Last Update: June 1, 2019
firmTRAK (“firmTRAK”, “We”, “Our”, “Us”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, that you provide to us, or that is provided to us by a Subscriber to our Services (under the brand name firmTRAK), will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.firmtrak.com or any other website owned or operated by firmTRAK (collectively “firmTRAK Websites”), you are accepting and consenting to the practices described in this policy.
2. Information We May Collect From You
We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our firmTRAK Websites or by corresponding with us by phone, e-mail, or otherwise. This includes information you provide when you register to use our site, subscribe to our Service, participate in any discussion boards, forums, or other social media functions on our site or enter a competition, promotion, or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address, and phone number, financial and credit card information, personal description and photograph. We also store the Content that you upload or provide to the Service in order to provide you with the features and functionality of the Service.
- Information we receive from other sources. We may receive information about you from individuals or corporate entities which are Subscribers to our Service (“Subscribers”), where you are to be designated a user of our Service. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, subcontractors in technical, payment, and delivery services, advertising networks, insurers, insurance brokers, analytics providers, search information providers) and may receive information about you from them, subject to your agreements with them.
Please note that our Service requires you to provide us with certain personal data. If you choose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of the site and for us to respond to your queries.
4. Tracking Technologies
Technologies such as: cookies, beacons, tags, and scripts are used by firmTRAK and our marketing partners, affiliates, or analytics or online customer support service providers.
These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
5. Analytics/Log Files
Log Files – As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exist pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
6. Uses Made of the Information
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us, or between a Subscriber and us, and to provide you with the information, products, and services that you or a Subscriber request from us;
- to provide you with information about other goods and services we or our third-party affiliates or business partners offer;
- to provide you with information about goods or services we feel may interest you, including providing you with information about goods and services similar to those that were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we may contact you by electronic means;
- to notify you about changes to our Service; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to carry out our obligations arising from any contracts entered into between a Subscriber and use;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our Services, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to provide you with information about other goods and services we or our third-party affiliates or business partners offer; and
- to make suggestions and recommendations to you, Subscribers and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give us and information we collect from you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- Information you give to us. We will use this information:
7. Disclosure of Your Information
We may share your personal information with any member of our group, which includes our subsidiaries, affiliates, business partners, agents, and other designated third parties.
We will not share personal information about you or any Content with any third parties, except as described in this Private Policy or in connection with the Services. Data we share with third parties may be in aggregate form or may be personally identifiable. We may share your information with selected third parties, including:
- Business partners, vendors, suppliers, and subcontractors for the performance of any contract we enter into with you or a corporate entity which is a Subscriber.
- For sales and marketing purposes related to the Service or selected third-party affiliates and business partners.
- Analytics and search engine providers that assist us in the improvement and optimization of our site.
- Aggregated demographic information from our user base with or without personally identifiable data.
In certain situations, firmTRAK may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If firmTRAK or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of service and other agreements; or to protect the rights, property, or safety of firmTRAK, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- If firmTRAK is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via e-mail and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Some of our pages utilize framing techniques to serve content to/from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to third parties and not to firmTRAK.
8. User Access and Choice
firmTRAK will make commercially reasonable efforts to provide you reasonable access to any of your personally identifying information we maintain at your request. If your personally identifiable information changes, or if you no longer desire our Service, you may request to amend your personally identifiable information by postal mail at the contact information listed below, or at https://firmtrak.com/contact/ or calling (309) 807-2885.
221 East Front Street
Bloomington, IL 61701
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as described in this Policy, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Opt-out Preferences
Out of respect for your privacy, you may choose to stop receiving our marketing information e-mails by following the unsubscribe instructions included in these emails, accessing the e-mail preferences in your account settings page, or you can contact us at firmtrak.com/contact/ or by calling (309) 807-2885.
10. Where We Store Your Personal Data
All information you provide to us is stored on secure servers in a controlled environment with limited access. Any payment transactions will be made using encrypted technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
While no transmission of information via the internet is completely secure, we take reasonable measures to protect your personal data, and we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
11. Your Rights
You have the right to ask us not to process your personal data for marketing purposes. You can also exercise the right at any time by contacting us at https://firmtrak.com/contact/ or calling (309) 807-2885.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. Your California Privacy Rights
Under California law, (CCPA), California residents are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. The notice will identify the categories of personal information shared with third parties, as well as the name and address of the third parties that receive such personal information. If you want a copy of this notice, please submit a written request to the following address:
221 East Front Street
Bloomington, IL 61701
13. Social Media
Our website includes publicly accessible blogs or forums. Any information you provide in these areas may be read, collected, and used by others who access them. This includes information posted on our public social media accounts. To request removal of your personal information from our blog or community forum, contact us at [preferred email] In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We may display personal testimonials of satisfied customers on our site, along with other endorsements. If you wish to update or delete your testimonial, you can contact us at https://firmtrak.com/contact/ or calling (309) 807-2885.
15. Import Contacts
You can import contacts from your Outlook or other e-mail account address book to invite them to become members of our site. We collect the username and password for the e-mail account you wish to import your contacts from and will only use it for that purpose.
16. Our Policy Toward Children
This Service is not directed at individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us at [preferred email] If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.
17. GDPR Rights and Preferences
The European Union’s General Data Protection Regulation, or “GDPR,” gives certain rights to European residents in relation to their personal data. We have implemented transparency and organizational changes to allow and help users take advantage of those rights.
If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for the purposes specified in Uses Made of the Information will be deleted. If at any point you wish for us to delete information about you, you can simply contact us at https://firmtrak.com/contact/ or calling (309) 807-2885.
You have the right to request access to the information we have on you. You can do this by contacting us at [preferred email]. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfill your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.
Data Protection Policy
Last Updated: June 1,2019
- “Company” shall mean Marvel Solutions LLC d/b/a firmTRAK
- “Authorized User” shall mean an individual subscriber or the partners, members, employees, temporary employees, and third-party subscribers with a subscription to the Service who have been added to the account as users.
- “Policy” shall mean this entire
- “GDPR” shall mean the General Data Protection Regulation.
- “Responsible Person” shall mean person assigned the responsibility for data protection with the Company.
- “Register of Systems” shall mean a register of all systems or contexts in which personal data is processed by the Company.
2. Data protection principles
The Company is committed to processing data of Authorized Users in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- “processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
- This policy applies to all personal data of Authorized Users processed by the Company.
- The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Company shall register with the Information Commissioner’s Office as an organzation that processes personal data.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.
4. Lawful purposes
- All Authorized User’s data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests [(see ICO guidance for more information)].
- The Company shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data minimization
- The Company shall ensure that personal data of Authorized Users are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Company shall take reasonable steps to ensure personal data of Authorized Users is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data of Authorized Users is kept up to date.
7. Archiving / removal
- To ensure that personal data of Authorized Users is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data of Authorized Users is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Company shall ensure that personal data of Authorized Users is stored securely using modern software that is kept-up-to-date.
- Access to personal data of Authorized Users shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data of Authorized Users is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
What is a cookie?
A cookie is a simple text file that is stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers.
Cookies may be set by the website you are visiting (‘first party cookies’) or they may be set by other websites who run content on the page you are viewing (‘third party cookies’).
What do cookies do?
- Preferences: When you are signed in to your account, cookies help us display the correct information and personalize your experience, by providing you with features, insights, and customized content. They can also help you fill out forms more easily, e.g., RFI forms. Loss of the information stored in a preference cookie may make the Site experience less functional but should not prevent it from working.
- Session State: We collect information about how our Users and Members use and interact with the Site. This may include the pages Members visit most often and when and where Members get error messages. We use these “session state cookies” to help us improve our Site and Services. Blocking or deleting these cookies will not prevent the Site from working.
What third-party cookies does firmTRAK use?
[Include information and links to the companies your company partners with—the paragraph and links below are an example of the types of companies you should list]
What should you do if you don’t want cookies to be set?
Some people find the idea of a website storing information on their computer or mobile device to be intrusive, particularly when this information is stored and used by a third party without them knowing. Although cookies are generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests using your browser history. If you prefer, you may choose to block some or all cookies, or even to delete cookies that have already been set; but you should be aware that you might lose some functions of the website.
If you want to restrict or block the cookies that are set by our Site, or any other site, you can do so through your browser setting. The ‘Help’ function in your browser should explain how. Alternatively, you can visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers. You will find general information about cookies and details on how to delete cookies from your machine.
To opt-out of third-parties collecting any data regarding your interaction on our Site, please refer to their websites for further information