The Forem services, including (without limitation) our customer website, client platform, and other interactive properties through which the services are delivered (collectively, the “Services”) are owned, operated, and distributed by Foremy Corp. (referred to in this Privacy Notice as “The Forem” or “we” and through similar words such as “us,” “our,” etc.). This Privacy Notice outlines the personal information that The Forem may collect, how The Forem uses and safeguards that information, and with whom we may share it.
The Forem encourages our clients, visitors, business associates, and other interested parties to read this Privacy Notice, which applies to all users. By using our Service or submitting personal information to The Forem by any other means, you acknowledge that you understand and agree to be bound by this Privacy Notice, and agree that The Forem may collect, process, transfer, use, and disclose your personal information as described in this Notice. Further, by accessing any part of the Service, you are agreeing to THE TERMS AND CONDITIONS OF OUR TERMS AND CONDITIONS (the “Terms and Conditions”). IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY NOTICE OR OUR TERMS AND CONDITIONS, PLEASE DO NOT USE ANY PORTION OF THE SERVICES OR REGISTER FOR AN ACCOUNT.
What personal information do we collect about you?
Personal information (also commonly known as personally identifiable information (PII) or personal data) is information that can be used to identify you, or any other individual to whom the information may relate.
The personal information that we collect directly from those registering for the Service, includes the following categories:
- Name and contact information (e.g. address, phone number, email);
- Billing Information (e.g. credit card, bank account, billing contact information);
- Purchase Information (e.g. current order/purchase information, purchase history);
- Account Information (e.g. login credentials for the Platform) Demographic Information (e.g. gender, race, or other information that you provide on in your Platform account);
- Personal information from social media or content accounts as described in the “What are the Sources of Personal Information Collected by The Forem” section below, as well as information you choose to link or post from your own social media accounts;
- Personal Information contained in User Generated Content (as defined and described in the next section);
- Company/employer information; Geographic or location information; Information contained in posts you may on the public forums and interactive features of the Services (e.g. comments, survey responses, reviews of the Services);
- Information in the “Cookies, Device Data, and How it is Used” Section below, the degree to which such information is defined as personal information under the laws of a particular jurisdiction;
- Other information that may be exchanged in the course of engaging with the Service. You will be aware of any subsequently collected information because it will come directly from you.
Collection of User Generated Content
We may invite you to post content on the Service, including your comments and any other information that you would like to be available on the Service, which may become public (“User Generated Content”). User Generated Content may include any of the following:
- your comments on any portion of the Services, including, but not limited to, comments/posts in Slack, chats during a meeting in Zoom, meeting notes in the networking hub, and comments on other public portions of the Services;
- certain elements of your profile (e.g. social media links, name, education, job title, and company), which are publicly available in your networking profile;
- your responses to voluntary surveys; reviews of any portion of the Services; or
- participation in public forums where applicable.
Note that some of the above items are always public, and for some items you have the option to make them public or private. Please be sure to modify your privacy setting appropriately, as allowed within the Service.
If you post User Generated Content, all of the information that you post will be available to authorized personnel of The Forem and may be made available to the public at our discretion. You expressly acknowledge and agree that we may access in real-time, record, and store archives of any User Generated Content on our servers to make use of them in connection with the Service. If you submit a review, recommendation, endorsement, or other User Generated Content through the Service, or through other websites including Facebook, Instagram, Google, Yelp, and other similar channels, we may share that review, recommendation, endorsement, or content publicly on the Service.
What are the sources of personal information collected by The Forem?
When providing personal information to The Forem as described in this Notice, that personal information can be collected directly from you. We collect information from you through several means, including through 1.) your use of the Services and platform or processing any specific orders outside of your regular use of the Services; 2. requests you submit to The Forem; 3.) your participation in sweepstakes, contests, or surveys; 4.) reviews you submit on the Services; and 5.) account registration.
In certain limited circumstances, third-party service providers may collect information on behalf of The Forem, though such collection will always be within the context of the Services. The Forem may also automatically collect certain information as described in the section titled “Cookies, Device Data, and How it is Used,” the degree to which the information in that section is considered personal information. In particular, we may collect personal and non-personal information through the following additional channels:
- Our own cookies on our website;
- 3rd party cookies on our website;
- Social media networks;
- 3rd party software applications.
How does The Forem use personal information?
Subject to the terms of this Privacy Notice, The Forem uses the above-described categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the following purposes:
- to administer the Services to you;
- to respond to your requests for information or assistance;
- to distribute communications relevant to your use of the Services, such as system updates or information about your use of the Services;
- as may be necessary to support the operation of the Services, such as for billing, account maintenance, and record-keeping purposes; to send to you The Forem solicitations, product announcements, and the like that we feel may be of interest to you (you may “opt out” of receiving these marketing materials);
- to provide information to you about the Service or products;
- to notify you about changes to this Privacy Notice;
- to allow you to participate in surveys or provide testimonials;
- to carry out The Forem’s obligations and enforce rights arising from any contracts between you and The Forem;
- in other manners after subsequent notice is provided to you and/or your consent is obtained, if necessary.
The Forem does not sell, re-sell, or distribute for re-sale your personal information.
How does The Forem share your Personal Information with third parties?
We may provide any of the described categories of personal information to The Forem employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Service to you. In such circumstances, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this Privacy Notice. Third parties receiving personal information may include:
- Third-party vendors or service providers providing crucial services and necessary to provide the Service;
- Business partners, contractors, channel partners, or other affiliated entities;
- Government agencies or other parties in response to legal process or other requests, where permitted by law.
We will not share your personal information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.
In addition, we may release personal information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law; (ii) to enforce any provision of the Terms of Service , protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user, or protect the public welfare; (iii) when disclosure is required to maintain the security and integrity of the Service, or to protect any user’s security or the security of other persons, consistent with applicable laws (iv) to respond to a court order, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; or (v) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets.
How does The Forem use direct marketing communications?
We may communicate with you using email, SMS, facsimile machines, or calling machines as part of our effort to market our products or services, administer or improve our products or services, or for other reasons stated in this Privacy Notice. You have an opportunity to withdraw consent to receive such direct marketing communications, as permitted by law.
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by submitting a request through the following Email Unsubscribe Form, or by one of the following means:
- using the UNSUBSCRIBE link in any email communication you may have received;
- noting your preferences at the time you register your account with the Service on our website;
- logging into your account settings and updating your preferences; or contacting us using the contact information provided below.
We may use third party marketing providers to market or promote our products and services. If you no longer wish to receive emails, SMSs, facsimile messages, or other communications from such third parties, you are responsible for contacting the third party directly.
How long does The Forem retain your personal information?
The Forem will retain your personal information only for as long as is necessary for the purposes set out in this Notice. We will retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
The Forem will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites and/or Portals, or we are legally obligated to retain this data for longer periods.
Cookies, Device Data, and How it is Used
When you use our Service, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Service, and your network location. The Forem uses aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Service and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends. Specifically, we may automatically collect the following information about your use of Service through cookies, web beacons, and other technologies:
- domain name
- browser type and operating system
- web pages you view
- links you click
- IP address
- the length of time you visit the Sites, Portals, and/or Services
- the referring URL or the webpage that led you to the Sites
We may also collect information regarding application-level events, such as crashes, and associate that temporarily with your account to provide customer service. In some circumstances, we may combine this information with personal information collected from you (and third-party service providers may do so on behalf of us).
Third Party Ad Networks
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will remove you from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through the Service or on other third party websites. Even if you opt-out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page, you may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt-out on the DAA or NAI websites, your opt-out action may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at https://www.networkadvertising.org/.
State Privacy Rights for Residents of California, Colorado, and Virginia
If you are a resident of the states of California, Colorado, or Virginia, your state law may provide you with certain rights with regard to your personal information. These rights may include confirmation and access, the right to know about selling or sharing, correction or deletion, data portability, limitations on use and disclosure, or the right to opt out of selling or sharing.
Throughout this Privacy Notice you will find information required by such state laws regarding the categories of personal information collected from you, the purposes for which we use personal information, and the categories of third parties your data may be shared with. This information is current as of the date of the Notice and is applicable in the 12 months preceding the effective date of the Notice.
While The Forem may not currently be subject to all of these state laws, The Forem is committed to supporting your rights with regard to your personal information as well as fulfilling The Forem’s commitment to any California, Colorado, or Virginia based partners or businesses.
As a resident of California, Colorado, or Virginia, your state law provides you the ability to make inquiries regarding your personal information. Specifically, you have the right to request disclosure about the collection and use of your personal information over the past 12 months, including:
- The categories of personal information collected about you.
- The categories of sources for the personal information collected about you.
- The business or commercial purpose for collecting your personal information.
- The categories of third parties with whom your personal information was shared.
- The specific pieces of personal information collected about you.
- If your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed.
- If your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold.
The Forem does not sell, re-sell, or distribute for re-sale your personal information.
You may have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions. The Forem will inform you of such exceptions in its response to your request. If The Forem is selling, re-selling, or otherwise distributing your personal information in exchange for monetary compensation, advertising, or other purposes, you may have the right to opt-out or limit such sales or disclosures. Finally, you have the right to not receive discriminatory treatment by The Forem or any business for exercising any of the rights provided under your state law.
If we receive a request from you, we will first make a determination regarding the applicability of your state’s law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by The Forem and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through contact information that we have on file, not the contact information submitted to make the request). The Forem will respond to your request within the time required by law (typically 45 days). If for any reason your request is denied, The Forem will provide a “no action” explanation within the time required by law (typically a 45-days).
If you are a California resident, your rights are established under the California Consumer Privacy Act (“CCPA”), as amended and replaced by the California Privacy Rights Act (“CPRA”) (hereinafter collectively referred to as “CPRA”). The proceeding paragraphs provide information regarding your methods of contacting The Forem to exercise your rights under CPRA.
As a resident of the State of California, you may make these requests twice in a 12-month period, free of charge. The Forem may charge a reasonable fee for any request that exceeds this limitation. Further, The Forem may charge a reasonable fee or deny any requests that are manifestly unfounded and excessive.
Your rights as stated here can also be exercised by an authorized agent on your behalf. The Forem will follow the standards set by the Attorney General of California regarding designation of an authorized agent to exercise rights under CPRA. You may review information available through from the Attorney General regarding how an individual can be designated as an authorized agent under CPRA.
In addition to CPRA, California Civil Code Section 1798.83 permits users of the Website who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as described here.
If you are a resident of the Commonwealth of Virginia, your rights are established under the Consumer Data Protection Act (“CDPA”). The proceeding paragraphs provide information regarding your methods of contacting The Forem to exercise your rights under CDPA.
As a resident of the Commonwealth of Virginia, you may make these requests twice in a 12-month period, free of charge. The Forem may charge a reasonable fee for any request that exceeds this limitation. Further, The Forem may charge a reasonable fee or deny any requests that are manifestly unfounded and excessive. If The Forem is not able to fulfill your request, you will be provided instructions regarding your right to appeal that decision.
If you are a resident of the State of Colorado, your rights are established under the Colorado Privacy Act (“CPA”). The proceeding paragraphs provide information regarding your methods of contacting The Forem to exercise your rights under CPA.
As a resident of the State of Colorado, you may make these requests once in a 12-month period, free of charge. The Forem may charge a reasonable fee for any request that exceeds this limitation. Further, The Forem may charge a reasonable fee or deny any requests that are manifestly unfounded and excessive. If The Forem is not able to fulfill your request, you will be provided instructions regarding your right to appeal that decision. You will be informed of the result of such appeal within 45 days.
International Data Transfer
If you are located outside the United States, in particular if you are located in Canada, Brazil, the European Union (“EU”), the European Economic Area (“EEA”), New Zealand, the Republic of South Africa, Switzerland, the United Kingdom, or other countries with similar data privacy laws, please note that we and our servers are located in the United States. Any information that you provide to us may be transferred to and processed in the United States or other countries around the world where we do business. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your personal information than in your country, we will make efforts to protect your information in accordance with requirements applicable to the law in your particular jurisdiction and take steps to only share with third parties that offer similar protection. By using our Service, you unambiguously consent to your information being collected, processed, used, and transferred as disclosed herein.
Data Privacy Rights (European Union and Similar Jurisdictions)
If you are located in the EU or a jurisdiction with a similar law, the GDPR or its local equivalent may grant you certain rights under the law. In particular, the right to access, correct, and delete the personal information we hold about you. The Forem will retain your personal information for the length of time you engage with our services as described in the retention section of this Notice, until you request deletion of such personal information. The Forem is considered the Data Controller (or equivalent distinction) with regard to your personal information. You can find our contact information as described herein or in other portions of the Service.
In certain circumstances, you have the following data protection rights:
- The right to access, update, or delete the personal information we have about you.
- The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your personal information.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us as described in order to allow us to resolve the matter. In addition, if you are located in the EEA, you may submit a complaint regarding the processing of your personal information to a regulatory authority. The following links may assist you in finding the appropriate regulator:
- In the UK, you have the right to lodge a complaint with the Information Commissioner: www.ico.org.uk
- In South Africa, you have the right to file a complaint with the Information Regulator: https://www.justice.gov.za/inforeg/index.html
- In Switzerland, you have the right to contact the Federal Data Protection and Information Commissioner (FDPIC) FDPIC
- In the EU, you have the right to lodge a complaint with your local data protection authority. To find your local authority, you can check the list on the European Data Protection Board website: https://edpb.europa.eu/about-edpb/board/members_en
- In Brazil, you have the right to lodge a complaint with the National Data Protection Authority (ANPD) (Note: Jan 2021 – not yet established)
- In Argentina, you have the right to contact the National Directorate for Personal Data Protection PDP
- In Canada, you have the right to lodge a complaint with the Office of the Privacy Commissioner in Canada: Office of the Privacy Commissioner in Canada
- In Japan, you have the right to contact the Personal Information Protection Commission. https://www.ppc.go.jp/en/
- In Australia, you have the right to lodge a complaint with the Privacy Commissioner Australian Information Commissioner
- In New Zealand, you can contact the Privacy Commissioner’s office www.privacy.org.nz
Legal Basis for Processing
If you are located in the EEA or a jurisdiction that requires a similar legal basis for processing, our legal basis for collecting and using the personal information described in this Notice depends on the personal information we collect and the specific context in which we collect it.
We may process personal information because:
- We need to perform a contract with you;
- You have given us consent to do so;
- The processing is in our legitimate interest to offer the Service, when that legitimate interest is not overridden by your rights;
- To comply with the law.
Where personal information is processed based on consent, you may have the right to withdraw such consent at any time. To do so, please contact us as described in this Notice. If there is a different legal basis that would permit us to continue processing your personal information after withdrawing consent, we will notify you of that legal basis at the time of your request.
Third Party Advertisers
Information Security and User Responsibility
We employ industry-standard security measures designed to protect the security of all information submitted through the Service. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.
Users of the Service are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Service. In order to protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if any breach of security is suspected.
The Service may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and The Forem is not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites before providing any personal information.
You hereby acknowledge and agree that The Forem is not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release The Forem from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites.
The Service is not intended for children under the age of 13, and The Forem does not knowingly collect the personal information of children under the age of 13.
Changes to this Privacy Notice
The Forem reserves the right to modify this Privacy Notice from time to time in order that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Privacy Notice, The Forem will post the revised Notice on our website. This Privacy Notice was last modified as of February 25, 2022.
If you have any questions or comments about this Privacy Notice or the Service provided by The Forem, please contact us at email@example.com.