OVERVIEW

Richard Fleischman & Associates (“RFA”), RFA UK, Limited, RFA S.a.r.l. is committed to the security of all personal data collected, stored and processed within RFA systems. RFA has developed this Privacy Policy (this “Policy”) to advise you of the ways in which RFA collects, uses, shares and protects your information. Any person accessing, browsing or otherwise using a website where this Privacy Statement is posted (a “Site”) either manually or via an automated device or program, is a “User” for purposes of this Policy.

RFA, together with RFA UK, Limited and RFA S.a.r.l., are hereinafter referred to as “RFA.”

PERSONAL DATA WE COLLECT

During the course of conducting business operations, RFA collects, stores and processes specific personal data including, but not limited to:

  • Personal information regarding current, former and prospective employees for the purposes of business operations, performing human resource administration, recruitment, and maintaining contact with the individual employees.
  • Personal information regarding current, former and prospective clients and their personal data for the purposes of providing services and support, maintaining client relationships, business operations and ongoing development of business activities.
  • Personal information regarding our third parties, including vendors and service providers, and their personnel for the purposes of managing and maintaining business operations and business relationships with third parties.
  • Personal information from publically available resources in order to respond to inquiries or provide information related to business operations.

Collected personal data may include: names, work addresses, work email addresses, work telephone number(s), title, company name, general contact information.

HOW WE USE PERSONAL DATA COLLECTED

RFA uses the Information collected from Users to respond to Users’ questions and/or comments, market or provide products, services or information to Users, process Users’ purchases, or provide related account status to the applicable User. Personal information, non-personal information, and anonymous browsing information may be used to gather broad demographic information used in marketing, promotion, analytics, or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about Users of a Site. RFA also may use this Information to monitor Site performance and to make a Site easier and more convenient to use. RFA also may use Information collected from its Users to enforce its agreements with Users, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that RFA complies with applicable laws.

SHARING OF PERSONAL DATA

Personal Data will not be shared with third parties, except as provided below.

We may disclose Personal Data to the following categories of recipients:

  • external services providers;
  • subcontractors;
  • professional advisors;
  • public authorities and administrations;
  • clients or business partners of RFA;
  • affiliated companies of RFA.

RFA may disclose Personal Data in the following circumstances:

  • In the event of a legal request and/or investigation when, in our opinion, such disclosure is necessary to prevent crime or fraud, or to comply with any statute, law, rule or regulation of any governmental authority or any order of any court of competent jurisdiction;
  • If we outsource some or all of the operations of our business to third party service providers, as we do from time to time. In such cases, it may be necessary for us to disclose Personal Data to those service providers. Sometimes the service providers may process some Personal Data on behalf of and under the instructions of RFA. We restrict how such service providers may access, use, disclose, and protect that Personal Data;
  • In case of business transfers in the event of the sale or acquisition of companies, subsidiaries, or business units. In such transactions, Personal Data may be part of the transferred business assets but remain subject to the protections in any pre-existing privacy statement;
  • When we believe release is appropriate or necessary to conduct the company’s business, comply with the law, enforce or apply our policies and other agreements, or protect the rights, property or safety of RFA, our employees, or others.

In such circumstances, RFA ensures that Personal Data is kept secure from unauthorized access and disclosure.

USER CONSENT

With User consent, other than as set out above, Users will receive notice when personal information might go to third parties, and Users will have an opportunity to choose not to share the information.

ACCESS, CHANGE, DELETION OF DATA

Individuals whose personal information is covered by this Privacy Policy have the right to access the personal information that RFA maintains about them. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, amendment or deletion should be sent to: help@rfa.com.

CHILDRENS PRIVACY PROTECTION

RFA’s Site is not directed towards children under 13 years of age, and RFA does not knowingly collect any information from children under 13 years of age through any Site. If you are under 13 years of age, you are not permitted to submit any information to RFA through any Site.

SECURITY

RFA’s Site has commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of Information that is submitted to RFA and remains under RFA’s control. You should be aware, however, that RFA has no control over the security of other websites that you might visit or use, even when a link to those websites is available on or through the Site. If you share your Equipment or use Equipment that is accessed by the general public, remember to sign off and close your browser when you finish using the Site.

RFA makes no representations or warranties with regard to the sufficiency of its security measures. RFA shall not be responsible for any damages, including without limitation consequential damages, resulting from a lapse in compliance with this Policy as a result of a security breach or technical malfunction. Certain information may be transmitted to you by email. Although it is illegal to intercept or disclose such messages under U.S. Federal law, such transmissions are not secure. In addition, Users’ communications through a Site are, in most cases, viewed only by you and anyone to whom you address your message. As the operator of a Site, RFA may need to review or monitor your electronic mail and other communications through a Site from time to time as may be required by law. Therefore, you should not expect to have a right to privacy in any of your electronic communications through a Site.

In the event of a breach of the confidentiality or security of your personal information, RFA will notify you if reasonably possible and as reasonably necessary under applicable law so that you can take appropriate protective steps. RFA may notify you under such circumstances using the email address or addresses that it has on record for you. You should also take care with how you handle and disclose your personal information. Please refer to the U.S. Federal Trade Commission’s website for information about how to protect yourself against identity theft.

POLICY MODIFICATIONS AND CHANGES

RFA may update this Policy at any time by publishing an updated version here.

RIGHTS OF THIRD PARTIES

This Policy does not create rights enforceable by third parties.

NON-HR DATA RECOURSE, ENFORCEMENT AND LIABILITY

RFA commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Policy should contact RFA at: help@rfa.com.

With regards to personal information, or information collected in the context of an employment relationship, we will cooperate with the appropriate data protection authorities and comply with the advice of such authorities.

INFORMATION AND REQUESTS

For any information or requests concerning this Policy, please contact RFA using the below information:

Call: 212.867.4600

Email: help@rfa.com

Write:

Legal Department – Privacy

330 Madison Avenue

19th Floor

New York, NY 10017