FourThirds Online Privacy Statement

FourThirds is committed to protecting the privacy of confidential and personal information, including personal data relating to individuals who may be clients, staff, agents, personnel, students, job applicants or professionals in the high tech, financial services, government or professional services sectors or others inside or outside of FourThirds. This Privacy Statement is based on the privacy and data protection principles applicable in the countries in which we operate and the Safe Harbor Framework established by the United States Department of Commerce. We apply it in light of our over-arching obligations to comply with the law, and commitments to preserve confidential information.

This Privacy Statement is intended to summarize FourThirds’s data protection practices generally, and to advise our clients, interested students, job applicants, website visitors, and other third parties about our privacy policies that may be applicable to them.

This Privacy Statement applies to data collected by FourThirds through its Website and services and is specifically addressed to parties outside FourThirds who provide personal information to FourThirds or who visit or use FourThirds’s Website. It does not apply to those FourThirds sites, services and products that do not display or link to this Privacy Statement or that have their own privacy statements.

Your Consent
IMPORTANT: BY SUBMITTING PERSONAL DATA TO FOURTHIRDS AND/OR BY USING THIS WEBSITE YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY FOURTHIRDS IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW.

Collection and Use of Personal Data

FourThirds does not collect from visitors to its Website any personally identifiable information about you, such as your name, job description, e-mail address or mailing address (“Personal Data”) that is not voluntarily provided. You do not have to submit any personal data in order to use this website. If you do provide Personal Data, we may combine such Personal Data with other publicly available data about you and use that data for the following purposes:

• We may contact you occasionally to inform you of new products and services we will be providing.
• We may send you regular updates on issues we think will be of interest to you.
• We may send you requested information on our products and services.
• We may use your Personal Data for marketing purposes and market research.
• We may, in circumstances where we act as a Data Processor for third parties, process your data strictly in accordance with the instructions of that third party.
• We may use your Personal Data internally to administer this Website and to help us improve our services.
• We may use your Personal Data in processing your job application to FourThirds. Such processing may include evaluation of your application for other positions within FourThirds for which you may be interested or qualified.
• We may provide you with services, if you are or become a client of FourThirds, and/or deal with any requests or inquiries you may have.
• We may use your Personal Data to enter into or carry out contracts of various kinds.
• We may use your Personal Data to comply with applicable laws or regulations in a country.
If you do not wish to receive e-mails or mail from us for these purposes, please let us know by contacting us as described below.

User Postings
Our site may contain areas where you may be able to publicly post information and communicate with others, such as blogs and discussion boards. We may collect and process any information that you post on our website. Prior to posting in these areas, please read our Terms of Use carefully. All the information you post will be accessible to anyone with Internet access, and any Personal Data you include in your posting may be read, collected, and used by others. Please avoid posting Personal Data.

The content of this site is intended to be informative and is not professional or business advice.

Confidentiality of Client Information
Consistent with our client obligations, it has always been the policy of FourThirds to exercise the utmost discretion regarding the information our clients entrust to us. FourThirds accepts and processes confidential client information always subject to the client’s direction and control, and FourThirds maintains reasonable and appropriate, although not infallible, security precautions. Operating internationally, we operate systems that may make data related to your matters accessible from our various offices around the world and often transfer client data between our offices. We never trade, sell or share your information with any unrelated parties except as necessary or appropriate to conduct FourThirds’s business activities, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party, or to further your interests or as permitted or required by law or as authorized or directed by you. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to the FourThirds Principal who is handling your matter or [email protected].

Disclosure and Transfer of Personal Data
We do not share, sell, or distribute your Personal Data to unrelated third parties outside of FourThirds, except to our agents or data processors or other contractors acting on our behalf and at our direction, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party, or where we believe it necessary to provide a service which you have requested, or as permitted or required by law, or as otherwise authorized or directed by you, including and under these limited circumstances:

Personal Data may occasionally be transferred or shared with or among FourThirds’s direct or indirect affiliates for further processing in accordance with the purposes for which such Personal Data was originally collected. We may also share your Personal Data with third parties who we use to support our business. For example, sometimes a third party may have access to your Personal Data in order to support our information technology or to handle mailings on our behalf or for validation services within the context of recruitment.

• Where you have consented, we may also share your Personal Data with or among FourThirds’s direct or indirect affiliates or with other businesses who may contact you about their products or services that may interest you.

• We may also share your personal information with other companies within our group of companies or disclose your personal information to other businesses may wish to receive and use research data about you. Where we do so we will anonymize your information as far as possible, so that you cannot be identified.

We may share, transfer or disclose the information in our databases and server logs to comply with a legal requirement, for the administration of justice, interacting with anti-fraud databases, to protect your vital interests, to protect the security or integrity of our databases or this Website, to take precautions against legal liability, or in the event of our sale, merger, reorganization, dissolution or similar event. We will inform you of any such transfer or disclosure as required by law.
Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

We may transfer your Personal Data to other affiliated offices of FourThirds for the purposes set out for use of Personal Data in this Privacy Statement. Such transfers may involve the transfer of your information between jurisdictions and outside of the jurisdiction in which you submitted your information, including to jurisdictions which the European Union may not deem to provide “adequate” data protection. Please do not provide us any information that you do not wish to be transferred between our offices.

Safe Harbor Policy
FourThirds, Inc. abides by the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework as established by the United States Department of Commerce regarding the collection, use and retention of personally identifiable information (PII) originating from the European Union and Switzerland. FourThirds has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement with respect to PII. To learn more about the Safe Harbor program, and to view FourThirds’s certification, please visit the Safe Harbor website.
FourThirds’s use of PII may be governed by additional requirements described below:

• PII obtained from or relating to clients or former clients of FourThirds is also subject to the terms of any applicable contractual client agreements, laws and/or professional standards

• Certain websites maintained by FourThirds may have their own privacy policies, accessible on their respective websites, regarding the collection of PII on those sites

Access
If you are an individual, you may have certain rights under applicable data protection legislation which includes the right for you to review and correct the Personal Data we hold about you. We may charge you a fee to receive a copy of this data. We will also correct, amend or delete any Personal Data that you inform us is inaccurate and notify any third-party recipients of the necessary changes. Requests to delete Personal Data are subject to any applicable legal and ethical reporting or document retention obligations imposed on us. For a copy of or reasonable access to your Personal Data, please contact: [email protected].

Sensitive Information
We do not intend to seek or collect any sensitive information through our Website unless it is legally required for recruiting purposes. All references to “sensitive information” are to the various categories of personal data identified by applicable data privacy laws as requiring special treatment. These categories can include data relating to age, gender, ethnic origin or race, marital status, political opinions or affiliations, trade union membership, religious beliefs, physical or mental health, disability, sexual orientation or criminal record. We suggest that you do not provide sensitive information of this type to us. If you do provide any sensitive information to us, you explicitly consent by doing so to allow us to use such sensitive information as Personal Data in the ways described in this Privacy Statement, subject to applicable laws.

Where we have obtained your express consent, we may use your sensitive personal data for the purposes specified in this Privacy Policy, including for research purposes.

Anonymous Data Collected through this Website
In addition to the information we collect as described above, we use technology that automatically collects anonymous information about the use of our Website. For example, our web server automatically logs which pages of our Website our visitors view, their IP addresses and which web browsers our visitors use. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our Website, which we may use, for example, to improve our Website.

Our Website contains hyperlinks to other pages on our Website. We may use technology to track how often these links are used and which pages on our Website our visitors choose to view. Again, this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

Data Collected through Tools and Surveys on this Website
You may voluntarily participate in a survey or other tool available on this website. FourThirds compiles data collected from its online surveys and tools to produce benchmarking reports for respondents, FourThirds Clients, and other third parties. Any information provided by you as a respondent to our online surveys or tools will be anonymized and aggregated before such information is shared with a third party. The data you provide will become the property of FourThirds and may be used by FourThirds.

We may use the data we collect through survey or tool results to provide you with feedback, to provide industry information to others, and/or to help us provide and improve our overall services.

Cookies
In order to collect the anonymous data described in the preceding paragraph, we may use “cookies” that remain in the cookies file of your browser until the browser is closed.

A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through this Website may not function properly if your cookies are disabled.

We use cookies to improve the quality of our website by storing user preferences and monitoring user trends, as well as to deliver services requested by you. We use several types of cookies on our website:

Authentication and authorization cookies (i.e. strictly necessary cookies) allow access to secure areas and specific functionality of the website. These are strictly necessary for the proper operation of our website and the service we provide to you.

Personalization cookies (i.e. functionality cookies) allow the website to remember choices you make and provide enhanced (more personalized) features. They may also be used to provide services in the way you have specified, such as collating data in a report.

Tracking cookies (i.e. performance cookies) collect information about how you use our website; what pages you visit and how often. We use this information to improve our website and the service we provide to you.

We also use your IP address to help diagnose problems with our server, to administer our Website AND TO IMPROVE THE SERVICE WE OFFER TO YOU. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address may also be used to gather broad demographic information.

We may also perform IP lookups to determine which domain you are coming from (i.e.: aol.com, yourcompany.com) to more accurately gauge our users’ demographics.

In connection with our marketing activities, information from these types of cookies and technologies or about your website usage may be combined with identifiable information provided by you via the website (e.g. when you request a white paper or more information), and publically available information about you from third party sources.

BY USING OUR WEBSITE YOU AGREE THAT WE CAN PLACE THESE TYPES OF COOKIES ON YOUR DEVICE.
Non-Anonymous Data Provided through this Website
Your access to and use of this Website, if through an identification code or password, is monitored by us, and the data provided by you is ascribed to you.

Links to Other Websites
This Website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.

Transfer of Data Abroad
If you are visiting this Website from a country other than the country in which our servers are located (currently the United States), the various communications will necessarily result in the transfer of information across international boundaries.
As FourThirds has legal entities operating components of our Website worldwide, transfers of your personal information may be to countries which provide varying levels of protection of personal data.

By visiting this Website and communicating electronically with us, you consent to the processing and transfer of your Personal Data as set out in this Privacy Statement.

Children
In order to respect the privacy of children online, FourThirds does not knowingly collect, maintain or process Personal Data submitted by children under the age of 13.

Security
We maintain reasonable and appropriate physical, electronic and procedural safeguards intended to maintain the confidentiality of Personal Data provided by a visitor to this Website. We do not guarantee that our safeguards will always work.

Changes
We reserve the right to change this Privacy Statement at any time without advance notice. Should any new policy go into effect, FourThirds will post it on this Website.

Marketing
We like to keep our clients, personnel and other interested parties informed of events and news of interest to them. If you do not want to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by sending an e-mail with your instructions to [email protected]

Contractors, Suppliers and Vendors
In order to support its provision of services to its clients, from time to time, FourThirds may maintain business information about prospective or ongoing contractors, suppliers, and vendors. We use this information for internal purposes and do not share this data with unrelated third parties.

We expect contractors, suppliers, and vendors to maintain data protections consistent with reasonable and appropriate obligations of data processors including, where applicable, the European Union’s Data Protection Directive (95/46/EC). Any prospective contractors, suppliers, or vendors with questions about our policies and expectations should contact us at [email protected].

Governing Law
This Privacy Statement forms part of our Website Terms of Use, and the substantive laws of the State of California govern any controversy or claim of whatever nature arising out of or relating to the use of this Website, without regard to any conflict of laws provisions. All actions or proceedings arising out of or relating to this Privacy Statement, its validity, performance, enforcement or breach, or the subject matter of this Privacy Statement may be venued in the courts of the State of California, and you hereby irrevocably consent and submit yourself to the personal jurisdiction of said courts for all such purposes. Notwithstanding the foregoing, we retain the right to bring legal proceedings in any jurisdiction where we believe that breach of this agreement is taking place or originating..

Controlling “Spam” or Unsolicited E-mail
FourThirds is concerned about controlling unsolicited commercial e-mail, or “spam.” FourThirds prohibits the use of its Website or services linked to send spam. There is no currently available technology that will totally prevent the sending and receiving of unsolicited e-mail. Using junk e-mail tools and being cautious about the sharing of your e-mail address while online will help reduce the amount of unsolicited e-mail you receive.

Contacting Us
FourThirds welcomes comments about this Privacy Statement. If you have any questions about this Statement or any part of our service, you may contact at:

FourThirds, Inc.
Attn: Legal Department
260 Joseph Lane
Pleasanton, CA 94588
[email protected]

Definitions
References in this Website and this Privacy Statement to “FourThirds”, “we”, “us”, and “our” are references to FourThirds, Inc. and its direct or indirect affiliates.

When referring to FourThirds in this Website and this Privacy Statement as a “firm”, we are referring collectively to FourThirds, Inc. and its direct or indirect affiliates.

The terms “you”, “your” and “yours” when used in this Privacy Statement mean any user of this Website.

The terms “Data Processor” and “Data Controller” have the following meanings ascribed to them in the Data Protection Directive (EU Directive 95/46/EC):

The term “Data Processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the Data Controller.

The term “Data Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of Personal Data; where the purposes and means of processing are determined by natural or Community laws or regulations, the Controller or specific criteria for his nomination may be designated by national or Community law.

The term “PII” shall mean Personally Identifiable Information.

The U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework shall have the meaning found at the following links: U.S. – EU Safe Harbor Framework U.S. – Swiss Safe Harbor Framework

The term “Website” shall mean all FourThirds’s websites linked to this Online Privacy Statement.