This FiRa Consortium Global Privacy Notice was last updated on January 3, 2020.
Data privacy is important to the FiRa Consortium and its’ members. This Privacy Notice describes the Personal Data that we collect about you as a visitor to the FiRa Consortium’s website, how we use it, with whom we share it, and describes your rights with regard to the Personal Data we have about you.
Personal Data We Collect
The FiRa Consortium is committed to protecting your privacy. Should we ask you to provide certain personal data by which you can be identified when using this website, we will use it in accordance with this Privacy Notice.
The FiRa Consortium collects, processes, and retains information about you when you visit our website, which may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exist pages, the files viewed on our site (e.g. HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site. Such Personal Data will not be kept for longer than is necessary for the purpose (s) for which it was collected. Notwithstanding this, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.
You may choose to provide us with additional information, such as your name, email address, company name, telephone number, or other information, so we can follow up with you after your visit. We may combine other publicly available information related to the organization from which you work for with the information that you provide to us. The FiRa Consortium and/or FiRa Consortium service providers may observe your activities, interactions, and other computer and connection information (such as IP address) relating to your use of our websites and our services.
We may also use log files, cookies and similar technologies. For more information about our use of these technologies and how to control them, see our Cookies and Similar Technologies section below. We may collect and store this information and combine this information with other Personal Data you may have provided.
We may also obtain data from third parties with which we offer services or engage in joint marketing activities. We protect data obtained from third parties according to the practices described in this Notice, plus any additional restrictions imposed by the source of the data.
When you download mobile applications, we automatically collect technical data and related information about the devices being used for the Services, including information on the type of device you use, operating system version, application software, peripherals and the device identifier; and push ID (“UDID”).
You have choices about the data we collect. When you are asked to provide Personal Data, you may decline. But if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.
This Privacy Notice may be updated from time to time. This notice is effective from June 24, 2019. We suggest that you review the Privacy Notice periodically. In the event of a material change, we will post a change notice on our website and we may notify individuals of such changes through contact information that we have for such individuals prior to the change becoming effective. If we amend the Privacy Notice, the new Notice will apply to Personal Data previously collected by the FiRa Consortium only insofar as the rights of the individual affected are not reduced, or the data subject expressly consents.
How We Use Personal Data
The FiRa Consortium requires personal data to communicate with you when you submit inquiries via our Contact Us form.
The FiRa Consortium uses the data we collect to operate the Consortium, which includes using data to improve the information we provide and to personalize your experiences. We also may use the data to communicate with you, for example, informing you about your account, to send email communications or make phone calls for the purpose of sending you information about upcoming webinars and events, announcements, newsletters and educational content. We will use the aggregate data that we collect internally in order to better understand and assist our members and visitors and to help improve our website and services. We process Personal Data for certain Legitimate Interests, which include some or all of the following:
- where the processing enables us to enhance, modify, personalize or otherwise improve our services / communications for the benefit of our members or other visitors
- to identify and prevent fraud
- to enhance the security of our network and information systems
- to better understand how people interact with our website
- to provide postal communications which we think will be of interest to you; and to
- determine the effectiveness of promotional campaigns and advertising.
Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish. To object to this processing, for inquiries on your rights and/or for general inquiries, please send an email to email@example.com. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit or to provide information.
When we process your Personal Data for our Legitimate Interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business 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).
Reasons We Share Personal Data
We may disclose your personal data to our agents or sub-contractors for the purposes identified above. For example, companies we’ve hired to assist in protecting and securing our systems and services may need access to Personal Data to provide those functions; they are not allowed to use Personal Data they receive from us for any other purpose. In such cases, the agent or sub-contractor must abide by our data privacy and security requirements and agree to any data protection agreements as we may require. They will be obligated to use that personal data in accordance with the terms of this Privacy Notice.
The FiRa Consortium will not sell, distribute or lease your Personal Data to third parties unless we have your permission or are required by law to do so.
Disclosure Required by Law
The FiRa Consortium may cooperate with law enforcement agencies in identifying users who use the website for illegal activities. Therefore, the FiRa Consortium will respond to subpoenas, warrants, or other court orders regarding information concerning any user. The FiRa Consortium will, at the FiRa Consortium’s discretion, disclose information, including Personal Data, if the FiRa Consortium reasonably believes that the FiRa Consortium is required to do so by law, that such disclosure is necessary to protect the FiRa Consortium from legal liability, or that the FiRa Consortium should do so to protect the integrity of the website or the products or services.
How to Access and Control Your Personal Data
Upon request, the FiRa Consortium will provide you with information about whether we hold any of your Personal Data. We will retain your information for as long as your account is active or as needed to provide you with information on products and services. Additionally, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
For more information on how to exercise your rights or make an inquiry regarding the Personal Data we have about you, please send an inquiry to firstname.lastname@example.org.
If you would like to opt-out of receiving sales and marketing communications from us, you may contact us at email@example.com.
Links to Third Party Sites
Our website includes links to other websites whose privacy practices may differ from those of the FiRa Consortium. If you submit Personal Data to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy notice of any website you visit.
Cookies and Similar Technologies
What Are Cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be "persistent" or "session" cookies. Persistent cookies save a file on your computer permanently. It can then be used to customize the web page as the choices and user interests. Session cookies are sent between your computer and the server to access information while you are browsing. Session cookies do not identify you personally and disappear when you turn off your browser.
For more information on cookies generally, please visit www.allaboutcookies.org.
Cookies we use specifically in this site are (the cookie storage time is in parentheses after its name):
- hjIncludedInSample (session) - Used to let Hotjar know whether that visitor is included in the sample which is used to generate Heatmaps, Funnels, Recordings, etc.
We are working to improve www.firaconsortium.org. In order to do this, we use Google Analytics and Hotjar to analyze our visitors' behavior on an anonymous and aggregate level.
The following cookies are installed by our web statistics tool Google Analytics to log information about visits and site visitors. Statistics are used to improve the use of the website by the user:
__utma (2 years)
_utmz (6 months)
_utmb (30 minutes)
_utmt (10 minutes)
_ga (2 years)
_gid (24 hours)
_gat (1 minute)
AMP_TOKEN (30 seconds to 1 year)
_gac (90 days)
Social Media Widgets
What Are Your Choices Regarding Cookies
If you do not accept cookies, your browser can be set to not automatically accept cookies from being stored or to inform you whenever a site requests storing a cookie. Previously stored cookies can also be deleted through the browser. See the help pages of your browser for more information. However, be aware that some areas or functions of the FiRa Consortium website depends on cookies and may not work if you delete or not to accept cookies. Please contact us at firstname.lastname@example.org for more information about the cookies used on the website.
The FiRa Consortium has built our website using industry-standard encryption and authentication tools to protect the security of personal data. We also use technological measures such as secure routers and firewalls to help protect personal data. Information collected through the website is encrypted before it travels over the Internet using industry-standard technology for conducting secure online transactions. Unfortunately, because of its nature, we cannot guarantee against the loss or misuse of personal data transmitted over the Internet.
Rights Under GDPR
If you are a resident of or are located in the European Economic Area (EEA), you may have certain rights under the General Data Protection Regulation (“GDPR”).
In general, under the GDPR you may:
- Request access to your Personal Data
- Have incomplete or incorrect data corrected
- Have your Personal Data deleted
- Suspend or restrict our use of your Personal Data, or withdraw your consent
- Request a copy of your Personal Data
- Complain to a supervisory authority if you believe your rights under the GDPR are not being respected
Should you request a copy of your Personal Data, we will supply to you a copy of your Personal Data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. Should you request the deletion of your Personal Data, the FiRa Consortium will generally do so as soon as practicable, although your right to have your Personal Data deleted is subject to exceptions, such as, for example, compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
Contact the FiRa Consortium at email@example.com if you have concerns regarding your Personal Data, or wish to exercise any of these listed rights.
Transfer of Personal Data
Our computer systems are currently based in the United States, so your Personal Data may be processed by us in the United States. If you use the website and/or services offered on the website as a member or visitor from outside the United States, by using the website and/or services offered on the website, you agree to this Privacy Notice and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Notice.
The personal data that is collected and stored is exclusively used by the FiRa Consortium, except in the following cases where we may submit the data to third parties:
- When required by law; and/or;
- To the following categories of service providers appointed by the FiRa Consortium who provide services connected to this website or its functions or to assist us in providing our services to customers, but only to the extent it is necessary in order to provide these services:
- Web developers which develop the website, update or add content, etc.
- IT service providers which host, develop or offer support
Inquiries and Complaints
If you believe the FiRa Consortium maintains your personal data in one of the services discussed in this Privacy Notice, you may direct inquiries or complaints to firstname.lastname@example.org. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily after 45 days, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.
3855 SW 153rd Drive
Beaverton, OR 97003
This PRIVACY ADDENDUM FOR CALIFORNIA RESIDENTS supplements the information contained in our Privacy Notice and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
The FiRa Consortium collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||Yes|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||No|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||No|
|G. Geolocation data.||Physical location or movements.||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
The FiRa Consortium obtains the categories of personal information listed above from the following categories of sources:
- Directly from our members or their agents. For example, from documents that our members provide to us related to the services for which they engage us.
- Indirectly from our members or their agents. For example, through information we collect from our members in the course of providing services to them.
- Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
Use of Personal Information
The FiRa Consortium may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
The FiRa Consortium will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
The FiRa Consortium may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve months, we have disclosed the following categories of personal information for a business purpose:
Category: Identifiers and Personal Information
Information collected includes name and email address. Optional information collected includes phone number and/or company name.
The FiRa Consortium will disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: