Privacy Policy

FIRNEO, INC. PRIVACY POLICY

Last Updated: 08/31/2020

This privacy policy (“Policy”) describes how FIRNEO, INC. and its related companies (“Company”, “We”, “Our”, “Firneo”) collect, use and share personal information of consumer users of this website, www.Firneo.com and other Firneo websites, mobile applications, or Services (collectively, the “Services”). This Policy also applies to any of our other websites that post this Policy. This Policy does not apply to websites that post different statements.

PRIVACY IS IMPORTANT TO FIRNEO

Here at Firneo, your privacy is important to us and this policy provides an overview of how we employ, disclose, and process your personal data.

CHANGES TO THIS POLICY

We may amend this policy at any time by posting a revised version on our Services. The revised version will be effective at the time we post it.

WHAT WE COLLECT

We get information about you in a range of ways.

Information You Give Us. We collect your‎ name, postal address, email address, phone number, fax number, username, password, demographic information  as well as other information you directly give us on our Services.

Information We Get From Others. We may get information about you from other sources. We may add this to information we get from these Services.

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Services, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services.

Cookies. We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services.    This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

USE OF PERSONAL INFORMATION

We use your personal information as follows:

  • We use your personal information to operate, maintain, and improve our sites, products, and Services.
  • We use your personal information to process and deliver contest entries and rewards.
  • We use your personal information to respond to comments and questions and provide customer service.
  • We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • We use your personal information to communicate about promotions, upcoming events, and other news about products and Services offered by us and our selected partners.
  • We use your personal information to link or combine user information with other personal information.
  • We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • We use your personal information to provide and deliver products and Services customers request.
  • As part of our Services, we may use your personal information for purposes of serving you content and/or providing you with opportunities to meet and interact with other members and users of our Services.

SHARING OF PERSONAL INFORMATION

We may share personal information as follows:

  • We may share personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
  • We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • We may share personal information for legal, protection, and safety purposes.
    • We may share information to comply with laws.
    • We may share information to respond to lawful requests and legal processes.
    • We may share information to protect the rights and property of Firneo, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may share information with those who need it to do work for us.
  • We may share personal information as a necessary part of our Services.
    • In order to make introductions and connect you to other members and users of our Services before, during, or after events as well as to connect you to other members and users of our Services with similar interests for networking and purposes,
    • To include you in our user and member directory, permitting other users and members to see certain of your contact and other personal information.
    • In order to allow you to communicate with other members and users of our Services about various projects, such as collaborating on content.

We may also share aggregated and/or anonymized data with others for their own uses.

INFORMATION CHOICES AND CHANGES

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you, including but not limited to emails informing you of events and other items of interest based on information you provide us as to your areas of interest.

You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

You can typically remove and reject cookies from our Services with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Services works for you.

THIRD PARTY PRIVACY POLICIES

Users of our Services may access third party websites and or utilize third party Services that are packaged within or supplied by and through the Services, subject to the terms and conditions and privacy policies of such third parties. Users acknowledge and agree that Firneo is not responsible for any third party terms and conditions, nor for privacy policies and use of information by such third parties. Among others, we may share your Personal Information with the following third-party Services, such as social media platforms and analytics services, which we reserve the right to modify or expand at any time: Google Analytics, Heap, LogRocket, LinkedIn, and Facebook, etc.

MARKETING

We do not sell your personal data to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad programs, you can send an email to legal@firneo.com

HOW WE PROTECT YOUR INFORMATION

We are committed to making sure your information is protected and have selected third-party vendors that help keep your personal data safe. Unfortunately, we do not control these third parties and therefore cannot guarantee complete security.  We employ commercially reasonable physical and electronic safeguards to keep your information safe where possible. Accordingly, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk.

COOPERATION WITH LAW ENFORCEMENT

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to: comply with the law or a court order; cooperate with law enforcement; enforce or apply our Terms of Services and other agreements; or protect the rights, property, or safety of Firneo, our employees, our users, or others.

BUSINESS TRANSFERS

We may choose to buy or sell assets. In these types of transactions, company data is a business asset that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, company data which may include your personal information could be one of the assets transferred to or acquired by a third party. By accepting this Privacy Policy, as outlined above, you consent to any such transfer.

DATA RETENTION

If you delete your information from any of the Services including but not limited to any mobile applications or request that your information be deleted, we still may retain some information that you have provided to us to maintain Firneo or to comply with relevant laws.

AGGREGATED PERSONAL DATA AND NON-PERSONAL INFORMATION

We may share or disclose aggregated personal data or non-personal information with service providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the Services. These service providers and other persons may also share with us aggregated non-personal information that they have independently developed or acquired. Additionally, we may combine aggregate information from the pixel tags, web beacons, and cookies with similar data we collect from other visitors to help us improve our Services. When doing so, we use commercially reasonable efforts to ensure that the any aggregated information cannot be linked back to you.

INTERNATIONAL USERS AND VISITORS

Due to requirements of the General Data Protection Regulation or other applicable international privacy laws or regulations, please be aware that Firneo is hosted in the United States. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Services, which is governed by US law, you are transferring your Personal Information to the United States and you consent to that transfer.

EU and Swiss residents: Please bear in mind that we may transfer your Personal Information to the United States where data protection is not deemed adequate under applicable data protection law.

CALIFORNIA PRIVACY RIGHTS

Access

You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification. You may only make such requests twice (2) per every twelve (12) months.

Deletion

You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Exercising Your Rights

To exercise the access and deletion rights described above, please submit a request to us by either:

  • Emailing us at legal@firneo.com
  • Calling us at (646) 809-0521

Please note that Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA.

Verifying Your Request

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Your California Privacy Rights under the “Shine the Light” Law

Pursuant to Section 1798.83 of the California Civil Code (a separate law from the CCPA), residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of Services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via legal@firneo.com

CHILDREN’S PERSONAL INFORMATION

We are committed to protecting the privacy of children. The Services are not intended for children and we do not intentionally collect information about children under 13 years old. The Services do not collect Personal Information from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the Services and/or the Services, please contact us at legal@firneo.com and we will take required steps to delete such information and (or) delete her account.

Due to requirements of the General Data Protection Regulation, you shall be at least 16 years old in order to use the Services. To the extent prohibited by applicable law, we do not allow use of the Services by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the Services, please contact us at legal@firneo.com and we will take steps to delete such information and/or delete the account.

CONTACT INFORMATION. We welcome your comments or questions about this privacy policy. You may also contact us at our postal and email address:

Firneo, Inc.

99 Wall Street #3003

New York, NY 10005

legal@firneo.com

(646) 809-0521