This policy applies to information we collect:
- On the Website.
- When we provide valuation advisory, transaction opinions, investment banking, dispute consulting, management consulting, or other services (collectively, “Services”) to you.
- When you apply for employment with us.
- In email, text, and other electronic messages between you and the Website or Franklin Nova.
- On Franklin Nova’s accounts on Twitter®, Facebook®, LinkedIn®, Google Plus®, Instagram®, YouTube®, and/or any other social media website.
2. WHO IS COLLECTING INFORMATION
Information will be collected by Franklin Nova.
3.WHAT INFORMATION WE COLLECT
We collect several types of information from and about users of our Website and Services, including the following types and categories of information and personal data:
- Identifiers such as your name, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, telephone number or other similar identifiers.
- Other categories of information that may be defined as personal information under state or federal law.
- Services data to the extent required to perform Services.
- A persistent identifier (such as a “cookie,” device or processor serial number, or an IP address).
- Information about how you use the Website, including browsing and search history and how you interact with ads or campaigns provided through the Website. We also use Google Analytics to help us gather statistical information about the visitors to our website and how they use the website on an anonymous, aggregate basis. We will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit google.com/policies/privacy/partners/.
- Information about your computer or mobile device, including your physical location, browser and operating system type, and referring URLs.
- Inferences drawn from any of the information described in this Section 3 to create a profile about you and your preferences.
- Employment information that you choose to disclose if you apply for potential employment with Franklin Nova, including your educational history, professional experience, and certain sensitive information such as race, age, citizenship, and any disabilities you may have.
- Marketing information to respond to inquiries regarding our services or to provide you with information, reports, or updates. This information includes the contact data and website visitor information described above as well as information about your occupation or employer if you provide it to us. Clients and other third parties who provide personal data to Franklin Nova must do so in compliance with applicable data privacy regulations.
4. HOW WE COLLECT THIS INFORMATION
We collect information from you when you provide it to us, such as by submitting information when making purchases or setting up an account, and automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
- The information we collect automatically may include personal information and/or we may maintain it or associate this information with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Website according to your individual interests; speed up your searches; recognize you when you return to our Website.
5. HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide information to you about our products and services or those of our business partners.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To notify you about changes to our Website or Services we offer or provide through it.
- To create aggregated anonymous data about the usage of the Website and to use this aggregated anonymous data for our own business purposes or to provide it to third service providers that provide services on our behalf.
- To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business).
- To provide the products or perform the services requested by clients and individuals using our website or web applications (where the processing is necessary for our legitimate business interests in conducting and managing our business).
- For complying with obligations provided by laws, current regulations and legislation (e.g. tax regulations) (where processing is based on a legal obligation)
- For legitimate business purposes to advise you through e-mail, phone call, electronic communication, or postal mailings, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests).
- For marketing purposes. For example, we may use your information to further discuss your interest in our services and to send you information regarding Franklin Nova promotions, events, products or services.
- For security purposes. For example, we may use your data to protect Franklin Nova and its third parties against security breaches and to prevent fraud and violation of Franklin Nova’s applicable agreements (where the processing is necessary for our legitimate business interests).
Personal data is processed by Franklin Nova both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized Franklin Nova employees and third-party service providers to have access to your information. Such employees and third-party services providers are appropriately designated and trained to process data only according to the instructions we provide them.
Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.
6. STORAGE OF INFORMATION
Franklin Nova will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements.
7. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Franklin Nova’s assets.
- To third parties to market their products or services to you if you have consented to/not opted out of these disclosures.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- For any other purpose with your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Franklin Nova’s, our customers, or others.
8. COMPLIANCE WITH THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (“COPPA”)
The Website is not designed or intended for children under the age of thirteen (a “Child”) and may not be used by a Child. Franklin Nova will delete any information that Franklin Nova suspects may relate to a Child.
9NOTICE TO CALIFORNIA RESIDENTS
Shine the Light: Under California’s “Shine the Light” law, California residents have the right to ask us once a year if we have shared their personal information with third parties for their direct marketing purposes. To make a request, please contact us at email@example.com and specify you are making a Shine the Light request.
COMPLIANCE WITH THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)
California residents have certain rights under the CCPA with respect to personal information that is collected, sold, and/or used for business purposes. In the last 12 months, Franklin Nova may have collected those categories of information outlined in Section 2 from the various sources identified in Section 3. California residents have the following rights with respect to personal information collected by Franklin Nova:
- Request for Information. You can also request a copy of your personal information and how it has been used and shared over the last 12 months directly from Franklin Nova. In particular, you have the right to request: (1) categories of personal information that have been collected; (2) the categories of sources of this personal information; (3) the business or commercial purpose for collecting the personal information; (4) categories of third parties with whom Franklin Nova shares personal information; and (5) specific pieces of personal information that Franklin Nova has collected about you.
- Deletion of Information. Franklin Nova users can request that Franklin Nova delete your personal information on your behalf at any time.
- Franklin Nova will not discriminate against any user that exercises their rights under CCPA. However, certain aspects of the Website or Franklin Nova’s products or services may depend on Franklin Nova’s ability to collect and share your personal information. So, the nature and quality of services Franklin Nova provides to you may depend on Franklin Nova’s ability to collect and share this personal information.
- Requests for copies of personal information, or deletion of personal information, may be made using the contacts set forth below.
Franklin Nova does not sell any personal information. In the last 12 months, Franklin Nova may have collected and/or disclosed your personal information to enable Franklin Nova to provide its products and services and run its business, including for the following business purposes:
- To detect security incidents and to protect Franklin Nova against malicious, deceptive, fraudulent, or illegal activity and prosecute those responsible.
- To troubleshoot, debug, or correct errors in the Website or Franklin Nova’s products or services.
- For other short term or transient use where the personal information is not disclosed to a third party.
- To provide customer service, process analytics, and other similar services performed on behalf of Franklin Nova.
- For Franklin Nova’s own internal research and development purposes and to improve the quality, safety, and features of Franklin Nova’s products and services.
- To audit interactions between users and transactions through the Website, including interactions with ads or campaigns provided through the Website.
10.COMPLIANCE WITH INTERNATIONAL PRIVACY LAWS
If you are a member of the European Union (EU), you have special rights under the General Data Protection Regulation (GDPR). Those include:
- The right to object to the processing of your data and the right to portability of your data. All complaints must be sent to [email address].
- The right to erasure, rectification, access, or to seek restrictions to the processing of your personal data in our system. To the extent you provide consent to our processing of your personal data, you have the right to withdraw that consent at any time. Any withdrawal of consent does not apply to data collected lawfully prior to such consent.
The right to lodge a complaint with a supervisory authority containing jurisdiction over GDPR related issues.
11.VERIFYING, CHANGING, OR DELETING YOUR INFORMATION
13. CONTACT US
The Franklin Nova Group
322 North Shore Drive, 2nd Floor
Building 1B Suite 200-328
Pittsburgh PA 15212