1. INTRODUCTION

FEIN Collections [made in new york city] (“FEIN”, we”, “us”, “our”) are committed to protecting and respecting your privacy.  This Privacy Policy (the “Policy”) (together with our Terms) sets out the basis on which any personal data we collect from you, or that you provide to us, via our Website and communications with you, will be processed by us. PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR VIEWS AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE WILL USE IT TO PROVIDE THE SERVICES OFFERED THROUGH OUR WEBSITE.  By using our Website, products or any of our services (collectively, “Services”), you consent to the collection, use, processing, and sharing of your information as described in this Policy.

Who We Are

FEIN Collections is the controller and responsible for your personal data.

Our contact details are:

FEIN Collections [made in new york city]
Unit 7
Old Mill Business Park,
Station Road Industrial Estate,
Bruton,
Somerset BA10 0EH

Email address: danielle@feincollections.com
Website: https://feincollections.com

2. INFORMATION WE MAY COLLECT AND PROCESS

We may collect and process the following data about you:

Information You Give Us

We may collect the information that you give us (such as name, email address, phone number) or otherwise make available to us when you access or use our Services, including when you:

  • fill in any forms on our Services, [such as when you register for a FEIN account] or update your account or user profile information;
  • access or use our Services, this can include the information you provide on or through our Services, and information about how you access or use our Services, such as which features you use and when you use them;
  • communicate with us.

Information We Collect About You

We may automatically collect the following information:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to contact us (whether directly or through the use of third party-analytics tools) to help us measure traffic and usage trends for the Service.
  • All information collected through the Google Analytics service is anonymised.

We do not intend to process any special categories of data.

Information We Collect From Others

We may obtain information about you from third-party partners (such as other companies with which we may jointly offer services or conduct promotional events), third-party service providers, payment providers, including but not limited to demographic information, contact information, open data, publicly available data and credit check information. We may use this information for legitimate business purposes, including the performance of a contract, customer support, fraud prevention, and credit-related decisions in connection with our Services, along with other purposes described in this Policy.

[We may receive data (such as a payment token) from our payment partners such as [PayPal] [Stripe] to enable us to process payments and provide you with what you have purchased. However we do not receive or hold any card information.]

We may obtain certain analytical data, web user stats, such as cookie ID or other analytics from third-party analytics service providers that enables us to improve our Services, provide dashboard and overview information and review how content has been viewed.

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

Information from Mobile Use

When you access our Services on a mobile device, for example, when you download or use a [FEIN mobile application] or visit our Website from a mobile browser, we may obtain information about your location and mobile device, including a unique identifier for your device which information may be used for legitimate business purposes. Along with the other purposes described in this Policy, we may use this information in order to customize our Services, Content and marketing for your location. Most mobile devices let you disable location services, and your choices for location services may vary depending on your mobile device.

Cookies

When you visit our Website, we send one or more cookies – a small file containing a string of characters – to your computer that uniquely identifies your browser. 

No personal data – such as your name, address, contact phone numbers or email address – will be collected if you are only browsing our Website. Some of our cookies may collect your IP address, but if you are only browsing and provide no additional personal data, we would not be able to identify you from that information. [Please see our cookie policy for more information in this respect.]

3. HOW WE USE YOUR INFORMATION

The information we collect helps us to operate, improve, protect, and customise our Services, as well as develop new Services. The information we collect also helps us provide customer support and make our Services more efficient for you and other users.

For the sake of transparency, it is our responsibility to outline for you the legitimate business purposes for the collection of information and the reasons why we do so, in order for you to make an informed decision regarding the use of our Services.

In addition to the other uses of information described in this Policy, we may use all of the information that we obtain from or about you for the following purposes and reasons:

  • to provide our Services to you, including new Services we develop later (reason: legitimate business purpose and performance of a contract);
  • to provide you with customer support (reason: legitimate business purpose);
  • to facilitate your communications or transactions with us (reason: to receive consent, and for legitimate business purpose);
  • to operate, improve, and customise our Services, content, and marketing, to develop new Services, and to understand how you use and interact with our Services and content (reason: legitimate business purpose);
  • if necessary, to develop and display more customised content and ads to you on or off our Services (reason: to receive consent, and for legitimate business purpose);
  • to promote and maintain a trusted, safer, and more reliable environment on our Services, for example, to help detect, prevent or otherwise address fraud, security or technical issues, conduct investigations or risk assessments, or verify actions taken by you or associated with your account (reason: to protect the public interest and for legitimate business purpose);
  • to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to address issues with your account or use of our Services, collect fees, send you updates about our Services or policies, or for other purposes permitted by law (reason: performance of a contract and for legitimate business purpose);
  • to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorised by you) in order to send you marketing communications, promotional messages, and offers about our Services and content (see below for information on how to opt out of receiving certain communications from us) (reason: to receive consent, and for legitimate business purpose);
  • to comply with our legal obligations, resolve disputes, or enforce our Terms or any other FEIN policies (reason: compliance with a legal obligation); and
  • to perform other functions as described when the information is collected or requested, or for other purposes with your prior consent (reason: legitimate business purpose).

4. DISCLOSURE OF YOUR PERSONAL DATA

We will treat your personal data with complete respect and will not disclose it to any third party, other than to those necessary or appropriate in connection with any of the purposes for which we use personal data, including to subcontractors or service providers, for example, outsourced development team, that help host or support the relevant sites or application services, or otherwise provide technical assistance to us.

We use third-parties, including [Stripe], to gather your data from financial institutions. By using our Services, you grant our third-party providers the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to terms of such third-party providers’ privacy policies and service terms.

We may also disclose your information to third parties as follows:

  • In connection with the sale or transfer of all or part of our business.
  • As required by law and or in the good faith belief that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, bankruptcy or similar legal process.

Where we use third party service providers as outlined above, we choose parties which we believe offer a secure service and help us enhance our Services or practices, and follow any legal requirements that may apply.

5. SECURITY

Every FEIN account is protected by a password to help maintain privacy and security on our Services. If you register for an account, we urge you to use a strong password containing unique numbers, letters and special characters, and to protect the confidentiality of your password at all times. If you suspect or become aware of any unauthorized access to or use of your account or password, you agree to immediately notify us and change your password. Please note that while we seek to protect your information and maintain the security of our Services, due to the possibility of hardware or software failure, unauthorized entry or use and other factors, we cannot guarantee the security of any information, whether online or offline. Any transmission of information is at your own risk.

6. EU AND UK RESIDENTS

You have the right to ask us not to process your personal data for marketing purposes. You may also choose not to receive publications or certain other communications from us at any time by opting-out by email or via direct marketing emails sent to you.

In addition to the right referred to above, you also have the following rights:

  • Correction right – the right to correct inaccurate or incomplete personal data held by us.
  • Erasure right – you can request erasure of your personal data if it is no longer necessary for Us to retain it for the purpose for which it was collected, if you withdraw your consent, if you have objected to Our processing and We have no other justification for processing the data, if it was processed unlawfully or if We are under a legal obligation to erase the data. If one of these grounds exist and we have no other legitimate grounds for retaining or processing your data, we will erase it without delay.
  • Right to object – you can object to our processing of your data. We will stop processing the data unless we can demonstrate a compelling legitimate ground.
  • Restriction right – this will apply if you contest the accuracy of the personal data We hold, until We can verify its accuracy; if the processing is unlawful; if you wish Us to preserve it for a legal claim or if you object to processing based on our or a third party’s legitimate interests, until We decide which interests prevail. We will notify you before lifting a restriction.
  • You have the right to make a complaint at any time to your supervisory authority. In the UK this is the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you wish to exercise any of your lawful rights or have questions in this regard, please reach out to us via the contact details provided below.

Our Website may, from time to time, contain links to and from other websites. 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.

7. ADDITIONAL INFORMATION FOR CUSTOMERS BASED IN THE UNITED STATES – CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “Personal Information” (in this section, all terms as defined in the California Consumer Privacy Act (“CCPA”)).

Categories of Personal Information we collect

Throughout this Policy, we discuss in detail the specific pieces of Personal Information we collect from and about users. Under the CCPA, we are also required to provide you with the “categories” of Personal Information we collect. The categories, and some examples of what we may collect, are:

  • Identifiers; we may collect, e.g., name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
  • Customer records information; we may collect, e.g., name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit or debit card number, or other financial information
  • Characteristics of protected classifications under CA or federal law; we may collect, e.g., gender identity or age
  • Commercial and financial information; we may collect, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • Internet or other electronic network activity information; we may collect, e.g., browsing history, search history, or information regarding a consumer’s interaction with an Internet website, application, or advertisement
  • Geolocation data; we may collect, e.g., city, state, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, based on your mailing address
  • Inferences that could be used to create a profile about a consumer reflecting the consumer’s preference, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
  • Other Information, e.g., any other information you choose to directly provide to us in connection with your use of the Services

How we use your Personal Information.

We use and share the categories of Personal Information we collect about you consistent with the various business purposes we discuss throughout this Policy, as described in the “How we use your Information ” and “Disclosure of your Personal Data?” sections above.

CCPA rights disclosure 

If you are a California resident, the CCPA allows you or an authorised agent on your behalf to make certain requests about your Personal Information. Specifically, the CCPA allows you or your agent to request:

  • Right to know. Information about the categories of Personal Information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your Personal Information; and the categories of third parties with whom we share/disclose Personal Information. Such information is also set forth in this Policy.
  • Right to access. Provide access to and/or a copy of certain information we hold about you and that we have collected about you during the past twelve (12) months.
  • Right to request deletion. Delete certain information we have about you.
  • Information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request. You are also permitted to designate an authorised agent to subject certain requests on your behalf. To verify that your agent has been authorised to make a request on your behalf, we may require them to provide us with a signed written authorization or a copy of a power of attorney.

Right to non-discrimination 

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Sale of Personal Information 

Any data collected through our Website will be used for marketing and/or sales purposes as appropriate. We will not sell your Personal Information to a third party.

Shine the Light

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your Personal Information with third parties for their own direct marketing purposes, except with your consent.

8. CHILDREN’S INFORMATION

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal data from people in this age group. If you believe we may have collected personal data from anyone under the age of 18, please contact us.

9. HOW LONG DO WE STORE YOUR DATA FOR

We may keep records of any personal data obtained from you on or through our Website, or otherwise, for as long as we believe is reasonably required for our ongoing legitimate business needs, or such longer period as may be required for legal, audit and compliance purposes. This does not affect your right to opt out from receiving marketing communications, as outlined in the section “Communication Preferences” below or to request that we delete your data where you have the right to erasure.

  1. WHERE DO WE STORE YOUR PERSONAL DATA

We will keep your personal data secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage.

Our Website is hosted on secure servers based in London, United Kingdom.  The data that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area (“EEA”). It may also be processed by staff operating outside the UK and EEA who process account details and who provide support services. Transfers will only be made to countries which are the subject of an adequacy decision of the EU Commission or recipients who have entered into binding contracts with us to comply with the terms of this Policy and Data Protection Law. By submitting your personal data, you agree to this transfer, storing or processing.   For the purposes of this Policy, Data Protection Law means (i) the UK GDPR and Data Protection Act 2018, (ii), for customers in the EEA, the General Data Protection Regulation (GDPR), and (iii) and any national implementing laws of the GDPR, as amended from time to time and any successor legislation to the UK GDPR, the GDPR or the Data Protection Act 2018.

2. ACCOUNTS AND USER PROFILES

To register for a FEIN account, as and when this feature becomes available, you will need to do so by providing your full name and a valid email address. If you have received our permission to use our Services as a business, you may need to complete an additional registration process and provide additional information. If you have a FEIN account, you may access, add, remove or update certain information about you in your profile and account settings, as indicated on our Services. It is your responsibility to update all such information as necessary to keep it accurate and current. When you update your account or profile information, we may keep a record of the unrevised information for purposes consistent with this Policy. If you wish to cancel your account, you may do so by using the tools provided in your profile and account settings, subject to any other agreements between you and us and any transactions which have not yet been completed. If you terminate your account, we may keep a record of any or all information associated with you or your account, as required or permitted by law, for purposes consistent with this Policy, and any such data shall be attached to a unique identifier which cannot be used to identify you; specific account data that includes Personal Information including your name, e-mail, contact information, and certain other records such as settings and collector profiles will be removed at such termination. For further information, please contact us at [danielle@feincollections.com].

3. COMMUNICATION PREFERENCES

We provide registered users with settings on our Services to control whether they receive certain communications from us. If you do not want to receive marketing email from us, you can unsubscribe by following the unsubscribe link in the email you received, changing your preferences in your profile and account settings (if you have registered for a FEIN account), or emailing us at [danielle@feincollections.com]. You may not be able to opt out of receiving some communications from us, such as email about your account, your relationship with us, or your transactions. For further information, please don’t hesitate to contact us at [danielle@feincollections.com]. Please note that unsubscribing from receiving emails from us may result in a less robust experience of our Services.

4. DISPUTE RESOLUTION

As this Policy is part of our Terms, any disputes involving you and us that relate to privacy or the use of your information, and that arise out of or are related to this Policy or our Services, will be subject to our Terms, including any provisions regarding the limitation of damages and liability, choice of law, and dispute resolution.

Our business changes with time, and our Privacy Policy will change also. We reserve the right to change this Policy, without prior notice, at any time at our sole discretion. For example, and without limitation, we may change this Policy to reflect changes to the law or changes to our Services. All changes to this Policy will be effective when posted on our Services, or at such later date as may be specified in the updated Policy. We will notify you of any changes to this Policy by posting the updated Policy on our Services, and you agree to review this Policy regularly and inform yourself of all applicable changes. By continuing to use our Services after any changes to this Policy become effective, you agree to such changes and the updated Policy. Unless we notify you otherwise, the current version of this Policy will apply to all information that we have about you or your account.

5. CONTACT INFORMATION

If you have any questions about our Privacy Policy or the information practices of the services, please contact us at:

FEIN Collections [made in new york city]
Unit 7
Old Mill Business Park,
Station Road Industrial Estate,
Bruton, Somerset
BA10 0EH
United Kingdom

Email address: danielle@feincollections.com