INTERNATIONAL PRIVACY POLICY
The above general Policy still applies to those individuals who reside outside of the United States or who have had personal information collected by Further Worldwide, LLC or its agents (“Further”, “us,” “we” or “our”) in a country other than the United States. However, due to various international regulations, those individuals may be entitled to additional disclosures and rights. This International Privacy Policy (the “International Policy”) supplements the above general Policy, but where the provisions of the general Policy and this International Policy cannot be construed consistently, this International Policy will govern.
Please note that by visiting the Website or by having personal information collected by us, your personal information is being stored or processed in the United States where our data center and servers are located and operated. The United States may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. Your personal information may also be stored in a multi-tenant cloud environment hosted by our service providers.
Depending on your country of residence, you may have data rights as provided by various laws, regulations and codes, which can include the Canadian Personal Information Protection and Electronic Documents Act, the European Union General Data Protection Regulation, the UK Data Protection Act 2018, the Swiss Revised Federal Act on Data Protection 1992 and Ordinance on the Federal Act on Data Protection, the New Zealand Privacy Act 2020, the Japanese Amended Act on Protection of Personal Information or the Australian Privacy Act 1988, among others.
THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH THE WEBSITE, THE SERVICES OR OTHERWISE).
Our International Policy includes:
1. Collection Of Personal Information
2. How We Use Personal Information
3. The Basis On Which We Process Your Personal Information
4. Obtaining Consent
5. Third-Parties
6. Limitations
7. Retention Of Personal Information
8. International Transfer Notice
9. Access And Rights To Your Personal information
10. Response Time
11. Costs
12. Identifying You In Connection With Requests
13. Opt-Out And Unsubscribe
14. Accuracy
15. Safeguards
16. Contact Us
COLLECTION OF PERSONAL INFORMATION
You can find specific details about the personal information that we collect about you in the section titled What Information We Collect And Disclose And For What Purposes of the general Policy.
Where we are the data controller with regards to the personal information that we process, you may exercise your rights as a data subject, including the right to object to the processing of your personal information when it is processed based on legitimate interests, as described in this International Policy. However, when providing services to our customers, we primarily collect and process your personal information as a processor or service provider on behalf of our customers. This means that we collect, process and disclose your personal information at the direction of our customers. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller to the extent we are required to do so by law.
HOW WE USE PERSONAL INFORMATION
As a general matter, we collect your personal information to perform our Services and administer our Website. You can find specific details about the purposes for which we collect personal information about you in the section titled What Information We Collect And Disclose And For What Purposes.
THE BASIS ON WHICH WE PROCESS YOUR PERSONAL INFORMATION
We will only collect and process your personal information as is reasonably necessary for, or directly related to, one or more of our functions or activities, including for administering our Website or providing our Services to you or our customers. You can find specific details about the purposes for which we collect personal information about you in the section titled What Information We Collect And Disclose And For What Purposes of the general Policy.
Where required by law, we rely on the following legal grounds to process your personal information:
- Performance of a contract: We may need to collect and use your personal information to enter into a contract with you or to perform a contract or provide services that you have requested from us.
- Consent: Where required by law, we will obtain your explicit consent for collecting and processing of your personal information.
- Legitimate interests: We may use your personal information for our legitimate interests of detecting and preventing fraud, maintaining the security of Further’s network and information systems or engaging in direct marketing of our products and services.
OBTAINING CONSENT
Except when otherwise permitted by law or binding regulation, we will obtain the requisite consent from you prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose other than as disclosed in this International Policy. You may provide your consent to us orally, in writing, by electronic communication, through your actions or any other means reasonably capable of conveying your consent.
Generally, we will seek to obtain your explicit consent if we collect, use or disclose sensitive personal information about you. However, your refusal to provide consent for collection (or your withdrawal of previously given consent) or to give your personal information when requested, can have negative consequences. For example, if you do not give consent for our collection of cookies, then the Website will not remember your preferences. In another example, if you do not provide your personal information when requested we may not be able to provide you with requested materials, disclosures or Services.
THIRD PARTIES
We remain responsible for all personal information communicated to other entities for processing on our behalf. As such, we ensure that other entities that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was communicated. You can find specific details about to whom we disclose your personal information in the section titled What Information We Collect And Disclose And For What Purposes.
LIMITATIONS
We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.
We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.
We do not, as a condition of providing the Website or performing the Services, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law or regulation.
RETENTION OF PERSONAL INFORMATION
We may keep a record of your personal information, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.
INTERNATIONAL TRANSFER NOTICE
Please note that your personal data may be disclosed to our affiliates and service providers located in countries other than your country of residence, such as the United States, Costa Rica, the United Kingdom, and Germany. These entities may disclose your personal data in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in their jurisdictions or countries.
Our service providers located in other countries are authorized to process your personal data to:
- facilitate your use and our provision of the Website;
- facilitate the provision of our Services to our customers;
- store and host data;
- provide administrative and operational services to us;
- measure, track and analyze trends and usage in connection with your use of or the performance of our Website and Services; and
- market and advertise our Services.
When we transfer or store personal data outside countries that require legal protection for international data transfer, we will ensure that an adequate level of protection is provided by the destination country, enter into written data processing agreements with recipients that require them to provide an adequate level of protection, or rely on other legally-approved transfer mechanisms. You can obtain more information about our policies and practices regarding our use of service providers by contacting our privacy office at dataprivacy@gofurther.com.
If you are a resident of the UK, Switzerland or EEA, we will:
- Process your personal data in a territory which the European Commission (or its equivalent in Switzerland or the UK) has determined provides an adequate level of protection for personal data;
- Implement appropriate safeguards to protect your personal data, including transferring it in accordance with applicable transfer mechanisms, such as the following:some text
- European Commission’s Standard Contractual Clauses (available here);
- The UK’s Information Commissioner’s Office International Data Transfer Agreement (available here); or
- Switzerland’s Transborder Data Flow Agreement (available here); or
- Enter into data processing agreements with recipients that require them to provide an adequate level of protection, or relying on other legally-approved transfer mechanisms.
ACCESS AND RIGHTS TO YOUR PERSONAL INFORMATION
There are a number of data privacy laws that provide specific data subject rights to residents of certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we possess information will have access to these rights and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:
- you do not live in a jurisdictions that grants you the specific right that you have requested;
- the information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information;
- we are prevented by law, regulation or rule from complying with your request;
- we are not able to comply with your request without incurring disproportionate burden or expense; or
- if complying with your request conflicts with the integrity of our services or the ability to administer our business, to administer our business and related relationships or to establish, defend or administer legal claims.
If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.
Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal information:
- if we process your personal data based on your consent, you have the right to withdraw your consent at any time for further processing;
- you have the right to request access to, rectification or deletion of your personal data;
- you have the right to object to the processing of your personal data;
- you have the right to request us to transfer your personal data to another controller; and
- you have the right to request us to restrict the processing of your personal data.
You can submit your request to exercise your data rights through the below:
Finally, you have the right to raise a complaint with us or the appropriate data protection authority of your country of residence if you feel that our processing of your personal information violates your individual rights, is not in line with this International Policy or violates the privacy principals, laws or regulations of your country of residence.
- You can contact our privacy officer by using the information provided under Contact Us. We will promptly investigate any complaint and will respond within the timeframes describe in this International Policy.
- If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
- If you are a resident of Switzerland, you can contact your data protection authority through the information provided in this link.
- If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
- If you are a resident of Australia, you can contact your data protection authority through the information provided in this link. You can view the Australian Privacy Principles through this link.
- If you are a resident of Canada, you can contact your data protection authority through the information provided in this link.
RESPONSE TIME
We will make every reasonable effort to respond to your written request not later than 30 days after receipt of such request. We will advise you in writing if we cannot meet your request within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority, as detailed in this International Policy, with respect to this time limit.
COSTS
We expect to be able to respond to your request without charge as a general matter. However, where allowed by law, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.
IDENTIFYING YOU IN CONNECTION WITH REQUESTS
We may require that you provide to us additional information to identify yourself before we provide information about the existence, use or disclosure of your personal information in our possession. Any such information that you provide to us shall be used only for this purpose.
OPT-OUT AND UNSUBSCRIBE
You may opt-out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications that are necessary to maintain the existing business relationship between you and us, to the extent there is one.
We use remarketing services to advertise on third party websites to you after you visited the Website. We and our service providers use cookies to inform, optimize and serve ads based on your past visits to our Website. We only engage in remarketing with your consent through the acceptance of a cookie banner when you access appropriate webpages. You can opt-out of this marketing by deleting all Further related cookies and restrict further collection of cookies using the methods outlined in our Cookies Policy.
ACCURACY
We will use reasonable efforts to ensure that your personal information is kept as accurate, complete and up to date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the data that you have provided to us.
You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.
SAFEGUARDS
We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.
CONTACT US
To submit questions or to inquire about or submit a request relating to data rights, our privacy office can be contacted at dataprivacy@gofurther.com.
