Privacy Policy - FORTNA

This is the privacy policy of FORTNA Inc. 

Our postal address is: 
1349 W Peachtree Street NW, Suite 1300 
Atlanta, GA 30309 

We can be reached via e-mail at mail@fortna.com or you can reach us by telephone at 770-475-0991. 

This privacy policy applies only to our relationship with our customers, customers of other FORTNA group company members, registered users and visitors to our site, and recipients of our newsletter. It does not apply to customers of our registered users. If there is any question about the handling of consumer information by our registered users, please refer to their site’s privacy policy. When a registered user logs in to FORTNA, our Web server automatically recognizes the user and uses all information provided to allow them access to our services (including e-mail address and domain name). We do not gather any information from visitors (that are viewing public areas of this site), except where requested and if provided to us by the visitor (i.e. to receive our newsletter). 

We collect the e-mail addresses of those who register as users of our service, aggregate information on what pages they access or visit, information volunteered by the user, such as survey information. 

The information we collect is used for internal review and is then discarded, used to improve the content of our Web page, used to notify consumers about updates to our Website, not shared with other organizations for commercial purposes. 

With respect to cookies: We use cookies to store visitor’s preferences, record past activity at a site in order to provide better service when visitors return to our site. 

If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail at the above address, writing to us at the above address or using the automatic unsubscribe field provided in each e-mail we send. 

If you supply us with your postal address on-line, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by calling us at the number provided above, writing to us at the above address. 

Persons who supply us with their telephone numbers on-line may receive a follow-up call if sales information is requested. 

With respect to Ad Servers: We do not partner with or have special relationships with any ad server companies. If our information practices change at some time in the future, we will post the policy changes to our Website to notify you of these changes. If you are concerned about how your information is used, you should check back at our Website periodically. Customers may prevent their information from being used for purposes other than those for which it was originally collected by emailing mail@fortna.com. 

Upon request we provide registered users with access to a description of information that we maintain about them. Registered users can access this information by sending an e-mail to us at the above address. Information can also be corrected by sending us e-mail at the above address. 

With respect to security, we always use industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. When we transfer and receive certain types of sensitive information such as financial information, we redirect visitors to a secure server and will notify visitors through a pop-up screen on our site, we have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our Website. Of course, every data which is handled by us, on-line and off-line is subject to state-of-the-art data security measures. 

If you feel that this site is not following its stated information policy, you may contact us at the above addresses or phone number. 

PRIVACY POLICY OF FORTNA Inc.

OWNER AND DATA CONTROLLER
FORTNA Inc.
1349 W Peachtree Street NW, Suite 1300
Atlanta, GA 30309

Owner contact email: mail@fortna.com
You can reach out to our data protection officer (DPO) via email: dataprotection@fortna.com

GENERAL INFORMATION
The general information provided in this section applies to both, the data processing that is carried out with regard to our Website and the processing of customer data from FORTNA Inc. customers and FORTNA group company customers.

MODE AND PLACE OF PROCESSING THE DATA

Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time. 

Place of processing and data transfer from EU or the EEA to a third-country recipient
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. 

If you are based within the European Union (EU) or the European Economic Area (EEA) your data may be transferred to a recipient outside the EU or EEA. A transfer of personal data to a recipient in a third country may take place where the EU-Commission has decided that the third country, a territory or a specified sector within that third country, or the international organization in question ensures an adequate level of data protection. In case the recipient neither is based in a country or territory that provides an adequate level of protection nor is the recipient active in a specific sector in terms of Article 45 GDPR, we take appropriate safeguards to secure any transfer or disclosure to and the processing by a non-EU recipient by concluding standard contractual clauses (SCC) within the whole FORTNA company group. For further questions regarding the SCC please refer to our Data Protection Officer (for contact information, see above). 

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section. 

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the data subject has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

DATA PROCESSING ON OUR WEBSITE
This Website collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

FULL WEBSITE POLICY

TYPES OF DATA COLLECTED
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Data stored in Cookies; Usage Data; geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Web site to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes (Art. 6 (1) (a) EU GDPR). Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to the EU GDPR;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof (Art. 6 (1) (b) EU GDPR);
  • processing is necessary for compliance with a legal obligation to which the Owner is subject (Art. 6 (1) (c) EU GDPR);
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner (Art. 6 (1) (e) EU GDPR);
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party (Art. 6 (1) (f) EU GDPR). This legitimate interest will include effective maintenance and developing of the Website as well as User and customer services and direct marketing of our products and services.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The purpose of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Displaying content from external platforms, Tag Management, Interaction with external social networks and platforms and Location-based interactions.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services:

Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Google will use this information on our behalf for the purpose of measuring your activity on this Website, for compiling statistical reports on overall content interaction activity for us and providing other services relating to website activity and internet usage.

You can prevent the collection of the data generated by the cookie by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in, whereby an opt-out cookie is set, or by selecting the appropriate setting in your browser software.

Personal Data collected: Personal information stored in Cookies; Usage Data.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Marketo Inc.
Marketo uses cookies to measure user engagement with our Sites, online events, advertisements and online content such as white paper downloads. The cookie allows linking a user to the recipient of an email marketing campaign to measure campaign effectiveness. The personal information collected may include the following: time of visit, pages visited, referring site details, type of web browser and operating system, interactions on site, network location, IP address, document downloads, clicks on links leading to external websites. We use the feature of IP anonymization in the service provided by Marketo.

Personal Data processed: Cookies and Usage Data

Place of processing: United States – Privacy Policy

Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data collected: Personal information stored in Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.

The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.

LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Personal information stored in Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Personal information stored in Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Personal information stored in Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

ShareThis (Sharethis Inc.)
ShareThis is a service provided by ShareThis Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Website.

Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Location-based interactions
Non-continuous geolocation (this Website)
This Website may collect, use, and share User location Data in order to provide location-based services.

Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website.

The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data collected: geographic position.

Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.

This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Usage Data.

Privacy Policy: Google Tag Manager’s Privacy Policy

Place of processing: United States – Google LLC’s Privacy Policy. Privacy Shield participant.

COOKIE POLICY
This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

Legal action
The User’s Personal Data may be used for the legitimate interest (Art. 6 (1) (f) EU GDPR) of legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

EU GDPR
The General Data Protection Regulation 2016/679/EU of the European Union issued on April 27, 2016.

Cookies
Small sets of data stored in the User’s device.

PROCESSING OF CUSTOMER DATA

Type of data and purpose of processing
We process personal data of our customers and employees of our customers insofar as this is necessary to maintain a proper business relationship. This applies both to data from customers of FORTNA Inc. and to data from customers of other companies that are belonging to the FORTNA company group. If you are a contact person for FORTNA Inc. or a FORTNA group company member at your employer, we may process Your contact details, such as your name, email address, role, phone number and other company information. 

Legal basis for processing
If the company you are working for is a customer of FORTNA Inc. we process your data based on our legitimate interest to maintain the business relationship to your employer (Art. 6 (1) (f) GDPR).

If the company you are working for is a customer of a FORTNA company group member, we process your data based on our legitimate interest in the internal administration of group company data (Art. 6 (1) (f) GDPR). In that case we received your personal data from the FORTNA company group member to whom your employer holds a business relationship. 

THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on the legal basis of public or legitimate interest. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to our data protection officer at dataprotection@fortna.com, or our postal address through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document.