Privacy Notice

FORTNA Group, Inc. and its subsidiaries and affiliates (collectively, “we”, “us”, or “FORTNA”) takes your privacy seriously. We want you to know how we collect, use, disclose, and protect your personal information.

This Privacy Notice tells you:

Scope of this Policy
What personal information we collect
Purposes for using the Personal Information we collect
How we may disclose the Personal Information we collect
How we protect the Personal Information we collect
How long we keep your Personal Information
Updating/Correcting your Personal Information
Additional information for California residents
Additional information for all locations outside the United States
Additional information for residents of the EEA, Switzerland, and the United Kingdom
Changes to this Privacy Notice
Have Questions?

1. SCOPE OF THIS POLICY

This Privacy Notice applies to personal information that we collect on the website www.fortna.com as it may be modified, relocated and/or redirected from time to time (the “Site”). If we interact with you offline, such as when you visit our facilities, the Policy also applies to the personal information collected through those off-line interactions. This Privacy Notice does not apply to the personal information of individuals in their capacity as prospective, current, or former employees, contract workers, board members, or owners of FORTNA, or their spouse, dependents, other beneficiaries, or emergency contacts.

If you do not want us to handle your personal information as described in this Privacy Notice, please do not use the Site. You will not be able to submit personal information through this Site unless you consent to this Privacy Notice where requested.

As used in this Privacy Notice “personal information” means information that relates to you as an individually identifiable person, such as your name, e-mail address, job title and mobile number.

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2. WHAT PERSONAL INFORMATION WE COLLECT

CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We do not collect any information from anyone under 13 years of age. The Site, products and services are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorised to use the Site.

Information You Submit Through The Site

We collect personal information that you voluntarily submit through the Site. For example, we collect information from you when you fill out a contact form on the Site.

The personal information you might provide us may include:

Identifiers, for example: real name, alias, telephone number, postal address, e-mail address, signature, photographs, and Social Security, driver’s license, or state identification card.
User Content, includes content you submit when you contact customer service or otherwise contact FORTNA. This may include recordings you create, including audio recordings or voicemails you submit in connection with customer service. Users are responsible for any third-party personal information obtained, published or shared through this website and confirm that they have the third party’s consent to provide the personal information to FORTNA.

Information Collected Through Offline Interactions

When you visit our facilities or otherwise interact with us offline, we may collect the following categories of personal information form or about you:

Identifiers, for example: real name, alias, job title, telephone number, postal address, e-mail address, signature, photographs, and Social Security, driver’s license, or state identification card.

Information We Collect Through Technology On The Site

We collect information through technology to enhance our ability to serve you. When you access and use the Site, FORTNA and, in some cases, our third-party service providers, collect information about how you interact with the Site. We describe below methods we use to collect information through technology.

Internet or Other Electronic Network Activity Information, for example: information about your usage of the Site, such as the pages you viewed, time of visit, the services and features you used or interacted with; your browser type and details about any links or communications with which you interacted; internet protocol (IP); URI addresses, browser plug-in types and versions; document downloads, and operating systems and platform. Where, according to local law, IP addresses and the like are considered personal information, then we treat them as such. We do not link your personal information to device identifier information, browser information, and IP addresses, unless you have specifically provided consent to us to save your personal information.
Communications Data, for example: during our communications with you, we collect the content of these communications as well as metadata about the communications, i.e., date and time of the call or text (SMS or MMS) message and phone numbers.

Do We Use Cookies?

Yes. Cookies are small files that the Site or our service provider transfers to your computer’s hard drive through your Web browser that enables the Site’s or service provider’s systems to recognise your browser and capture and remember certain information. We use cookies to help us understand how users use the Site. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users.

You can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features on the Site may not function properly. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

Google Analytics

We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding our Site visitors. These cookies collect information tied to a user’s IP address, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the Site. Based on this information, Google Analytics compiles aggregate information about Site traffic and Site interactions, which we use to offer better Site experiences and tools in the future. Google Analytics does not collect any personal information (other than IP Address which may be considered personal information in some countries). For more information on Google Analytics, visit https://support.google.com/analytics.

Web Beacons

We include small graphic images or other web programming code, called web beacons (also known as “pixel tags”, “web bugs” or “clear GIFs”), on the Site. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

Information Third Parties Provide About You

We may supplement the information we collect about you through the Site with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, the service provider that processes orders submitted through the Site discloses your order information, but not payment information, with us.

Information You Provide To A Third Party

The Site includes links from the Site to, and plug-ins (such as social media buttons) from, sites or applications operated by third parties (“Third-Party Sites”). We do not control any Third-Party Sites and are not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by its privacy policy. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.

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3. PURPOSES FOR USING THE PERSONAL INFORMATION WE COLLECT

We use the information we collect to serve you and improve your experience on the Site. Some examples include:

Providing Products and Services, including:

To deliver our products and administer our services.
To communicate with you.
To improve our products and services, develop new products and services, and conduct research on further improvements.
To enhance your experience using our products, services, and Site and to personalise your online experience, including making our website more intuitive.
To display content from external platforms.
To enable location-based interactions.
To enable interaction with external social networks and platforms.
To provide our services via (online) customer ticketing/support systems.

Support, Analytics, and Marketing, including:

For customer support.
To respond to any requests, queries, suggestions, feedback, or comments you may have.
To send you marketing information about our products and services, including notifying you of marketing events, membership and rewards programs, promotions, and sweepstakes, with your consent in accordance with applicable law.
To inform you of any changes to the services, your account (if applicable), this Privacy Notice, or any other policies or terms in relation thereto.
To perform operations to maintain and/or improve the services, including to conduct data analysis, testing, tag management, and research; and to monitor and analyse usage and activity trends.

Monitoring, Security, and Compliance, including:

To administer and protect our business and our Site (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
To store, host, or backup (whether for disaster recovery or otherwise) our services or any personal information contained therein.
To protect the rights, property, or safety of FORTNA, you, or others.
In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of FORTNA or any of the FORTNA subsidiaries or affiliates.
To detect any malicious or fraudulent activity.
To report suspected criminal conduct to law enforcement and cooperate in investigations.
To exercise FORTNA’s rights under applicable law and to support any claim, defence, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
To ensure compliance with applicable laws and regulatory obligations.

Incidental Purposes:

Any incidental purposes related to, or in connection with, the above.

Anticipated Purposes of Use:

Although FORTNA has not used personal information for the following purposes in the past 12 months, it may do so in the future:

e-commerce purposes
increasing ease of Site usage

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4. HOW WE MAY DISCLOSE THE PERSONAL INFORMATION WE COLLECT

The following are some of the ways we disclose your personal information:

Third-Party Service Providers: We will disclose your personal information to third-party service providers under contract with FORTNA to help us provide services to you. The types of third-party service providers to which we may disclosure your personal information and include, for example, customer relationship management (CRM) platform providers, payment service providers, auditors, accountants, attorneys, and consultants. We require these third-party service providers, by written agreement, to provide safeguards for your personal information similar to the ones that we provide.
Third parties: For example, we might disclose personal information to business partners to assist us in providing services to you.
Affiliated companies: We may disclose your personal information to individual FORTNA group members for internal administration of data.
Government or administrative agencies: For example, FORTNA may report unlawful activity to law enforcement.
Required Disclosures: We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
Legal Compliance and Protections: We may disclose account and other personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of FORTNA, our users, or others. This includes exchanging personal information with other companies and organizations for fraud protection and credit risk reduction.
Corporate Transactions: We reserve the right to disclose and transfer your information, including your personal information:
- To a subsequent owner, co-owner, or operator of the Site or successor database.
- In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

Unless required by applicable law, we do not allow your personal information to be disclosed for reselling to other parties.

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5. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT

The security and confidentiality of your personal information is important to us. We have technical, administrative, and physical security measures in place to protect your personal information from unauthorised access or disclosure and improper use.

For example, we use Transport Security Layer (TSL) encryption to protect the information collection forms on our Site. In addition, we restrict access to your personal information. Only employees who need the personal information to perform a specific job (for example, a customer service representative) are granted access to personal information. Employees with access to personal information are kept up-to-date on our security and privacy practices.

It is important for you to protect against unauthorised access to your password and to your computer. Be sure to close your browser after you have completed your visit to the Site.

Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your personal information.

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6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain your personal information for the duration of the customer relationship, if any. We also retain your personal information for 12 months after our last interaction with you. We will retain personal information longer as necessary to comply with legal, administrative, or procedural requirements, for example, a litigation hold.

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7. UPDATING/CORRECTING YOUR PERSONAL INFORMATION

You may contact privacyglobal@fortna.com to update OR correct your personal information. For more information regarding your rights if you reside in California or outside the United States, please refer to Section 8 through 10, below.

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8. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section applies only to consumers who are residents of the state of California in the United States (“California consumers”) and it applies to all personal information of California consumers collected, disclosed for business purposes, or sold by FORTNA, regardless of whether the personal information is collected, disclosed or sold through the Site.

Assistance For The Disabled

Alternative formats of this Privacy Notice are available to individuals with a disability. Please contact privacyglobal@fortna.com for assistance.

Notice at Collection for California Residents

FORTNA collects the personal information identified in Section 2 for the purposes identified in Section 3 and retains it for the period described in Section 6. To the extent you provide FORTNA with personal information about other California residents, you are responsible for providing this notice to them.

A. Additional Information Concerning The Handling Of Personal Information

The information in this Section 8.A supplements the information contained in Sections 1 through 6, above.

1) Categories of Sources

We may collect the categories of personal information listed in Section 2, above, from the following categories of sources:

You, for example, when you register with our Site, subscribe to online services, when you shop with us, or when you otherwise provide information directly to us.
Service providers, for example, analytics providers, IT, and system administration services.
Affiliated companies, for example, so that we can assist other companies in the FORTNA family of companies in providing you with products or services.
Automated technologies, for example, browsing activity collected by automated technologies on the Site.
Third parties, for example, lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
Public sources, for example, public databases.
Marketing/advertising companies, for example, from social media platforms, consumer research companies, and analytics or marketing/advertising companies.
Surveillance/recording technologies installed by FORTNA, for example, video surveillance in common areas of FORTNA facilities, voicemail technologies, and audio recording technologies with consent to the extent required by law.
Government or administrative agencies, for example, law enforcement, public health officials, and other government authorities.
Acquired entity, if FORTNA acquired another entity, FORTNA might collect personal information from that entity.

2) Disclosures for Business Purposes

FORTNA has disclosed each of the categories of personal information listed in Section 1, above, for the following “business purposes”, as that term is defined under the California Privacy Rights Act (“CPRA”), in the last 12 months:

Service providers: For the business purpose of performing services on FORTNA’s behalf and, in particular, for the specific purposes described in Section 3, above.
Auditors, lawyers, consultants, and accountants engaged by FORTNA: For the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on FORTNA’s behalf.
Affiliated companies: To other companies within the FORTNA family of companies for the business purposes of (1) auditing compliance with policies and applicable laws, (2) helping to ensure security and integrity, (3) debugging, (4) short-term transient use, (5) performing services on behalf of FORTNA, (6) internal research, and (7) activities to maintain or improve the quality or safety of a service or device.

3) Sales and Sharing
We do not sell or share your personal information, where “share” means disclosing personal information to third parties for cross-context behavioural advertising. Without limiting the foregoing, we have not, and have no actual knowledge that we have, sold or “shared” the personal information of individuals of any age, including the personal information of children under 16, in the last 12 months.

4) Aggregated and Deidentified Information

We may aggregate and/or deidentify information, use it internally, and disclose to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal information.

“Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our Site’s contact form on a given day.
“Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be the data point that an unidentified visitor first entered the Site through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.

B. Your California Privacy Rights

Subject to applicable law, California residents have the following rights:

Right to Know: You have the right to submit a verifiable request for specific pieces of your personal information and for information about FORTNA’s collection, use, and disclosure of your personal information. Please note that the CPRA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to copies of items of personal information. Moreover, California residents generally just have a right to know categories, for example, categories of third parties to which personal information is disclosed, but not the individual third parties.
Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to FORTNA.
Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by FORTNA, taking into account the nature of the personal information and the purposes of processing the personal information.
Right to Opt out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for cross-context behavioural advertising. You may also implement a browser setting or extension to communicate your selling and sharing preferences automatically to the websites you visit. We honour your right to opt out of the sale and sharing of your personal information as signalled by a universal opt out signal or Global Privacy Control (“GPC”). To enable GPC, you can visit the Global Privacy Control page at https://globalprivacycontrol.org. If you download a supported browser or extension and exercise your privacy rights with GPC, we will turn off certain third-party cookies on our Site after our Site detects a GPC signal. However, if you visit our website from a different device or from a different browser on the same device, you will need to opt-out or use an opt-out preference signal for that browser and/or device.

C. How to Exercise Your Rights

FORTNA will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

Email privacyglobal@fortna.com
Call 1-844-564-3371
Complete the request form available here and email it to privacyglobal@fortna.com

D. How We Will Verify Your Request

If you submit a request, we will match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

E. Authorised Agents

You may designate an authorised agent to exercise your right to know, to correct, or to delete. If an authorised agent submits a request on your behalf, the authorised agent must submit with the request another document signed by you that authorises the authorised agent to submit the request on your behalf. In addition, we may ask you or your authorised agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorised Agent Designation” form by contacting us at privacyglobal@fortna.com.

In the alternative, you can provide a power of attorney compliant with the California Probate Code.

F. FORTNA’s Non-Discrimination Policy

FORTNA will not unlawfully discriminate against you for exercising your privacy rights under the California Privacy Rights Act.

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9. ADDITIONAL INFORMATION FOR ALL LOCATIONS OUTSIDE THE UNITED STATES

Identification of the Data Controller

The data controller of your personal information is at the members of the FORTNA corporate group. Contact details for each corporate group member can be found here http://www.fortna.com/contact/.

Legal Basis for Processing

FORTNA processes your personal information with your consent and as required by law. In addition, FORTNA processes your personal information as necessary for the performance of a contract, for example, when processing your orders and payments and to take steps, at your request, before entering into a contract with you, for example, by providing you with quotes for products and services. FORTNA also processes personal information as necessary for its legitimate interests as follows:

Marketing and advertising: Unless you opt out as described below, we use your personal information regarding products and services you have ordered, or in which you have otherwise demonstrated an interest, as necessary to provide you information about the products and services that we think might interest you in accordance with applicable law.
Network and information security, fraud prevention, and reporting suspected criminal acts: In the event of fraud, a security incident, or a suspected criminal act, we would examine personal information that appeared to be linked to the incident as necessary to determine what happened, remediate, report to the authorities, and prevent a recurrence.
Business Relationship. If the company you are working for is a customer of or supplier to a FORTNA group member, we process your data based on our legitimate interest to maintain the business relationship with your employer.
Internal administration. If the company you are working for is a customer of or supplier to a FORTNA company group member, we process your data based on our legitimate interest in the internal administration of group company data. In that case we received your personal information from the FORTNA company group member with which your employer holds a business relationship.

International Transfer of Your Personal Information

If you reside outside the United States, the personal information that we collect about you will be stored in the U.S. and in other countries where members of the FORTNA corporate group are located. Authorised employees of FORTNA and/or affiliated companies at locations outside the United States may have access to your personal information. These employees may use and disclose your personal information only for the purposes as listed in this Privacy Notice, and must handle that information in accordance with this Privacy Notice and applicable data protection laws and guidance. The data protection laws where these companies are located may be less stringent than the laws of your home country. Details on the locations from which FORTNA employees may access your personal information can be found here: https://www.fortna.com/contact/.

Your Rights

To the extent provided by applicable law and subject to any relevant exceptions, you may be able to exercise the following rights:

Access: The right to request access to your personal information maintained by FORTNA.
- European Individuals’ right to access their personal information includes their right to receive a copy of all, or a portion, of their personal information in FORTNA’s possession as long as FORTNA’s providing the personal information would not adversely affect the rights and freedoms of others.
Rectification: The right to request that FORTNA update or correct your personal information that is outdated or inaccurate.
Deletion: The right to request that FORTNA to delete/erase your personal information.
Restrict Processing: The right to request restriction of processing of your personal information in certain situations, such as while a dispute concerning the accuracy of personal information is being resolved.
Data Portability: You have the right to request that FORTNA transfer your personal information to a third party.
- Subject to certain limitations, the right to information portability allows you to obtain from FORTNA, or to ask FORTNA to send to a third party, a copy of your personal information in electronic form that you provided to FORTNA in connection with your interactions with FORTNA.
Objection: You have the right to object to the processing of your personal information.
- You have the right to object when processing of your personal information is based solely on FORTNA’s legitimate interests. If you do object in these circumstances, the processing of your personal information will be stopped unless there is an overriding, compelling reason to continue the processing or the processing is necessary to establish, pursue or defend legal claims.
Withdraw Consent: The right to withdraw your consent to the processing of your personal information, at any time, where you previously consented to the processing of your personal information.
- Any withdrawal shall not affect the lawfulness of processing based on your consent before its withdrawal, and FORTNA will continue to retain the personal information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.

If you reside in China, you also have the right, subject to applicable limitations and exceptions to restrict the processing of your personal information.

If you reside in Mexico, you also have the right, subject to applicable limitations and exceptions, to cancel or block the processing of your personal information.

If you reside in South Africa, you also have the right, subject to applicable limitations and exceptions to cancel or block the processing of your personal information.

If you reside in Vietnam, you also have the right to (a) complain, denounce, or initiate lawsuits in accordance with applicable law, (b) claim damages for alleged violations of data protection regulations as provided by applicable law, and (c) request that competent authorities take steps to protect your rights. You also have the obligation under applicable data protection law to (a) comply with the law and cooperate in the fights against violations of data protection law, (b) protect and respect others’ personal data, and (c) upon consenting to processing of your personal data, provide complete and accurate personal data.

How To Exercise Your Rights

You can contact privacyglobal@fortna.com to request to exercise your data rights. FORTNA will respond to requests to exercise individual data rights in accordance with applicable law. FORTNA will recognise any additional rights you may have under applicable law, but it will not grant you more rights than applicable law provides.

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10. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EEA, SWITZERLAND, AND THE UNITED KINGDOM

The information in this section applies to applicants who reside in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland (collectively, “Europe”). Individuals in Europe (“European Individuals”) are not required by statute or by contract to provide any personal information to the Site.

International Transfer of Your Personal Information

FORTNA has taken steps to ensure an adequate level of protection for your transferred personal information through Standard Contractual Clauses (the “SCCs”) to which FORTNA and its affiliates are all parties. You may obtain a copy of the SCCs by submitting a request to privacyglobal@fortna.com.

Right to Lodge a Complaint: If European Individuals believe that their personal information has been processed in violation of applicable information protection law, they have the right to lodge a complaint with the competent supervisory authority in the country where they reside, where they work, or where the alleged violation occurred.

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11. CHANGES TO THIS PRIVACY NOTICE

If we change this Privacy Notice, we will post those changes on this page and update the Privacy Notice modification date above. If we materially change this Privacy Notice in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

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12. HAVE QUESTIONS?

Please direct any questions or concerns you may have about this Privacy Notice to privacyglobal@fortna.com.

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Published/Updated 11/13/24