Privacy Policy

1. Corporate Commitment to Privacy

Farouk Systems, Inc. and its subsidiaries and affiliates (collectively “FSI” “our,” “we” or “us”) are committed to respecting your privacy. This Privacy Policy describes how we collect, use, disclose, store and otherwise process information when you use our websites and other online products and services, including pursuant to the European Union General Data Protection Regulation (“GDPR”).

We urge you to read this Privacy Policy so that you understand our commitment to you and your privacy, and how you can participate in that commitment.

2. Definition of Personal Information

Personal Information

“Personal Information” means any information relating to an identified or identifiable   natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his    or her physical, physiological, mental, economic, cultural or social identity.

Examples of Personal Information

“Personal Information” may include the following: name, address, date of birth, gender and contact data (i.e. e-mail address, telephone number and employer name).

Sensitive Personal Information

“Sensitive Personal Information” means personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information pertaining to the sex life of the individual.

3. Definition of Non-Personal Information

We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.

4. Scope and Consent

FSI has established and implemented this Privacy Policy to inform visitors to the website and users of our services how we use and protect the information we collect from our websites and services. By visiting our website or using any of our services, you consent to FSI’s collection, use, disclosure, transfer and storage of your Personal Information as set forth in this Privacy Policy.

5. Information Voluntarily Provided

FSI collects Personal Information about you in connection with many of our services. When working with or using this website, you may be prompted to make an account which holds personal information such as name, mailing address, email address, or credit card information. When contacting our company, you may be required to submit contact information. When communicating with FSI, all communications will be transmitted and stored by us.

6. Information Collected Automatically

FSI may also collect Technical Information about you when you visit our websites, which your web browser automatically sends whenever you visit a website on the Internet. “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record this information, which may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request. Gathering your information helps us ensure our websites and other services work correctly and support out customer analytic efforts.

7. Information Collected Automatically

Email communication

We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.

Mobile communication

When you download or use our mobile-device applications, or access one of our mobile-optimized websites, we may receive information about your mobile device, including a unique identifier for your device.

Cookies and Similar Technologies

We may collect information about your use of the websites through cookies and similar technology. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites.

8. Information Collected about Friends/Family

FSI may also collect information about your friends and family through your interactions on our services. Referring friends to our services requires you to send their personal information to FSI. Other instances, such as sharing content, may also require you to send their personal information to us.

9. Information Collected from Social Media Applications/Networking Websites

Our websites include social media features, such as the Facebook Like button and other widgets that run on our site. These features may collect your IP address and which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the organization providing it. For example, if you create or log into your account through a third-party social networking site, we may have access to certain information from that site, such as your name, account information and friends, in accordance with the authorization procedures determined by such third-party social networking site.

10. Information Collected from Other Sources

FSI may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud.

11. Information Collected from Other Sources

Third-Party Vendors

In order to provide the services and improve FSI’s websites, we may engage the services of third-party vendors. In the process of supplying services to FSI, these third-party vendors may need to collect Personal Information about you.

Co-branding

Some company websites or services may be co-branded and offered in conjunction with another company. If you use such websites or services, both FSI and the other company may receive the Personal Information that’s collected via that co-branded website or service.

Public Forums, Blogs and the Customer Reference Program

FSI websites may feature bulletin boards, blogs or forums. Any Personal Information that you choose to submit via such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages.

Flash LSOs

We use Local Storage Objects (LSOs) such as HTML5 and Flash to store content information and preferences. We partner with third parties to provide certain features on our site or to display advertising based upon your browsing activity. Various browsers may offer their own management tools for removing HTML5 LSOs.

Log Files

Log files record website activity on our services and enable us to gather statistics about our users’ browsing habits. These entries help FSI determine (among other things) how many and how often users have accessed or used our services, which pages they’ve visited, and other similar data.

12. Why does the Company Process Personal Information?

FSI uses your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as fraud prevention, marketing, and legal functions. FSI has a legitimate interest in processing Personal Information during the process and for keeping records of the process. The Company may also need to process Personal Information to respond to and defend against legal claims. The Company also has to maintain accurate and up-to-date records and contact details. To do this, we combine personal and non-personal information, collected online and offline, including information from third party sources. FSI also processes Personal Information for one or more of the following reasons:

Fulfill requests

To fulfill your requests for products and services and communicate with you about those requests;

Understand customer behavior

To better understand customer behavior so that we may improve our marketing and advertising efforts and to improve the distribution of our products and services;

Personalize offerings

To help us personalize our service offerings, websites, mobile services, and advertising;

Fraud Prevention

FSI may use personal information such as name, date of birth, mailing address, or social security number to verify the identity of their customers and to prevent fraudulent activities such as the fraudulent purchase of products/services;

Credit Card Information

Credit card information may be used to check the financial qualifications or collect payment from customers regarding orders of products and services;

Protection

To protect the security and integrity of our websites, mobile services, and our business;

Legal

To comply with legal and regulatory requirements;

Responding to customer

To respond to reviews, comments, or other feedback you provide us;

Industry benchmarking

For industry benchmarking and analysis consistent with our legitimate business purpose;

13. Promotional Messaging or Advertising

FSI uses your contact information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, announcements, or special offers or to notify you about our upcoming events.

14. Disclosure of Personal Information to Third Parties

FSI will not rent or sell your Personal Information to others but may disclose personal information with third-party vendors and service providers that work with FSI. We will only share Personal Information to these vendors and service providers to help us provide a product or service to you.

15. Disclosure of Personal Information for Legal and Safety Reasons

FSI may be required to disclose personal information to the authorities, law enforcement agencies, government agencies, or legal entities. We may disclose information by law, litigation, or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law. We may also need to disclose personal information in the event of an emergency that threatens an individual’s life, health, or security.

16. Disclosure of Personal Information Via Links to Third-Party Websites, Services, and Applications

Using our website or services may link to third party web websites, services, and applications. FSI is not responsible for any Personal Information collected through these means. Information collected is governed through the third party’s website’s Privacy Policy. Any interactions you have with these web websites, services, or applications are beyond the control of FSI.

17. Use of Cookies and Other Technologies (e.g. Web Beacons)

FSI uses cookies to operate and improve our website as well as to simplify the interaction with you. When you visit our websites, our servers send a cookie to your computer or mobile device to help personalize your experience and advertisements. Cookies help us better understand user behavior and facilitate effectiveness of advertisements. Cookies only stand to recognize your web browser but information collected from cookies is not personally identifiable.

FSI may also use web beacons or other technologies in conjunction with cookies to gather information about your visit to our websites. Web beacons may be embedded through our website or electronic communications and can allow servers to collect information related to your visit. Web beacons are primarily use to provide content and advertisements that are more relevant to you.

18. Ability to Disable Technologies

Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services. For more information, visit the help page for your web browser or see https://www.allaboutcookies.org

19. Consequences of Disabling Technologies

Please note that if you disable your web browser’s cookies and other technologies, certain features of our website and services will be disabled and you will limit the functionality we can provide when you visit our site.

20. Security Measures Taken to Protect Personal Information by Company

Security of all information is of the utmost importance for FSI. FSI uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. We use encryption technology to keep all information secure. We also make all attempts to ensure that only necessary people and third parties have access to Personal Information.

21. Security Measures to Protect Personal Information by Third Parties

We require that our third party service providers and channel partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third party service providers and channel partners are expected to maintain privacy and security protections that are consistent with FSI’s privacy and information security policies.

While we provide these third parties with no more information than is necessary to perform the function for which we engaged them, any information that you provide to these third parties independently is subject to their respective privacy policies and practices.

22. Data Retention and Storage

FSI retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. FSI will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.

Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to our services. To that end, FSI will notify users of a data breach when FSI determines that is reasonably necessary in accordance with applicable law. Any transmission is at your own risk and FSI expects that you will use appropriate security measures to protect your information.

23. Collection of Information from Children Broad

The Company recognizes the importance of protecting the privacy and safety of children. Our website and services are directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 13 has provided Personal Information through one of our websites, we will use reasonable efforts to remove that information from our databases.

24. International Transfer of Personal Information

In addition FSI may share customer information within our family of companies for a variety of purposes, for example to provide you with the latest information about our products and services and offer you our latest promotions. This may involve the transfer of personal data to other locations outside your home country to other FSI companies in different locations around the world.

25. Questions/Updates to Policy

Inquiry, Complaint, and Dispute Process

Customers may contact the FSI with any questions, concern, or inquiries about this Privacy Policy or company data. If you would like to make a formal complaint, please contact [insert relevant e-mail address or mailing address]. All complaints will be evaluated and a reply will be sent as soon as appropriate. In some instances, the FSI may have to cease services to you if necessary to satisfy your request.

Changes to the Data Privacy Policy

FSI may review and update this Privacy Policy periodically without any prior notice. FSI will post a notice to its website to inform you of any changes to our Privacy Policy and indicate when it was most recently updated. In the case of material changes that may adversely affect you, the FSI may provide a more direct way of notifying you of changes to this Privacy Policy.

26. Applicable Regulations—California Privacy Rights; GDPR Rights

California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to infoweb@farouk.com or write us at Farouk Systems, Inc., 250 Pennbright Drive, Houston, TX 77090.

Pursuant to GDPR, You can:

• access and obtain a copy of your data on request;
• require FSI to change incorrect or incomplete data;
• require FSI to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where FSI is relying on its legitimate interests as the legal ground for processing; and
• request the transfer of your personal data to a third party.

If you would like to exercise any of these rights, please contact infoweb@farouk.com, in writing at 250 Pennbright Drive, Houston, TX 77090, or at the telephone number (281) 876-2000.  If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner.