FinancialCAD Corporation, including all of its Affiliates, specifically FINCAD Europe Limited, and FINCAD UK Limited (individually and collectively, as relevant, “FINCAD”, “we” or “us”) will collect and process your Personal Data and other information in relation to your dealings with us, including through your use of FINCAD websites (each a “Website”). “Affiliate" means, in relation to any person, a subsidiary of that person or a holding company of that person or any other subsidiary of that holding company. This privacy statement explains how FINCAD will manage your Personal Data, why we use it, and how you may contact FINCAD in relation to the use of your Personal Data.
Types of Information We Collect
We collect information, which includes Personal Data, about directors, officers, employees, agents and / or authorised signatories of FINCAD’s customers, prospective customers, suppliers, service providers, vendors and other commercial partners (“Individuals”) for the purposes of and in connection with FINCAD’s dealings with those relevant commercial entities. You may be such an Individual.
Personal Data means any information which FINCAD has or obtains, or which you provide to FINCAD, and may include your name, address, email address, phone number(s), title or position, from which you can be directly or indirectly personally identified. We may also collect data that includes the name of pages (URLs) that you view on our Websites and whether or not you open or click-through to read marketing emails sent to you.
FINCAD also collects certain statistical and other analytical information collected on an aggregate basis relating to all visitors to the Website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of the Website. We collect this information to help us monitor traffic and enhance your experience of the Website.
What are cookies?
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
We deploy the following technologies on our website. These services may set cookies in your browser if your privacy settings allow it to do so. The primary services we use to track activity are Marketo and Google Analytics.
In addition to these, we deploy some Geographic IP detection. This data is not stored nor is it used to identify specific user data - however your geographic IP location may be used to dynamically serve you content relevant to your location.
||The DoubleClick advertising platform is operated by Google to create, transact, and manage digital advertising.
||LinkedIn's marketing solutions enable marketers to deliver targeted ads its users.
||LiveRamp uses anonymous customer data to improve customer interactions on any channel and device.
||Beeswax connects to all the major exchanges and normalizes the supply into a single, clean OpenRTB stream across display, banners, and video
||Google Analytics is a freemium web analytics service offered by Google that tracks and reports website traffic.
||Marketo automates demand generation campaigns to track manage and qualify leads.
How We Obtain Your Information
We will obtain some of your Personal Data directly from you where we interact directly with you in the course of our business. We may also obtain Personal Data directly from you through the Website, such as (i) when you sign up to our mailing list, (ii) when you sign up to receive marketing materials, download a white paper or attend a webinar, or (iii) when you apply for a position with FINCAD.
This information may also be collected indirectly from a variety of sources, such as the commercial entity which you represent, and publicly available sources including media reports and social media, such as LinkedIn, with which you interact.
Use of Personal Data and Basis of Processing
We will use the Personal Data where necessary:
- where use is for a legitimate purpose of ours, including:
- for the purposes of managing our contracts and relationships with our existing and prospective customers, suppliers, service providers, vendors and other commercial partners;
- for day to day operational and business purposes, including recruitment purposes;
- board reporting and management purposes;
- in the event of a merger, reorganisation or disposal of, or a proposed merger, reorganisation of disposal of the whole or part of the business of FINCAD;
- to take advice from our external legal and other advisors;
- for compliance with our legal obligations, including:
- compliance with applicable tax and regulatory reporting obligations;
- where we are ordered to disclose information by a court with appropriate jurisdiction;
- where necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- where you have consented to the use of your Personal Data for a particular purpose, which will be made clear at the time your consent is obtained. If you give consent for us to use your Personal Data for particular purposes, you have the right at any time to withdraw consent to the future use of your Personal Data for some or all of those purposes by writing to the address specified below.
Applicants for jobs
Where you, or a third party recruitment agent acting for you, provides us with your CV and other Personal Data, we will use that information solely for the purposes of considering your application for a position with FINCAD, including to check your references. If you are a successful candidate, the Personal Data we obtain during the recruitment process will be held on your personnel file, which will be subject to our separate employee privacy statement.
Sharing Personal Data
We will not disclose any Personal Data to any third party, except as outlined above and / or as follows:
- to enable FINCAD to carry out the obligations under and enforce its contracts with its customers, suppliers, service providers, vendors and other commercial partners;
- to anyone providing a service to FINCAD or acting as FINCAD’s agent, as data processors, for the purposes of providing services to FINCAD and on the understanding that they will keep the Personal Data confidential;
- where we need to share Personal Data with our auditors, and legal and other advisors;
- to any (or any proposed) assignee, transferee, or successor in title to the whole or any relevant part of FINCAD’s business, and their respective officers, employees, agents and advisers; and
- the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of FINCAD’s regulators.
Personal Data may be transferred outside the European Economic Area (the “EEA”) in connection with the uses described above and / or as otherwise required or permitted by law.
Many of the countries outside the EEA will be ones which the European Commission has approved (which includes Canada, where FINCAD is headquartered, for most Personal Data), and will have data protection laws which are the same as or broadly equivalent to those in the European Union. However, some transfers may be to countries which do not have equivalent protections, and in that case FINCAD shall use reasonable efforts to ensure any transfers will be done in accordance with applicable data protection laws.
Third Party Providers of Information
We may obtain Personal Data relating to Individuals from someone other than that Individual, such as his / her employer or a recruitment agent. FINCAD will rely on the person providing the information to ensure that it will only do so in accordance with applicable data protection laws, and that it will ensure that before doing so, the Individuals in question are made aware of the fact that FINCAD will hold information relating to them and that it may use it for any of the purposes set out in this privacy statement, and where necessary that it will obtain consent to FINCAD’s use of the information.
Recipients of the Personal Data
In any case where we share Personal Data with a third party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Updates to Personal Data
We will use reasonable efforts to keep Personal Data up to date. However, you will need to notify us without delay in the event of any change in your personal circumstances, or those of the others mentioned above, so that we can keep the Personal Data up to date.
Retention of Personal Data
We are obliged to retain certain information to ensure accuracy, to help maintain quality of service, for legal and regulatory purposes, and for legitimate business purposes.
Information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal and regulatory purposes, and for legitimate business purposes.
Your Rights in Relation to Personal Data
You may at any time request a copy of your Personal Data from us. This right can be exercised by writing to us at the address specified below.
You also have the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of Personal Data, can be obtained by writing to us at the address specified below.
In any case where we are relying on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to the address specified below.
Where we are relying on a legitimate purpose of FINCAD or a third party recipient of the Personal Data, in order to use and disclose Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, we will cease to use and process the Personal Data for that purpose unless we can show there are compelling legitimate reasons for us to continue or we need to use the Personal Data for the purposes of legal claims.
You also have the right to lodge a complaint about the processing of your Personal Data by us with your local data protection supervisory authority.
Contacting the FINCAD Group
Any questions or concerns regarding the use of your Personal Data by FINCAD and / or the exercise of your rights should be addressed to us by emailing firstname.lastname@example.org with the subject line: My Data.
Last updated May 23rd, 2018