PRIVACY POLICY

LAST UPDATED 8/5/20

INTRODUCTION

Fulcrum Biometrics, Inc. (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website fulcrumbiometrics.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data

Identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Site, such as online chat. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Financial Data

Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor, Amazon Payments, Authorize.Net, PayPal, and you are encouraged to review their privacy policy and contact them directly for responses to any questions you may have.

Facebook Permissions

The Site may by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

Data From Social Networks

User information from social networking sites, such as Facebook, Google+, Instagram, Pinterest, Twitter, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks.

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

Data From Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

  • Administer sweepstakes, promotions, and contests.
  • Assist law enforcement and respond to subpoena.
  • Compile anonymous statistical data and analysis for use internally or with third parties.
  • Create and manage your account.
  • Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.
  • Email you regarding your account or order.
  • Enable user-to-user communications.
  • Fulfill and manage purchases, orders, payments, and other transactions related to the Site.
  • Generate a personal profile about you to make future visits to the Site more personalized.
  • Increase the efficiency and operation of the Site.
  • Monitor and analyze usage and trends to improve your experience with the Site.
  • Notify you of updates to the Site.
  • Offer new products, services, and/or recommendations to you.
  • Perform other business activities as needed.
  • Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  • Process payments and refunds.
  • Request feedback and contact you about your use of the Site.
  • Resolve disputes and troubleshoot problems.
  • Respond to product and customer service requests.
  • Send you a newsletter.

DISCLOSURE AND INTERNATIONAL TRANSER OF YOUR PERSONAL INFORMATION

We may disclose your personal information, where reasonably necessary for the various purposes set out above:

  • to the other members of the Fujitsu group of companies;
  • to your colleagues within the organization that you represent;
  • to service providers who host our web services or other information technology systems or otherwise hold or process your information on our behalf, under conditions of confidentiality and security required by law;
  • business partners, channel partners, service partner, agents, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • to a person who takes over our business and assets, or relevant parts of them; or
  • in exceptional circumstances:
    • to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
    • where we are required by law to disclose.

These disclosures may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area, you should be aware that this may include transfers to countries outside the European Economic Area, which have not been determined by the European Commission to have an adequate level of data protection. In those cases, where we transfer your personal information to other members of the Fujitsu group or our service providers, we will ensure that our arrangements with them are governed by relevant legal mechanisms and safeguards including data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission.

SPECIAL CATEGORIES OF DATA

We do not collect certain types of data, and we strongly encourage users who may make posts on the Site to avoid posts containing these types of data:

  • Race or Ethnic Origin
  • Political Opinions
  • Religious or Philosophical beliefs
  • Trade union memberships
  • Genetic or biometric data
  • Health or morality
  • Sex life or sexual orientation

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. For instance, we use cookies to help us remember and process the items in your shopping cart. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience.

Internet-Based Advertising

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Website Analytics

We may also partner with selected third-party vendors, such as Adobe Analytics, Clicktale, Clicky, Cloudfare, Crazy Egg, Flurry Analytics, Google Analytics, Heap Analytics, Inspectlet, Kissmetrics, Mixpanel, Piwik, and others, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.

OPTIONS REGARDING YOUR INFORMATION

Account Information

You may at any time review or change the information in your account or terminate your account by:

  • Logging into your account settings and remove your shipping addresses, billing addresses & payment information
  • Contacting us using the contact information provided below
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

  • Noting your preferences at the time you register your account with the Site
  • Logging into your account settings and updating your preferences.
  • Contacting us using the contact information provided below
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CALIFORNIA CONSUMER PRIVACY ACT ADDENDUM

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we (as defined in the Privacy Policy above) are providing the following additional details regarding the categories of Personal Information about California residents that we have collected (online and offline) or disclosed within the preceding 12 months. This CCPA Addendum does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

(1) We collected the following categories of Personal Information

A. Identifiers, such as name, contact information, IP address and other online identifiers;

B. Personal information, as defined in the California customer records law, such as name, contact information, and payment card number;

C. Characteristics of protected classifications under California or federal law, such as age and gender;

D. Commercial information, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location;

G. Audio, electronic, visual, and similar information; and

H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We collect this Personal Information from you as well as from our affiliates, publicly available databases, and joint marketing partners. We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, as described above in this Privacy Policy under “The Data We Collect and How We Use It.”

(2) We disclosed the following Personal Information to third parties for our operational business purposes:

A. Identifiers, such as name, contact information, IP address and other online identifiers;

B. Personal information, as defined in the California customer records law, such as name, contact information, and payment card number;

C. Characteristics of protected classifications under California or federal law, such as age and gender;

D. Commercial information, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location;

G. Audio, electronic, visual, and similar information; and

H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

We disclosed these categories of Personal Information to: our affiliates: resellers and distributors; consultants and other trusted third-party service providers; our event co-sponsors and alliance partners; third parties to permit them to send you marketing communications, consistent with your choices; and third-party sponsors of contests, surveys or similar promotions.

(3) We have not “sold” Personal Information for purposes of the CCPA the following categories of Personal Information:

A. Identifiers, such as name, contact information, IP address and other online identifiers;

B. Personal information, as defined in the California customer records law, such as name, contact information, and payment card number;

C. Characteristics of protected classifications under California or federal law, such as age and gender;

D. Commercial information, such as transaction information and purchase history;

E. Internet or network activity information, such as browsing history and interactions with our website;

F. Geolocation data, such as device location;

G. Audio, electronic, visual, and similar information; and

H. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you may request that we:

(1) Disclose to you the following information covering the 12 months preceding your request:

  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
  • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2) Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us by e-mail at info@fulcrumbiometrics.com. We will respond to your request consistent with applicable law.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:
Fulcrum Biometrics, Inc.
16108 University Oak
San Antonio, TX 78249
210-257-5615
Fax: 1-210-257-5769
info@fulcrumbiometrics.com