Foster Business Consulting Privacy Policy

PRIVACY NOTICE

Last updated June 27, 2023

Thank you for choosing to be part of our community at Foster Business Consulting, LLC (“FBC””Company”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at compliance@fosterbusinessconsulting.com

When you visit our website https://fosterbusinessconsulting.com (the “Website”), and more generally, use any of our services (the “Services”, which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously and comply with applicable laws to protect your information. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it contains important information, including methods to exercise your rights as established by the U.S. and Global privacy laws and regulations. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.

Again, please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

TABLE OF CONTENTS

1. APPLICABILITY OF THIS PRIVACY POLICY
2. LAWFULNESS OF PROCESSING
3. WHAT INFORMATION DO WE COLLECT?
   HOW DO WE USE YOUR INFORMATION?
4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. COOKIES
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
11. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU? 13. CHILDREN UNDER 18
12. CHANGES TO THIS PRIVACY POLICY
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

1. Applicability Of This Privacy Policy

In Short: This policy is applicable to all personal and protected data used to furnish services to our customers.

This Privacy Policy applies to FBC’s services, website, customer service interactions, workplace production tools, technology platform, and mobile applications. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of FBC’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the FBC platform (Third-Party Services), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the Customer Agreement), including the processing of any messages, files or other content submitted through Services accounts (collectively, Customer Data).

2. Lawfulness of Processing

In Short: We process your data to perform a service requested by you or your employer.

FBC is committed to compliance with all applicable US, UK, Canadian, and EU General Data Processing Regulation (GDPR) requirements. Specifically, the data that FBC processes meets the Lawfulness conditions articulated in GDPR Article 6, Section 1. Data that FBC processes is obtained after obtaining consent from the individual and is related to the performance of a contract. Combined, these two elements allow FBC lawful processing of data from individuals and that which is subject to the contracted business terms between FBC and our business partners.

3. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us, or our products or Services, when you participate in activities on the Website, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; passwords; job titles; gender; race; ethnicity; date of birth; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

4. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

• To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at compliance@/fosterbusinessconsulting.com and be sure to include your name, testimonial location, and contact information.

• Request feedback. We may use your information to request feedback and to contact you about your use of our Website or Services.

• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

• To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.

• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

• To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

5. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
   
   In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

• More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

6. HOW LONG DO WE KEEP YOUR INFORMATION?
   
   In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than eighty four (84) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

8. WHAT ARE YOUR PRIVACY AND DATA PROTECTION RIGHTS?

In Short: In some regions, such as the United States,  European Economic Area, United Kingdom (UK), California, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

What are your data protection rights?

FBC would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request FBC for copies of your personal data. We may charge you a small fee for this service.

The right to be informed – You have the right to request that FBC inform you about the collection and use of personal data.

The right to rectification – You have the right to request that FBC correct any information you believe is inaccurate. You also have the right to request FBC to complete the information you believe is incomplete.

The right to erasure – You have the right to request that FBC erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that FBC restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to FBC’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that FBC transfer the data that we have collected to another organization, or directly to you, under certain conditions.

The right to object – You have the right to object to the processing of your data by FBC.

The rights related to automatic decision making, including profiling – You have the right to object to any automated decision making or profiling performed by FBC.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: compliance@forsterbusinessconsulting.com, or use this form: EU and UK Data Request Form.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you are a resident of the UK, you have the right to make a complaint with the Information Commissioner’s Office at 0303 123 1113.

If you have questions or comments about your privacy rights, you may email us at compliance@fosterbusinessconsulting.com.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

• Access your account settings and update your preferences.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. COOKIES

In Short: Cookies are text files that are placed on your computer when you visit our website.

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit www.allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

• Advertising – Our Company does not use cookies to collect information about your visit to our website to share with third parties for advertising purposes.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection and Privacy Officer (DPO), Jonathan McLeod , by email at compliance@fosterbusinessconsulting.com, by phone at 7348452859, or by post to:

Foster Business Consulting

Jonathan McLeod

900 Washington Rd.

Grosse Pointe, MI 48230

United States

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: https://fosterbusinessconsulting.com. We will respond to your request within 30 days. California residents, please use this form: CCPA Request Form.

13. CHILDREN UNDER 18

In Short: Our Site and Services are intended for individuals over 18 years of age.

Our Site and Services are not intended to be used by children under 18 years old. You represent and warrant that you are at least 18 years of age. If you are under age 18, you may not use the Site or Services without parental consent that is achieved through having a signed waiver from a parent or guardian. We do collect Personal Information from children under 18 with signed waivers to perform services as requested. We do not target our Site or Services to children under the age 18. We understand that there may be exceptions to this rule including, but not limited to, children who are emancipated. If we discover that the Site is being used inappropriately, we may disable the user ID so that the individual may no longer access our Site.

14. CHANGES TO THIS PRIVACY POLICY

In Short: We will update this notice as necessary to stay compliant with relevant laws.

FBC may change this Privacy Policy from time to time. When updates are made, the Privacy Policy version date will also be updated to reflect that a revision occurred. Your use of our Site and/or Services after such revisions are first posted will mean you acknowledge and agree to be bound by those revisions. We encourage you to periodically reread this Privacy Policy to see if there have been any changes that may affect you. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

15. 15. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name	YES
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history and financial information	YES
C. Protected classification characteristics under California or federal law	Gender and date of birth	YES
D. Commercial information	Transaction information, purchase history, financial details and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	YES

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at support@fosterbusinessconsulting.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

The current list of our service providers can be found below.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

FBC has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.
• Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHO WILL YOUR INFORMATION BE SHARED WITH?”.

Your rights with respect to your personal data

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
  the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose; the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• you may object to the processing of your personal data
• you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
• you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at compliance@fosterbusinessconsulting.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.