Privacy Policy

Definitions and Legal References​

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Anonymized Identifier

Data used to identify unique accounts, which can include third party authentication token IDs and randomized strings.

Anonymized Usage Data

Information collected automatically through FISE (or third-party services employed in FISE), which can include:

• the IP addresses or device type of the computers utilized by the users who use FISE
• the time of the request
• the method utilized to submit the request
• the size of the file received in response
• the numerical code indicating the status of the server's answer (successful outcome, error, etc.)
• the features of the browser and the operating system utilized by the user
• the various time details per visit (e.g., the time spent on each page within the Application)
• the details about the path followed within the FISE application with special reference to the sequence of pages visited
• other parameters about the device operating system and/or the user's IT environment

User

The individual using FISE Portal who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller, as described in this privacy policy.

Data Control Facilitator

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of FISE. The Data Control Facilitator, unless otherwise specified, is FISE.

FISE (or this Application)

The means by which the data of the user is collected and processed.

Service

The service provided by FISE as described in the relative terms (if available) and on this site/application.

Cookies

Small sets of data stored in the User's device.

Legal Entity Name of FISE Platform(s) ​

FISE Technologies Inc., is referred to as “FISE” in this policy, also known as the Data Control Facilitator.

572, 1007 N Orange St. 4th Floor , Wilmington, DE, US, 19801

Contact email: nara@fiseportal.com

Email collection​

Email addresses via marketing communication or FISE application registration are collected with user permission for communication and registration purposes only. FISE does not share or sell user email addresses.

Types of Data Collected​

Types of data that FISE collects, by itself and/or through third parties:

• Anonymized identifiers
• Anonymized usage data

Data required by FISE:

• Anonymized unique strings from third party authentication providers or clients

User identifiable data from third party sources used to personalize user accounts on the user's client side is not collected or stored by FISE.

Regarding anonymized usage data, details on each type of anonymized usage data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the data collection while using the FISE application. Anonymized usage data is collected automatically when using FISE products and platform(s).

Any personal data collected by FISE and/or its affiliates is permissioned by user-controlled terms and consent.

FISE products and platform(s) do not use cookies to track users on its services.

Mode and Place of Processing the Data​

Methods of Processing​

FISE, the Data Control Facilitator, takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of user data while on the users’ client-side. The data processing is carried out using computer software following organizational procedures and modes strictly related to the purposes indicated to the user while using the FISE application.

With user permission and consent, the anonymized data may be accessible to authorized persons working at FISE (administration, sales, marketing, legal, system administration), or external parties such as third-party technical service providers, communications agencies appointed, if necessary, as data processors by FISE, only when the user has given authorized permission.

Legal Basis of Processing​

FISE may process personal data relating to users if one of the following applies:

• Users have given their consent for one or more specific purposes
• Processing is necessary to comply with a legal obligation to which FISE is subject
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in FISE

FISE will help clarify the specific legal basis that applies to the processing, and whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place​

The data is processed by FISE's software on user devices. There is no user specific data that is processed on servers that can identify the user.

The users' anonymized usage data is processed on third party offices and premises as well as cloud setups managed by the third party. This is only if the user permits use of anonymized data.

Retention Time​

Anonymized usage data shall be processed and stored for as long as required depending on the purpose of collection.

Furthermore, FISE may be obliged to retain anonymized usage data for a longer period whenever required for the performance of legal obligations or upon order of an authority.

Once the retention period expires, anonymized usage data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

The Purposes of Processing​

The data concerning the user is collected to allow FISE to provide its services, as well as for the following purposes: analytics, tag management, registration and authentication, displaying content from external platforms, and traffic optimization and distribution.

Users can find further detailed information about such purposes of processing and about the specific anonymized usage data used for each purpose in the respective sections of this document.

The Rights of Users​

Users may exercise certain rights regarding their data processed by FISE.

Users have the right to do the following if they can identify their anonymized data. As FISE does not store personal data, the following rights may not be technically enforceable since they are based on storage of personal data, which FISE does not do:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their anonymized data.
• Object to processing of their data. Users have the right to object to the processing of their personal data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their data. Users have the right to learn if any forms of personal data are being processed by FISE, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their personal data and ask for it to be updated or corrected.
• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, FISE will not process their data for any purpose other than storing it.
• Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from FISE.
• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user's consent, on a contract which the user is part of, or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

How to Exercise these Rights​

Any requests to exercise user rights can be directed to FISE through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by FISE within 30 days.

Additional information about data collection and processing​

Legal Action​

The user's anonymized usage data may be used for legal purposes by FISE in court or in the stages leading to possible legal action arising from improper use of FISE or related services. The user is made aware, through this privacy policy, that FISE may be required to reveal personal data upon request of public authorities.

Additional Information About User's Anonymized Usage Data​

In addition to the information contained in this privacy policy, FISE may provide the user with additional and contextual information concerning services or the collection and processing of it upon request.

System Logs and Maintenance​

For operation and maintenance purposes, FISE and any third-party services may collect files that record interaction with FISE or other usage data for this purpose.

Information not Contained in this Policy​

More details concerning the collection or processing of anonymized usage data may be requested from FISE at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” Requests are Handled​

FISE automatically respects “Do Not Track” requests as we do not store any user personal data. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies. However, it is intended that FISE only shares anonymized data with third parties.

Changes to this Privacy Policy​

FISE reserves the right to make changes to this privacy policy at any time by giving notice to users via email including a URL link to this page. It is strongly recommended to check this page often, referring to the date of the last modification listed.

Should the changes affect processing activities performed based on the user’s consent, FISE shall procure updated consent(s) from the user, where required.

Legal information​

This privacy statement has been prepared based on provisions of multiple legislations such as:

• General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)
• Fair Credit Reporting Act (FCRA)
• Bank Secrecy Act’s Anti-Money Laundering / Know Your Customer (BSA AML/KYC)

This privacy policy relates solely to FISE Application(s), Products, Services, and Platform(s).