Effective Date: June 4, 2021
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 6 below), please avoid any interaction with us or any use of our Services (or certain parts of our Services). If you are a User of the Platform on behalf of any of our Customers, we suggest that you contact your account administrator with any questions.
The data we process regarding our Prospects, Customers and their Users and Consumers (“you” or “your”), is typically collected and generated through automatic means, directly from you, through your interaction with us or with our Services; from our Customers, who provide us with their Users’ and Consumers’ data; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.
The definition of terms like “Personal Data”, “Personal Information”, “Personally Identifiable Information” and the like, may vary in different jurisdictions and in different laws. To the extent any of the information described in this section is not considered to be information which is protected by the laws which are applicable to you, we will not regard it as personal data, and this Policy will not apply to it.
FUSE processes the personal data described in Section 1 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use your data for the following purposes:
We retain your personal data for as long as it is reasonably necessary to provide you with our Services and offerings and to maintain and expand our relationship; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations, and where applicable, also with our Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at email@example.com.
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications with our Users.
If you do not wish to receive such promotional communications, you may notify FUSE at any time by sending an e-mail to: firstname.lastname@example.org or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under any applicable law, including the CCPA, or the Fair Credit Reporting Act (FCRA), such as the right to request access to, and rectification or erasure of your personal data held with FUSE, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices, or the right to receive the contact information of the relevant credit bureau (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: email@example.com.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding data we process on our Customer’s behalf, please contact the administrator of such Customer’s account directly. For example, if you are a User or a Consumer of our Customer and you wish to access, correct, or delete data processed by FUSE on behalf of our Customer, please direct your request to the relevant Customer (who is the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our Customer and its Users.
Certain data protection laws and regulations, such as the CCPA, typically distinguish between two main roles for parties processing personal data: the “business”, who determines the purposes and means of processing; and the “service provider”, who processes the data on behalf of the business. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
(ii) With respect to User data, FUSE assumes the responsibilities of both a “business” and a “service provider”. Such data is partially processed by FUSE for its own purposes (as described in Section 2 above), as a “business” whilst other aspects of Users’ data will be processed by us on our Customer’s behalf, as a “service provider”.
(iii) With respect to Consumer data, FUSE assumes the responsibilities of a “service provider”, processing the data on behalf of our Customer (the “business”). In such instances, our Service Providers processing such data will assume the role of “third-parties”.
Accordingly, FUSE processes Consumers personal data strictly in accordance with such Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer. The Customer, as controller of such data, will be responsible for meeting any legal requirements applicable to business. For the avoidance of doubt, each Customer is solely responsible for providing adequate notice to their Users and Consumers whose personal data may be processed – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.