Privacy Policy

I.        INTRODUCTION

FDNA Inc. (“FDNA”) understands how important privacy is to our users and we are committed to protecting it. This Privacy Policy will describe what information we collect and process about you and your use of the services we provided through our Websites (“Services”). It will explain the choices you have about how your personal data is used and how we protect that information.

We recommend you to read this Privacy Policy carefully because by using our Services you agree to the collection and use of information as set forth in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.

Please note that some privacy rights and obligations may differ in certain locations based on local law, in which case FDNA will comply with the local legal requirements.

Capitalize terms used but not defined herein, shall have the respective meaning given to them in our Terms of Use.

II.        WHAT INFORMATION WE MAY COLLECT

a. Personal data

In certain cases, FDNA may collect personal data about you, including without limitation, your title, name, e-mail address and phone number. You are under no obligation to provide personal data but your refusal to do so may prevent you from using certain Services.

Personal data is collected at the following times:

  • When you use our Services, we may ask you to optionally provide your name, occupation, phone number, email address and other personal data. We collect this information and use it to provide the relevant Services.
  • When you contact us, we may collect information in order to, among other things, accurately categorize and respond to your inquiry and deliver the appropriate Service.
  • When you select to receive educational and event communications or product or other related communications.

b. Non-Personal data

In addition to the personal data we may collect when using our Services, we may collect non-personal data about your use of our Services, including pages and screens that you view, your computer’s internet protocol (IP) addresses, your computer’s or mobile device operating system and/or browser type, the identity of your internet service provider, referring/exit pages, date/time stamp, and click-stream data (i.e., a list of pages or URLs visited). In some cases, this non-personal data may be collected automatically and stored in log files to help us analyze trends, administer the Website, track users’ movements around the Website, and gather demographic information about our user base as a whole. However, this information, when used together with cookies (see “cookies” below for more information) or if collected when you are logged-in, may be used to link or associate such information to your personally identifiable information.

c. Cookies

We use various cookies on our Websites. A cookie is a tiny data file which resides on your computer which allows us to recognize you as a User when you return to our Website using the same computer and web browser. For more information about our cookies, please see our Cookie Policy.

III.       USES OF THE PERSONAL DATA WE COLLECT

The information you choose to provide when using our Service is collected by FDNA for the following purposes:

  • To provide our Services.
  • To improve our Services, including our Website.
  • To communicate with you.
  • To respond to your query and for the purpose of further contact in this matter.
  • To process your requests.
  • To defend against or to make claims.
  • To administer our Website under our terms and for internal operations, including troubleshooting, and data analysis, testing, research, statistical and survey purposes.
  • To improve our Website and to ensure that content is presented in the most effective manner for you and for your computer.
  • To customize your experience on our Services.
  • To keep our Website and other systems safe and secure.
  • To advertise, market and provide information about us or our services.
  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising (adapted to your preferences).
  • To make suggestions and recommendations about Services that may interest you or the person that you work for and subject to your stated preferences, where relevant.
  • To comply with applicable laws, such as tax laws, and to maintain appropriate records for internal administrative purposes, and to comply with applicable legal and regulatory obligations and respond to lawful government requests, as needed.
  • To fulfill any other business or commercial purposes at your direction or with your consent.

IV.       DIRECT MARKETING

By providing your personal data and accepting this Privacy Policy you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services or promotions.

You can unsubscribe from receiving these marketing communications at any time. To unsubscribe send an email to [email protected].

V.        FDNA’s COMMUNICATIONS TO YOU

FDNA will communicate with you through email, through notices posted on our Website or through other means, including push notifications, text and other forms of messaging. If we send any communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with any such access (including text messaging charges for messages to your mobile device).

Our communications to you include emails or other messages which help us operate and improve our Services, respond to your comments and questions and provide customer service, provide and deliver products and services you request, send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. To better understand you we may tailor messaging and services based on your interests, preferences, needs and specialties, send you information via email about products and services or new features, we or our selected partners offer.

By accepting this Privacy Policy, you are giving your consent to receive these communications. You may revoke your authorization to participate in these features of our Services at any time by sending a request to [email protected].

VI.       SHARING INFORMATION WITH THIRD PARTIES

FDNA does not share any personal data it collects with any third party, except for the following cases.

We may employ other companies or individuals to perform functions on our behalf. Examples of those service providers include analyzing data, providing marketing assistance and providing customer service. They may receive limited access to personal data needed to perform their functions, but they may not use it for other purposes.

We may use third-party software for various internal needs. Examples of those software include file storage services, analytics tools, infrastructure platforms and communication platforms.

We may segment our users by occupation, specialty, geographic location or other similar information and provide information from your public profile as part of our Services and product offerings.

When you use the Services you may be presented with advertisements or opportunities to engage in informational programs consisting of sponsor-selected content. Examples of these programs include sponsored news alerts or branded or unbranded discussion groups. All sponsored programs are labeled clearly as sponsored. When you choose to engage with a sponsored program, such as engaging with a commercial client’s sponsored news alert, you give your consent to provide the sponsor of such content with your personal data and information about the type of engagement (e.g., whether you viewed, interacted with or requested information about such promotional content). By accepting this Privacy Policy you are consenting to receive these communications. You may revoke your authorization to participate in these features of our Services at any time by sending a request to [email protected].

We may also disclose your personal data and other information you provide to another third party as part of a reorganization or a sale of the assets of FDNA. Any third party to which we transfer or sell FDNA’s assets will have the right to continue to use the personal data in accordance with this Privacy Policy, our Term of Use, and any applicable data protection and privacy regulations.

It is possible that we may need to disclose personal data when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process or request to FDNA brought in any country throughout the world, or to exercise our legal rights or defend against legal claims.

VII.      SURVEYS AND POLLS

As an User you may receive requests to participate in market research, including polls and surveys. If you participate in surveys and polls offered through our Services, the information you provide may be visible to others. By accepting this Privacy Policy you are consenting to receive these communications. You may revoke your authorization to participate in these features of our Services at any time by sending a request to [email protected].

VIII.    MINORS

The Services are intended for a specific audience and are not intended for minors under the age of eighteen. FDNA does not wish to obtain any information from or about such minors. If you are under eighteen years old, do not use our Services.

We do not knowingly gather personal data (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) about children under the age of 13. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, please contact our us at any time by emailing us at [email protected]. We will remove the data to the extent required by applicable laws.

IX.       YOUR RIGHTS AND CHOICES

You have a right to modify or remove the data about you, which has been collected pursuant to your decision to become a User.

a. Modifying information

You can review the personal data you provided us, including your email and contact preferences, at any time by emailing us at [email protected]. Please be aware that even after your request for a change is processed, we may keep a copy of the information which you originally provided to us in our backup and/or archival copies of our database, as we deem necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

b. Changing your selections about our communications to you.

You can choose to receive educational and event communications or product or other related communications from us at any time. If you do so, you may choose to unsubscribe from receiving such communications at any time, by emailing us at [email protected]. As long as you continue to use the Services, we will continue to communicate to you any information relating to product support, operations and updates and related communications. If you wish to stop those communications, you will be requested to stop using our services.

c. Removing information

You can also request to remove your personal data at any time. If you do so, we will remove all of the information that you have provided to FDNA and we may deny further access to our Services. We may retain certain data contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, or if required by law. FDNA disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information, subject to applicable data protection and privacy regulations. FDNA does not control when search engines update their cache, which may contain certain public profile information that has since been removed from FDNA’s publicly viewable database.

To request that we remove your information, please send your request to [email protected]. You will receive a response within ten (10) business days of its receipt.

X.        YOUR OBLIGATIONS

As a User, you have certain obligations toward FDNA:

  • You must, at all times, respect the terms and conditions of the Privacy Policy and the Terms of Use. This includes respecting all intellectual property rights which may belong to third parties (such as photographs).
  • You must not download or otherwise disseminate any information which may be deemed to be injurious, defamatory, violent, offensive, racist, sexist or xenophobic, or which may otherwise violate the purpose and spirit of FDNA and its community of users.
  • You must not provide information to FDNA which you believe might be injurious or detrimental to your person, professional or social status.

Any violation of this Privacy Policy may lead to the restriction, suspension or termination of your use of the Services notwithstanding any legal remedies we may pursue as we take these principles seriously and consider them to be the basis on which our users adhere to the Website and the services which it offers.

XI.       DATA RETENTION

We process personal data only for so long as is necessary for the purposes for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.

The data retention periods may be extended, if necessary, in the event of any claims and court proceedings – for the duration of these proceedings and their settlement.
Sometimes your personal data may be available in different sites and places such as the Internet for indefinite period, and the group of recipients of your data is therefore unlimited.

XII.      HOW WE PROTECT YOUR INFORMATION

We are committed to protect the security of your information. Therefore, we use a variety of industry-standard security technologies and procedures to help protect such information from unauthorized access, use, or disclosure. In addition, we protect your information from unauthorized physical access by storing such information in a controlled facility.

Except as provided elsewhere in this Privacy Policy, we limit access to personal data collected by us to only those persons (including employees and contractors) who have a business need for such access, have signed confidentiality agreements with FDNA, and in the case of contractors and/or service providers agree to adhere to applicable data protection and privacy regulations.

Protecting your personal data is also your responsibility. We ask you to be responsible for safeguarding your information.

XIII.    DATA PROTECTION OFFICER

FDNA has a “Data Protection Officer” (DPO) who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:
FDNA Inc.

Attn: Data Protection Officer

490 Sawgrass Corporate Parkway, Suite 200 Sunrise, FL 33325, United States of America
email: [email protected]

XIV.    CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please make sure to review this frequently. Our most updated Privacy Policy is posted on our Website. All changes will apply with immediate effect. By continuing to use our Service after notice of changes have been sent to you by email or published on our Website or through the Service, you are consenting to the changes.

XV.      ADDITIONAL  INFORMATION FOR USERS OF THE EUROPEAN UNION

a. Scope

This section applies to the processing of personal data that is within the scope of the EU General Data Protection Regulation (“GDPR”) – when it is carried out by FDNA (as a data controller) and concerns users who are in the European Economic Area (the “EEA”). In case of any doubts please contact us at [email protected].

b. GDPR Compliance

FDNA complies with the GDPR in regards to collecting, processing, and transferring the personal data of our EEA to non-EEA areas.

Our servers and data processing facilities are based in Ireland. In principle, all data processing activities are conducted within the EEA. However, in case we rely on a provider with data processing premises in a non-EEA country or in a jurisdiction that has not been declared adequate by the European Commission, FDNA uses EU standard contractual clauses (an agreement approved by the European Commission which gives personal data the same protection it has in the EU for data processing in non-EU countries) to ensure compliance with applicable EEA data protection and privacy regulations for our EU users. The EU standard contractual clauses used are available under the URL https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en

If you have any questions or concerns, please send an email to [email protected].

c. Identity and details of the Data Controller

The data controller is FDNA Inc., 490 Sawgrass Corporate Parkway, Suite 200 Sunrise, FL 33325. United States of America.

d. Legal basis of processing

When FDNA is processing your personal data in conjunction with the contract that is being concluded with you such as the Terms of Use, the legal basis for such processing will then be Art. 6(1)(b) GDPR (it is necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract).

If you are contacting us, for example, you have given us your information with a request to send you particular information, we process your data in order to respond to your query and for the purpose of further contact in this matter. The legal basis for the processing of your personal data in accordance with this purpose will be your consent (Art. 6(1)(a) GDPR).

We process personal data for marketing purposes, particularly to promote FDNA (for example, to contact you from time to time to promote our Services), send advertising, advertising approaches, satisfaction surveys and to better adapt the content of our communications to your needs. These data processing activities are based on your consent (Article 6 (1)(a) GDPR).

We process data regarding using of our Website for the purpose of proper management of our Website, to improve its performance, ensure its security, adapt its content to your preferences. In addition, we gather this data for internal purposes, including resolving issues, conducting data analyses, testing, research, statistics, and for survey purposes. The legal basis of our activities is your consent, except for cases when the use of such data is essential for the functioning of our Website (electronic provision of a service to you within that scope); in such cases the legal basis will be our legitimate interest (Art. 6(1)(f) GDPR).

Additionally, with regard to processing of your personal data in order to:

  • defend against or to make claims – the legal basis for processing of your personal data will be our legitimate interest (Art. 6(1)(f) GDPR);
  • fulfil legal obligations of the data controller (g. tax, accounting) – the legal basis for processing of your personal data will be the necessity for compliance with a legal obligation to which the controller is subject (Art. 6(1)(c) GDPR).

e. Data retention

As a general rule, personal data:

  • collected for the purposes of conclusion and performance of a contract such as our Terms of Use will be processed for the duration of the contract;
  • processed on the basis of our legitimate interest will be processed until the objection to processing or the fulfilment of the purpose for which it has been processed;
  • processed on the basis of your consent will be processed until its possible withdrawal or fulfilment of the purpose for which it was given.

The above-mentioned rules will apply unless any law or regulation (e.g. regarding archiving, taxation, accounting) or an order issued by any authority obliges us to process such data for a longer period, or in case of potential claims, for such claim’s limitation period specified by law – whichever is longer.

f. Your rights

You may assert the following rights towards FDNA at any time free of charge. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested.

  • Right of access. You have the right to obtain confirmation as to whether personal data concerning you are being processed by us and if so, which personal data concerning you is processed by us and to learn which third parties domestic or abroad your personal data has been transferred to. Furthermore, you have the right to obtain a copy of the personal data undergoing processing by us.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or completion of any incomplete personal data concerning you. You can also request that your personal data be corrected accordingly by third parties to whom we have transferred this data.
  • Right to erasure. You have the right to obtain the erasure of your personal data if the legal conditions are met. Accordingly, you may obtain the erasure of your data, for instance, if it is no longer necessary for the purposes for which it was collected. Furthermore, you may obtain erasure if we process your personal data on the basis of your consent and you withdraw this consent. You can also request that your data be erased accordingly by third parties to whom we have transferred this data.
  • Right to restriction of processing. You have the right to obtain the restriction of the processing of your data if the legal requirements are met. This is the case, for example, if you contest the accuracy of your personal data. For the duration of the verification of the accuracy of the data you can then obtain the restriction of the processing.
  • Right to object. You have the right to object to the processing of your personal data in the following cases:
    • If the processing is for direct marketing purposes, including profiling related to direct marketing.
    • If the processing, including profiling, is based on the following legal grounds:
      • necessary for us to perform a task in the public interest under Article 6 (1)(e) of GDPR; or
      • necessary for the data controller’s or a third party’s legitimate interests under Article 6 (1)(f) of GDPR and if we are not able to demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In case of such objection, we kindly ask you to state the reasons for objecting to the data processing.
    • Right to data portability. If personal data processing is based on consent or contract performance and, in addition, is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller. Furthermore, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible.
    • Right to withdrawal. If data processing is based on your consent, you have the right to withdraw your consent at any time and free of charge, with effect for the future.
    • Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority or other applicable privacy regulator about our processing of your data. This can be for example the data protection authority in your country of residence. A list with all data protection authorities in the European Union can be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. We certainly encourage you to first contact us at [email protected].

g. Data Protection Officer

Our Data Protection Officer (DPO) is available to you as a contact person for all data protection-related concerns and for exercising your rights under Section (e.) above. We will inquire into any concerns you have and respond to your requests regarding your rights under data protection law to you in writing within one month of receipt of the request. That period may be extended by us two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, the information will be provided by electronic means where possible, unless otherwise requested by you. If you are not satisfied with our response, you can exercise your right to lodge a complaint referred to in Section e above.

XVI.    ADDITIONAL INFORMATION FOR USERS OF CALIFORNIA

This section applies only to California residents. Pursuant to the CCPA below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140(o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information, and the third-parties with whom we may share your Personal Information. As described further below, FDNA does not “sell” your Personal Information.

a. Personal Information we collect

We generally collect the following categories of Personal Information about you when you use our Websites:

  • Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices.
  • Commercial information such as records of products or services purchased, obtained, or considered by you.
  • Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Website, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
  • Your geolocation, to the extent you have configured your device to permit us to collect such information.
  • Inferences about your preferences, characteristics, behavior and attitudes.For more information about the Personal Information we collect and how we collect it, please refer to “What information we may collect” section above.

We collect your Personal Information for the business purposes described in the “Uses of the personal data we collect” above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The categories of third-parties with whom we may share your Personal Information are listed in the “Sharing information with third parties” section above.

b. California Privacy Rights

If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.

Access to Specific Information and Data Portability Rights

Subject to certain exceptions, if you are a California resident you have the right to request a copy of the Personal Information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:

  • The categories of Personal Information we have collected about you;
  • The categories of sources for the Personal Information we have collected about you;
  • Our business or commercial purpose for the information collection;
  • The categories of third parties with whom we share that Personal Information; and
  • The specific pieces of Personal Information we collected about you.

d. 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.

e. Non-Discrimination

We will not discriminate against you for exercising your right to know, delete, or opt-out of sales.

f. Opting-Out of Sale

In the preceding twelve months, we have not sold Personal Information as that term is generally understood. We do not sell Personal Information. In addition to the “Cookie Policy” description for opting out of interest-based advertising and controlling browser settings, California residents may also use the Digital Advertising Alliance’s tool to send requests under the CCPA for a web browser to opt out of the sale of Personal Information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/, or by downloading the DAA’s AppChoices mobile application opt-out here: https://www.privacyrights.info/appchoices.

g. Direct Marketing

If you are a California resident, you can request a notice disclosing the categories of Personal Information we have shared with third parties for the third parties’ direct marketing purposes. To request a notice, please submit your request by postal mail as described in the relevant section above.

Last updated: March 07, 2023.

 

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