Fusion Privacy Policy

Welcome to the Fusion Risk Management, Inc. (“Fusion”, “we” “our”, “us”) website.

Your privacy is important to us. This Privacy Policy explains how we collect, store, use and disclose your information when you use this website.

This Privacy Policy explains the following, amongst other things:

• Our principles with respect to your information and your privacy
• The information we collect about you
• How we use your information
• How we share your information
• How we use cookies and similar technology
• Your choices with respect to your information
• How to contact us regarding privacy issues

By using this website, you are consenting to the use of your information in the manner set out in this Privacy Policy.

For your convenience, information relating to our use of cookies and similar technologies is set out below in our Cookie Policy. The Cookies Policy forms part of the Privacy Policy, and whenever we refer to the Privacy Policy, we are referring to the Privacy Policy incorporating the Cookies Policy.

Please take some time to read this Privacy Policy (including the Cookies Policy), and make sure you are happy with our use and disclosure of your information.

If you do not agree to any of the provisions of this Privacy Policy, you should not use this website. If you have any questions or concerns, please contact us.

Please note that this Privacy Policy only applies to this website and Fusion’s marketing activities. When using this website, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. Fusion is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before sharing any personal data.

Data Controllers

When this policy mentions “Fusion,” “we,” “us,” or “our,” it refers to the Fusion entity that is responsible for your information under this Privacy Policy (the “Data Controller”).

• If you are located in the United States, Fusion Risk Management Inc. is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Platform;
• If you are located outside the United States, Fusion Risk Management Ltd. is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, this website — Fusion Risk Management Ltd. is a limited company incorporated in England and Wales under company number 11496765 whose registered office is at Griffin House, 135 High Street, Crawley, RH10 1DQ, West Sussex, United Kingdom;
• We may share your data within our corporate group of companies that are related by common ownership or control and data of US users may be processed by Fusion Risk Management Ltd. on Fusion Risk Management Inc.’s behalf.

Our Principles

We have a simple approach to data protection and privacy, which can be summarized as follows:

• You should know exactly what we do with your information. This Privacy Policy is designed to give you full transparency regarding our data protection practices. If there’s anything that’s not clear from this Privacy Policy, please contact us.
• You should have full control over your information. If you’d like your information removed from our records, please contact us and we will remove it as soon as possible (unless we have a lawful reason to retain it).

Information We Collect About You

We collect information about you from various sources:

Information provided by you

You don’t need to provide us with any personal data in order to visit this website. However, we may provide you with the opportunity to request information from Fusion and, by doing so, you will provide us with certain information:

• Essential information: When you register with Fusion, you will need to provide your first name, last name, title, company name and email address.
• Non-essential information: Your telephone number, if you wish to provide it, and comments.
• Information from correspondence: You will provide certain personal data if you contact us by email, or contact us by mail, fax or other offline means.
• Survey information: If you participate in any survey, you will provide certain personal data as part of your response, unless you respond anonymously.

Information we collect automatically

• There is certain information that we collect automatically as the result of your use of this website, or through the use of web analytics services as described in our Cookies Policy. This information includes but is not limited to:
• the Internet Protocol (IP) address of the device from which you access this website (this can sometimes be used to derive the country or city from which you are accessing this website)
• the site that you visited immediately prior to visiting this website
• the specific actions that you take on this website, including the pages that you visit, requesting information or, sending a comment or inquiry.
• the time, frequency and duration of your visits to this website your browser type and operating system
• the nature of the device from which you are accessing this website, for example, whether you are accessing this website from a personal computer or from a mobile device and its device-ID
• information collected through cookies and similar technology, as described in our Cookie Policy
• information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message

How We Use Your Information

We use the information that we collect about you for the following purposes:

Use of and interaction with this website:

• To provide you with information that you request.
• To respond to you about any comment or enquiry you have submitted.
• To contact you regarding our services and products if a demo is requested.
• To sign you up for an upcoming program.
• To seek your participation in surveys, and to conduct and analyze the results of those surveys if you choose to participate.

Improving and customizing this website:

• To analyze the use of this website, and the people visiting this website in order to improve it and customize it to the needs and interests of Fusion’s customers and website visitors.
• To customize your use of this website and/or the content of any email newsletter or other material that we may send to you from time to time.

For other purposes, provided we disclose this to you at the relevant time, and provided that you agree to the proposed use of your personal data.

Our Legal Basis for Processing Your Information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• Consent: where you have given us clear consent for us to process your personal information for a specific purpose
• Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

Please contact us for further information as to which particular lawful basis on which we rely when processing your personal information.

Sharing of Your Information

We will not share your information with any third party, except as described in this Privacy Policy (including our Cookies Policy). There are circumstances where we may need to share some of the information we collect about you or which you provide to us for the purposes set out above – these circumstances are as follows:

• With your consent: We will disclose your information if you have explicitly agreed that we may do so. We will make this clear to you at the point at which we collect your information.
• Service providers: We use certain reputable third parties, some of whom may be located outside of the European Economic Area (please also refer to “International Data Transfers” below), to provide us with certain specialized services related to this website. Our third party service providers will have access to certain information about you, but only where this is necessary in order for those third parties to provide their services to us. Where we transfer personal data to these third parties, we ask and require these third parties to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us.
• As aggregated data: We may aggregate your personal data with similar data relating to other users of this website in order to create statistical information regarding this website and its use, which we may then share with Service providers.
• If required by law: We will disclose your information if we believe in good faith that we are permitted or required to do so by law, including in response to a court order, subpoena or other legal demand or request.
• To protect our interests: We may disclose your information if we feel this is necessary in order to protect or defend our legitimate rights and interests, or those of our employees, directors or shareholders, and/or to ensure the safety and security of this website.
• In the context of a business transfer: We may transfer your information to any person or company that acquires all or substantially all of the assets or business of Fusion, or on a merger of our business, or in the event of our insolvency.

Cookies and Similar Technology

In common with most websites, we use cookies and other standard Internet technologies to help us improve this website. We have included information about our use of cookies and similar technology below in our Cookies Policy that forms part of this Privacy Policy. The Cookies Policy also includes information about how you can block or disable third party cookies (which we only use for the purposes of analyzing the use of this website and optimizing the content on this website), and how to opt out of other similar technologies.

We have done our best to provide you with as much information as possible about our use of cookies and similar technology. If you choose to use this website without blocking or disabling these cookies or opting out of other technologies as described in our Cookies Policy, you will indicate your consent to our use of these technologies and to our use (in accordance with this Privacy Policy and our Cookies Policy) of any personal data that we collect using these technologies.

Information Security

Fusion maintains technical, administrative, and physical safeguards that are designed to prevent unauthorized access, use or disclosure of personal information we collect or store.

We regularly monitor our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of information transmitted over the Internet. You use the website and provide us with information at your own discretion and risk.

Choice and Control

We do our best to give you as much choice as possible regarding the amount of information you provide to us, and the control you have over that information.

It is not necessary for you to provide us with any personal data in order to visit this website, although certain information will be collected automatically by virtue of your visit (as described above). However, if you do decide to request information from Fusion, you can control your information in the following ways.

Email preferences

You can unsubscribe from email newsletters and notifications (other than essential account notifications) at any time by clicking on the link at the end of each email.

You can contact us to change the email address or telephone number that you may wish us to use to communicate with you.

Please note that this Privacy Policy does not apply to any third party sites or applications that may be linked to the website and we cannot control the activities of those sites or applications. You are advised to read the privacy policies of those sites before sharing your information with any third party sites or applications.

Cookies

Information on how to block or disable cookies is included in our Cookies Policy. Further information is available at http://aboutcookies.org.

Exercising Your Rights

In some jurisdictions, including the UK and the EEA, you may exercise any of the rights described in this section through by contacting us. Please note that we may ask you to verify your identity before taking further action on your request.

• Data Access and Portability
  • You may be entitled to request copies of your personal information held by us. You may also be entitled to request copies of personal information you have provided to us in machine-readable format.
• Change or Correct Data
  • Where you cannot update data yourself through an account, you have the right to ask us to correct change, update or rectify your data.
• Data Retention and Deletion
  • We generally retain data for as long as needed. However, specific retention times can vary based on context of the processing we perform and on our legal obligations.
  • You have the right to ask us to delete all or some of the personal data we hold about you.
  • We may need to retain some of your personal data even after you have asked us to delete it if reasonably necessary to comply with our legal obligations.
• Objection to Processing
  • You may object to processing your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing).
  • If you object to such processing Fusion will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims or obligations.
  • Where your personal information is processed for direct marketing purposes, you may, under certain circumstances, ask Fusion to cease processing your data for these direct marketing purposes.
• Restriction of Processing
  • Under certain circumstances, you may have the right to limit the ways in which we use your personal information.
• Withdrawing Consent
  • Where you provide consent to the processing of your personal information by Fusion, you may withdraw your consent at any time by sending a communication to Fusion specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

Lodging Complaints

We hope that we can resolve any query or concern you raise about our use of your information.

You have the right to lodge complaints about the data processing activities carried out by Fusion before a competent data protection authority. The General Data Protection Regulation gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

International Data Transfers

Fusion operates globally and may share your information internally within the Fusion group of companies, and third parties for the purposes described in this Privacy Policy. Information collected within the EEA may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or another legally approved mechanism, to ensure the lawful transfer of your personal data outside of the EEA.

Children

This website not intended for use by children. Anyone under the age of 13 is not permitted to use this website and must not attempt to submit any personal information to us. We do not knowingly collect any personal information from any person who is under the age of 13 or allow them to register an account. If it comes to our attention that we have collected personal data from a person under the age of 13, we will delete this information as quickly as possible. If you have reason to believe that we may have collected any such personal data, please notify us immediately.

Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy, and when we do so, we will also revise the Effective Date set out below. Any changes to our Privacy Policy will always be available here so that website visitors are always aware of what information we gather, and how we might use and share that information.

Please be sure to check back here from time to time to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated by posting a notice of the change on this website.

Questions?

If you have questions or complaints about this Privacy Policy or our practices, or want to know what information we store about you, please contact us, or write to us at:

Fusion Cookie Policy

Effective as of 25 May 2018

This Cookie Policy forms part of our Privacy Policy and should be read together with it.

Like most companies, when you visit or interact with this website, we and our service providers may use cookies and other tracking technologies for storing information, including pixels (also known as a “web beacon” or “clear GIFs”), local storage, and device identifiers, to help provide, protect, and improve this website. For example, to save your preferences, personalize content, target ads based on your interests, combat fraud and abuse, and streamline the functioning of and your access to this website.

This policy explains how and why we use these technologies and the choices you have. We use “cookies” and “similar technologies” interchangeably to refer to all of these technologies.

What Are Cookies?

Cookies are small text files placed on your computer, phone, or other device when you visit websites and are used to record information about your activity, including the pages you view, the content you listen to, ads you click on, your settings, and other actions you take on this website.

Cookies can be “persistent” or “session” cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser.

Similar Technologies

We use other data collecting technologies with similar functionality as cookies, including pixels, local storage, and device identifiers. While the specific names and types of cookies we use may change from time to time as we improve and update this website, we have provided some basic definitions in order to help you better understand this policy.

• Pixels – A pixel is a small amount of code on a web page or in an email notification that typically work in conjunction with cookies to identify our users and record user behavior. As many services do, we use pixels to learn whether you’ve interacted with certain web or email content. This helps us measure and improve our services and personalize your experience.
• Local Storage – Local storage is an industry-standard technology that allows a website or application to store information locally on your computer or mobile device. We use local storage, including HTML5, to customize what we show you based on your content consumption and other past interactions with this website.
• Device Identifiers – We also use mobile device identifiers for the same purposes articulated in this policy, for example to recognize your device when you return to this website or otherwise use this website.
• Software Development Kits – We may use third parties including our service providers and business partners who use mobile SDKs to collect information to recognize your device when you return to this website. We may use this technology, for instance, to analyze how you interact with this website and to enable analytics or other features through mobile devices.

How We Use Cookies

While we use cookies to deliver, measure, and improve this website in various ways, the cookies we use generally fall into one of the following categories:

• Operational – These cookies are necessary to allow us to operate this website as you have requested. For example, they let us authenticate your account and recognize what type of visitor you are, so we can provide you with this website accordingly.
• Security/Abuse – These cookies enable and support our security features, and help us detect malicious or unauthorized activity. We also use cookies to combat activity that violates our policies or otherwise degrades our ability to provide this website. Cookies also help us fight spam and phishing attacks.
• Functional/Preferences – These cookies let us operate certain functions of this website in line with the choices you make. These cookies enables us to remember you in-between visits. For example, when you continue to use or come back to this website, we will remember your settings. Deletion of these types of cookies will result in limited functionality of this website.
• Performance/Analytics – We use these cookies to monitor and assess how this website is performing and where it can be improved. For example, we use these cookies to test different versions of our website to learn which features or content users prefer. We also use these cookies to analyze how people access and use our website. For instance, we may obtain information about your device and how users engage with this website or from email newsletters, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters’ effectiveness and helps us ensure that we’re delivering information you find interesting.
• Personalization – These cookies use information about your use of this website, such as the pages you visit or your response to emails, so we can recommend content that are more relevant and interesting to you based on criteria like your profile and activity on this website. We may also use these cookies to improve reporting on campaign performance, determine how many times people who click on ads end up taking an action (such as requesting information).
• Fusion Marketing – We also work with third party business partners, such as Google, to track user activity and market this website by showing you personalized ads for Fusion products and services on third party websites and applications.

Third Party Cookies

To help us better understand how people engage with this website, we work with third party analytics partners, including Google Analytics. To opt out of Google Analytics, you may install the Google Analytics Opt-Out Browser here. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.

Third-party cookies are covered by the third parties’ privacy policy.

Your Choices and Controls

Fusion is committed to offering you meaningful privacy choices. You have a number of options to control or limit how we, our partners, and other third parties use cookies. However, note that cookies are important to many aspects for this website – if you disable cookies, you may not be able to enjoy all of the features of this website.

Browser Settings

To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair this website or prevent certain elements of it from functioning.

Device Settings

On your mobile device, enable the “Limit Ad Tracking” setting in your iOS phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using our Apps, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.

Additional Controls

For more information about analytics cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu.

“Do Not Track Signals”

Your browser settings may allow you to automatically transmit a “Do Not Track” signal. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we are not configured to respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

Contact Us

If you have any questions about our use of cookies, please contact us.

Last amended: 23 May 2018