Definitions: “Personal Data” means any information relating to an identified or identifiable natural person. “Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in. “Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in. “User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity. “Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
2.What Information We May Collect & Process
We collect different types of information from your use of our Website with your specific knowledge and consent. The processing is necessary for providing the Service in accordance with our Terms of Service and the processing of which is carried out in our legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.
We may Process the following categories;
Personal details: username or log in details; password; your name (in rare cases); area of interest (in rare cases) Demographic information: age group (to confirm); Contact details: email address; telephone (in rare cases) Location information: location data that describes the geographic location of your device (“Location Data”). Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Website.
3. What Information We Do Not Collect & Process
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business.
Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:
Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.
Children: The Services are not intended for use by children, especially those under 18. No one under the age of 13 should provide any Personal Information. We do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at email@example.com and request that we delete that child’s Personal Data from our systems.
4. How We Collect Information
We may collect User Information about you from the following sources:
4.1 User-provided Information - We may obtain your Personal Information when you provide it to us across our Services (e.g. register for site membership or create a profile or account on any part of the Services; perform search queries through the Website; contact us via email, telephone or by any other means. We may also collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us.
4.3 Content and Advertising information - If you choose to interact with any third-party content or advertising on our website, we may receive User Information about you from the relevant third party.
4.4 Third party information - We may collect or obtain your Personal Information from third parties who provide it to us. This may include third-party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third-party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Website, create a profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third- party services or other information available about you or collected from you on those services.
This may include but is not limited to: information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the website, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
5. How We May Use Your Information
The purposes for which we may Process User Information, subject to applicable law, include:
5.1 Operations - We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process the same solely in accordance with the directions provided by the applicable Client or User.
5.2 Improvements - We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, to develop new features, and functionality, providing personalized content to you and notifying you of changes to any of our Services.
5.2 Communications - Communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
6. Cookies, Similar Technologies and Online Behavioral Advertising
Tracking Technologies & Analytics-
Tracking technologies on the Services may be deployed by FMD and/or by our service providers, advertisers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
We and our partners (including but not limited to advertising partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third-party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or User Information and use the associated information related to aggregate content preferences to assist in our efforts to market services to you or the originating corporation(s). Various browsers may offer their own management tools for removing Local Storage. To manage Flash Local Shared Objects please click here.
Interest Based Advertising -
The FMD and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the website. OBA is also referred to as interest-based advertising. It is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
In collaboration with these third parties, we collect information about our visitors and users over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
Visitors may opt out of receiving interest-based advertising by advertising networks that may be delivered to them on our platform and other websites. For information about how to opt out of tracking methods for these entities and others, click here. These features will opt a Visitor out of many – but not all - of the interest-based advertising activities in which we or third parties engage. More information can be obtained by visiting the following websites http://www.aboutads.info/consumers; and http://www.networkadvertising.org/managing/opt_out.asp.For more details about OBA and opting out, see Section 14 below.
7. What Information We Disclose to Third Parties
We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Website, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
7.1 Third Parties - We work with third party service providers who provide website, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. We may disclose information to:
(i) any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
(ii) any relevant third-party provider, where our website use third party plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the website to provide you targeted advertising based upon your interests may be shared with the relevant third-party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
(iv) Some of our advertisers may use third party advertising service companies to serve advertisements, and perform related services when you interact with the Website. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Website. We also engage third party providers to assist with the segmentation of this data.
(v) We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from FMD with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.
7.2 Law Enforcement, Legal Process and Compliance - We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
7.3 Non Personally Identifiable Information - We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
8. Transfers of Information
Because of the international nature of our business, we may need to transfer your User Information to third parties as noted in Section 9 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. The FMD is committed to subjecting all Personal Information received from European Union (E.U.) member countries and Switzerland. Information collected through our website may be stored and processed in the United States, Europe, or any other country. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or European Economic Area, please note that we will not transfer information, including personal data, to a country outside of the European Union or European Economic Area.
We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
9. Data Security
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties. Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
10. Data Retention
11. Your Choices: What Can you Do to Control your Information?
You may directly take steps to change your preferences as follows:
Location Based Services - You may opt-out of having your Precise Location Data collected by The FMD at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).
Navigation Information - You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
OBA / Interest Based Advertising - The FMD is a member of the Digital Advertising Alliance (“DAA”) in the U.S., E.U. and Canada and uses third party assurance platforms to comply with the DAA principles. FMD strives to adhere to the self-regulatory organization principles for the DAA (US), the DAAC (Canada) and the EDAA (EU).
Visitors may opt out of receiving interest-based advertising by advertising networks that may be delivered to them on our platform and other websites. For information about how to opt out of tracking methods for these entities and others, click here. These features will opt a Visitor out of many – but not all - of the interest-based advertising activities in which we or third parties engage.
European Union and Switzerland residents should visit the European DAA by clicking here.
Canadian residents should visit the DAA of Canada by clicking here.
This will opt you out of many – but not all - of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party Sites provide visitors with the ability to opt-out of receiving interest-based ads on their Sites that you need to control through your settings on that Site. For example, to opt out of Google’s use of your online behavior for advertising purposes, visit Google’s Ad Settings page.
EU Residents - GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Website. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us (using the contact instructions in Section 14 below). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
California Residents - In accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Website. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request using the contact instructions in Section 14 below.
Do not Track Policy - Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. FMD does not act on “do not track” requests from your browser because, there is not yet a common understanding of how to interpret Do Not Track signals and this way, we are able to personalize your experiences on our Websites.
Privacy Settings - Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
14. How to Contact Us
Please contact us with any questions, comments or concerns about any of the information in this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at . If you are an EU resident, for matters relating to privacy and data protection, you may contact our Data Protection Officer by email at
. Last Update:May 25th 2018
For more information concerning your rights, please visit our Your Rights