Notice Effective January 1, 2020
K2 Integrity, operating through Financial Integrity Network, LLC (together with its affiliates, the “Company”), operates at website https://dolfinapp.finintegrity.com/ (“Site”). We are data controller for this Site.
- How We Use Personal Information. The Company and its third-party service providers use Personal Information only for business purposes, including to:
- set up your account and enable you to use the Site and, in case of an institution, to allow authorized individual users to participate in training and certification programs supported by the Site;
- tailor the content on our Site to the needs of our users;
- fulfill and respond to your subscription requests and inquiries, whether sent to us by email or via the Contact Us form on the Site;
- provide updates on industry news and events (which we refer to collectively as “FIN Alerts”);
- receive notifications, engage experts via FINQuiryTM tool, and invite other members of the Company’s community to join your financial integrity network;
- process subscription payments;
- communicate with you regarding our services and provide you with related customer service; and
- send you important information regarding the Site, changes to our terms, conditions and policies and/or other administrative information.
Third parties provide us with services such as website hosting, data analysis, payment processing, infrastructure provision, email delivery services, credit card processing, auditing services, and other similar services for the Site. To enable them to provide such services, we have agreed to provide them with access to your Personal Information on a need-to-know basis. If you would like specific information about our providers and the information they received, please contact us at firstname.lastname@example.org
- Other Information We Collect. “Other Information” is any anonymous information that does not reveal your specific identity or relate to you as an identifiable individual.
Other Information includes:
- browser information and log data;
- information collected through cookies, pixel tags and other technologies;
- demographic information and other information provided by you;
- aggregated information;
- physical location.
- Log Data. When you visit this Site, our servers automatically record information and data (the “Log Data”) your browser sends. This Log Data may include IP addresses, browser types (Firefox, Chrome etc.), browser versions, the search terms you use, date and time of your visit, and the pages on our Site that you visit.
- Security. The Company uses reasonable organizational, technical, and administrative measures to protect Personal Information under the Company’s control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure. You use the Site and provide us with information at your own discretion and risk. If you suspect or have reason to believe that your interaction with the Company is no longer secure, immediately notify us of the problem by sending an email to email@example.com or calling +1.202.558.0960.
In addition, our Site is hosted by Weebly, Inc. Weebly provides us with the online e-commerce platform that allows us to provide the Service to you. Your information, including Personal Information, may be stored through Weebly’s servers.
Further information about each of these service providers’ privacy policies may be found here:
- How You Can Access, Change or Suppress Your Personal Information. If you would like to request to review, correct, update, suppress or delete, or object to, restrict, or otherwise limit the Company’s use of, your Personal Information that has been previously provided to the Company, you can contact us at firstname.lastname@example.org or by calling +1.202.558.0960. In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from a Company database, or otherwise let the Company know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable and in accordance with applicable law.
- Retention Period. We will retain your Personal Information for as long as is necessary for the purposes listed above or longer where this is required by the law. Please contact us for further details of applicable retention periods.
We may keep an anonymized form of your information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
We will retain information in accordance with our clients’ instructions where we act on their behalf as a data processor.
- If you are located in the European Economic Area. The Company’s main administrative offices are based in the USA and that is where we process Personal Information collected through our Site. When you provide Personal Information to us, we request your consent to transfer that personal information to the USA. The USA does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the USA provide adequate protection for personal information. Although the laws of the USA do not provide legal protection that is equivalent to EU data protection laws, we safeguard your Personal Information by treating it in accordance with the provisions of GDPR. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Information in storage. We use secure transmission methods to collect Personal Information through this Site. We also enter into contracts with our data processors that require them to treat Personal information in a manner that is consistent with this Notice.
You have the right to be informed about our use of your Personal Information, and to correct any mistakes in the Personal Information we have collected and have such information erased. To exercise any of these rights, please contact us at email@example.com or by calling +1.202.558.0960.
- Complaint with a Supervisory Authority. You have the right to file a complaint concerning our processing of your Personal Information with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: http://ec.europa.eu/justice/article- 29/structure/data-protection-authorities/index_en.htm
In limited circumstances, California residents may have additional rights over personal information including:
The Right to Request More Information. You may have the right to request more information about how we have treated our personal information in the past 12 months, including:
- The categories of personal information we collected about you;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting that information;
- The categories of third parties with whom we shared that information; and
- The specific pieces of personal information we collected about you.
The Right to Request Access. You also may have the right to receive a copy of your personal information.
The Right to Request Deletion. Under certain conditions, you have the right to request that we delete your personal information.
How to Exercise these Rights. To submit a request to exercise these rights you may contact us as follows:
Verification. Before we can respond to your request, we will first need to verify your identity using personal information you recently provided to us. If we are not able to verify your request, we will contact you for more information. If we are unable to verify your identify after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
Designating an Authorized Agent. You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf.
Third-Party Marketing and Selling. We do not provide your information to third parties for their direct marketing purposes. We also do not intend to sell your personal information to third parties.
No Discrimination. We will not unlawfully discriminate against you for exercising any of these rights.