This FiRa Consortium Global Privacy Notice was last updated on August 11, 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. 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 firstname.lastname@example.org. 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 email@example.com.
If you would like to opt-out of receiving sales and marketing communications from us, you may contact us at firstname.lastname@example.org.
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 email@example.com 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 and LGPD
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”). If you are a resident of or are located in Brazil, you may have certain rights under the Lei Geral de Proteção de Dados (“LGPD”).
In general, under the GDPR you have the following rights:
- Right to information. This right provides you with the ability to ask FiRa Consortium for information about what Personal Data is being processed and the rationale for such processing.
- Right to access. This right provides you with the ability to get access to your Personal Data that is being processed. This request provides the right for you to see or view your own personal data, as well as to request copies of the personal data.
- Right to rectification. This right provides you with the ability to ask for modifications to your Personal Data in case you believe that this Personal Data is not up to date or accurate.
- Right to withdraw consent. This right provides you with the ability to withdraw a previously given consent for processing of your Personal Data for a purpose.
- Right to object. This right provides you with the ability to object to the processing of your Personal Data.
- Right to object to automated processing. This right provides you with the ability to object to a decision based on automated processing.
- Right to be forgotten. Also known as right to erasure, this right provides you with the ability to ask for the deletion of your data. This will generally apply to situations where a customer relationship has ended. This is not an absolute right, and depends on FiRa Consortium’s retention policies.
- Right for data portability. This right provides you with the ability to ask for transfer of your Personal Data. As part of such request, you may ask for your Personal Data to be provided back to you or transferred to another controller.
Rights under the LGPD are similar, and include:
- Right to confirmation
- Right to access
- Right to Rectification
- Right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD
- Right to Data Portability
- Right to be Forgotten
- Right to information about public and private entities with which the controller has shared data
- Right to information about the possibility of denying consent and the consequences of such denial
- Right to withdraw consent
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. In the case of the GDPR, 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 Consortium’s Data Privacy Officer at firstname.lastname@example.org 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, Brazil 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 email@example.com. 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.
Mr. Joe Laferrera
3855 SW 153rd Drive
Beaverton, OR 97003