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 publicly 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;
- 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. RFA commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
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
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.
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. RFA is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). 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
In compliance with the Privacy Shield Principles, RFA commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact RFA at: email@example.com.
RFA has further committed to refer unresolved Privacy Shield complaints to the EU DPA through the United States Council for International Business (“USCIB”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.uscib.org/ for more information or to file a complaint. The services of USCIB are provided at no cost to you.
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.
Personal Data will not be transferred to third parties outside of the categories of recipients and circumstances set forth in the Sharing of Personal Data section above. As such, the Privacy Shield provision regarding liability for the actions of agent processors does not apply to RFA.
Information and Requests
For any information or requests concerning this Policy, please contact RFA using the below information.
Legal Department – Privacy
330 Madison Avenue
New York, NY 10017