Privacy Shield disclosure here. Frisco as an organization is committed to handling Personal Data in accordance with this Privacy Policy and applicable data protection and privacy laws worldwide including, but not limited to, the EU-U.S. Privacy Shield, the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).
Like many companies, Frisco monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Frisco collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor’s Internet Service Provider. This data is used to improve the usability, performance and effectiveness of Frisco’s website.
For more detailed information describing how Frisco uses cookies and your choices surrounding the use and opt out of such cookies, including information about third party embedded content on Frisco’s website and how Frisco responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.
As we describe below in this Privacy Policy, we may collect, store and otherwise process Personal Data of visitors to our websites, employees, officers, partners or other representatives and agents of our clients, business partners, and other individuals. This Privacy Policy does not apply to the collection and processing of Personal Data of job applicants and candidates or employees and non-employee workers. The processing of such Personal Data is subject to specific privacy policies and notices that are communicated to individuals in the context of their candidacy, employment or working relationship with Frisco.
In certain situations, where required by applicable law, Frisco will seek your express consent to collect or process your Personal Data. You may withdraw that consent at any time by emailing Frisco at data.protection@empoweredmargins.com. If you provide us with Personal Data of another individual that requires consent, it is your duty to make sure that the individual has consented to or is appropriately informed about the processing of their Personal Data by Frisco.
The Personal Data we collect varies depending upon the nature of the services provided and our interactions with individuals. In the context of the collection of data through this website, Frisco’s marketing activities and contract administration, we may collect the following categories of Personal Data (subject to applicable legal requirements and jurisdiction-specific privacy policies):
Visitors to our websites: we may collect the first name, last name, title, company, phone number, location, email address, subject of the request and message given for the purpose of the management of the relationship with clients and the administration of the website.
Clients’ representatives, officers, agents and employees, business partners, providers, parties to a contract: we may collect the name, professional address, title, email and other professional contact details, for contract administration purposes, to activate and maintain client accounts, to fulfill requests or respond to inquiries about Frisco products or services and to provide offers and information (as permitted by law) about products, services, or events offered by Frisco or that Friscos thinks may be of interest. Frisco may also use professional contact details of its clients’ employees for the purpose of sending surveys, questionnaires or for the purpose of organizing contests.
We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.
For some unique services, Frisco hosts and maintains its own proprietary software platforms (“Platforms”). These Platforms allow Frisco to offer enhanced services and specialized products to our customers. In some cases these software platforms may require the submission of Personal Data by customers. In cases where our data collection is materially different than described in this Privacy Policy, and may be subject to local data privacy laws, we will provide additional information regarding such data collection on the applicable Platforms.
All Frisco websites, products, and services are provided in cooperation with Frisco, Inc., located in the U.S. Any Personal Data may be shared with Frisco, Inc. or other entities controlled by or under common control with Frisco, Inc. for purposes of centralization of Frisco’s administrative, contract management, CRM, IT maintenance, marketing and IT security practices, for the purpose of the website’s management and security, and to provide information about Frisco products, services, or events. We may also share Personal Data with affiliated entities using the Frisco, in which case we will require those affiliates to honor this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Frisco ensures that it and its affiliates will process Personal Data in compliance with this Privacy Policy.
Frisco also may share Personal Data with authorized third-party agents or contractors that perform services for Frisco. If Frisco shares Personal Data with a third party, Frisco requires that those third parties agree to process Personal Data based on Frisco’s instructions and in compliance with this Privacy Policy.
Any transfers of Personal Data are subject to appropriate safeguards that are compliant with jurisdiction-specific privacy laws.
Frisco may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Frisco may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Frisco’s Terms of Use, or as otherwise required by law or regulation.
Frisco stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Frisco has in place security policies that are intended to ensure the security and integrity of all Personal Data.
Frisco has appropriate technical and organizational measures in place to protect against unauthorized or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Frisco. If Frisco forwards Personal Data to any third party, Frisco requires that those third parties have appropriate technical and organizational measures in place to comply with this Privacy Policy and applicable laws.
Frisco retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Frisco will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of a legitimate interest of us). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.
If you want to opt-out from a specific electronic communication service or marketing offer, you can unsubscribe at any time by using the opt-out link on such communication e-mail or send us an e-mail at: data.protection@empoweredmargins.com. Unsubscribing from a special service or product information may not automatically end the processing of your Personal Data by us unless we receive a specific email request from you in this respect. Any complaints about unsolicited marketing communication can be sent by e-mail to Frisco at the same email address.
Frisco’s websites, products, and services are not directed to children, and Frisco does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Frisco with Personal Data without their consent, the parent or legal guardian should contact Frisco at data.protection@empoweredmargins.com, and Frisco will take steps to delete any such Personal Data.
Frisco’s websites may provide links to other third-party websites that are outside of Frisco’s control and not covered by this Privacy Policy. Frisco is not responsible for the availability, content or accuracy, or privacy practices of other websites, products, services, or goods that may be linked to Frisco’s websites. Frisco encourages all users of its websites to review the privacy policies posted on these (and all) sites.
Frisco may change its Privacy Policy from time to time. Frisco therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.
If for any reason you wish to contact us, you may also send an email to data.protection@empoweredmargins.com. Complaints will be resolved internally in accordance with Frisco’s complaints procedures.
Frisco is committed to handling Personal Data in accordance with its Privacy Policy, the jurisdiction-specific privacy policies and the EU-U.S. Privacy Shield Framework (or the Swiss-U.S. Privacy Shield Framework, as the case may be), as administered by the U.S. Department of Commerce. There have been recent changes to the EU’s acceptance of the EU-U.S. Privacy Shield Framework’s terms. The European Court of Justice declared the Privacy Shield invalid as a legal mechanism of transfer. However, as of August 20, 2020, the U.S. Department of Commerce’s position is that this European Court of Justice decision does not relieve participants of their obligations under the Framework, and it continues to administer the Privacy Shield program while EU-US discussions on the issue continue. Frisco, as a part of our commitment to privacy and obligations as a privacy shield participant, continues to maintain its commitment to the EU-U.S. Privacy Shield and to adhering to a set of privacy principles that offer strong data privacy protections and recourse for EU residents. A link to the U.S. Department of Commerce’s position on the current state of the Privacy Shield Program can be found here: https://www.privacyshield.gov/article?id=EU-U-S-Privacy-Shield-Program-Update.
If there is any conflict between the terms of the Privacy Policy, the jurisdiction-specific privacy policies and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, and to view Frisco’s certification, please visit https://www.privacyshield.gov/list.
Frisco’s accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Frisco remains responsible and liable under the Privacy Shield Principles if third parties engaged by Frisco process the Personal Data in a manner inconsistent with the Principles, unless Frisco proves that it is not responsible for the event giving rise to any damage. Additionally, Frisco, Inc. has put in place data protection agreements with its affiliates where required.
You have certain rights to your Personal Data, including the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing or choose to limit the use and disclosure of your Personal Data. As a reminder, Frisco may disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Frisco commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Frisco’s European Data Protection Officer at data.protection@empoweredmargins.com.
If you live in the European Union, European Economic Area, or Switzerland and you have a complaint regarding the handling of your Personal Data in accordance with the EU-U.S. or Swiss-U.S. Privacy Shield Framework and your efforts to resolve the matter internally are unsatisfactory, the complaint may be submitted to the American Arbitration Association (http://go.adr.org/privacyshield.html) which has been selected as the independent recourse mechanism to resolve complaints and disputes relating to treatment of Personal Data originating in the European Union, European Economic Area, or Switzerland and transferred to the U.S. under this Privacy Policy. The services of the American Arbitration Association are provided at no cost to you. Under certain conditions, you may be entitled to invoke binding arbitration through the Privacy Shield Panel when other dispute resolution procedures have been exhausted. Frisco is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
As further explained in the “How to Contact Us” section in the Privacy Policy and the jurisdiction-specific privacy policies, Frisco encourages any individual to contact us should they have a Privacy Shield-related (or general privacy-related) complaint.
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