Good Job ScoreUpdated and Effective Date: April 2024
This Privacy Policy describes how FoW Partners (together with its affiliates, “FoW”, “we” or “us”) treats personal information, including personal information collected on www.fowpartners.com where this Privacy Policy is located (the “Site”) or other platforms that direct to this Privacy Policy. Natural person investors in our funds receive a separate investor privacy notice as part of their subscription document, as updated from time to time. That investor privacy notice supplements this Privacy Policy and, in the event of any conflict, the terms of that investor privacy notice will control.
WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.
We collect the following categories of personal information from you in different ways including from you directly, from you passively through your use of the Site, from third parties and from publicly available sources.
Personal Identifiers:
We might collect your name, address, phone number, username, email address and log-in information when you register on our Site, sign up for our newsletters, apply for a job or contribute to any of our projects. We also collect other information that you provide to us voluntarily.
We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.
Commercial Information:
We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties. We use and share this information as noted below.
Communications:
We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you such as personal identifiers and professional or employment information.
We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums and productivity and collaboration tool providers. We use and share this information as noted below.
Professional or Employment Information:
When you register on the Site or apply for a job, we may collect professional and employment information such as information about your employers, awards and associations.
We may collect this information from various sources including from you directly, through your use the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.
Educational Information:
When you register on the Site or apply for a job, we may collect educational information such as information about schools you attended, degrees awarded and academic status.
We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.
Internet or Other Electronic Network Activity:
We collect internet and other electronic information such as usage data on how you use our Site and how long you stay on the Site through the use of browser cookies or other commonly used technologies (e.g., web beacons). This may include information about your browser, device type, IP address, user session information, etc. and contain personal information about you.
We may collect this information from various sources including from you passively through your use of the Site and from our service providers. We use and share this information as noted below.
Geolocation Information:
We collect your IP address when you use the Site and from our services providers. We collect this information through your use of the Site. We use and share this information as noted below.
Aggregate information:
We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information. We collect this information through your use of the Site. We use and share this information as noted below.
We may collect personal information as otherwise described at the time of collection on the Site.
SENSITIVE PERSONAL INFORMATION.
We may collect information that is considered “sensitive” under some data protection laws, such as your account log-in information if you log into our investor portal. When we do so, we use such information only for lawful purposes in compliance with the applicable data protection laws, such as to perform the services requested by you, to conduct know-your-customer-diligence or to resist malicious, deceptive, fraudulent or illegal actions, and we do not use such information to directly infer characteristics about you. Where required by applicable law, we will obtain your consent prior to processing such information.
WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.
The provision of personal information by you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest or for business and commercial purposes. For each category of personal information above, we use your personal information to carry out the following purposes:
Our and Our Service Provider’s Operational Purposes:
We may use information about you to provide our products and services, operate our business, to customize content that we or our service providers display on the Services, to improve our existing Services and developing new services (e.g., by conducting research and analysis to develop new products or features), to engage contractors and service providers and manage our relationship with them, to evaluate commercial or business opportunities, and for other uses that advance our commercial or economic interests, such as third-party advertising (consistent with any privacy choices you have communicated to us).
We use information about you to provide you services and improve our websites and the information we provide. We might use your personal information to deliver the Site and/or customize your experience with us. For example, we may use your personal information to improve the Site, for our recruiting efforts and our other internal business purposes.
Responding to Requests:
We use information about you to respond to your requests or questions. For example, we might use your information to contact you about employment opportunities or to process your application for a job or to respond to your request to work on any of our projects.
Applicants for Employment and Contractors:
We use information that you submit, or that we receive from third parties such as current or prior employers to evaluate job applicants individuals or contractors, and to onboard and pay new hires.
Security and Fraud Prevention and Detection:
We use information for security purposes such as fraud prevention and detection. We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.
Compliance with Laws and to Protect Ourselves:
We use your personal information to support auditing, legal and compliance purposes, including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Recruiting and Marketing:
We use personal information to inform you about FoW. For example, we might send you information about FoW and what we offer. We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities.
Communications:
We use personal information to communicate with you about your account or our relationship. We may contact you about your use of our Site. We may contact you about your account or feedback. We might also contact you about this Privacy Policy or the Site’s Terms of Use.
Debug and Identify Errors:
We use your personal information to debug and identify and repair errors that impair existing intended functionality.
Statistical Analysis and Research:
We may use your personal information for statistical analysis and research purposes including analyzing performance.
We may use your personal information as otherwise described or permitted by law, for any other purpose as described in this Privacy Policy, or as we may notify you.
WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.
We may collect and share personal information about you from third parties. We collect such information: directly from you (such as when you contribute to or participate in one of our programs, apply for a job with FoW, submit your business contact information, or send us questions or otherwise communicate with us); through automated technology (such as cookies on our websites) or online platforms; from third parties such as recruiting platforms and events, referrals, financial institutions, or your employer; and from other sources (such as publicly available information).
For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.
FoW Companies:
We may share your personal information within the FoW family of companies.
To Respond to Your Requests:
We may use your personal information to respond to your requests or questions. For example, we might share your personal information with third parties in order to provide you with services requested by you or to answer your questions.
Service Providers:
We will share personal information with third parties who perform services on our behalf. For example, we share personal information with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our websites.
Comply with the Law:
We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Business Successors:
We may share personal information with any successor to all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of FoW or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction.
Business Transfers:
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.
Information You Elect to Share:
You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies or practices of these Third Party Services.
Information We Share With Your Consent:
We will also share your personal information in the manner that you authorize us to.
We may share personal information for other reasons we may describe to you or as permitted by law.
Data Retention
We generally retain personal data for so long as it may be relevant to the purposes set forth in the relevant privacy policy. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain a record of your inquiries to us for as long as it takes to fulfill the inquiry. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may de-identify it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS
You can opt out of receiving our marketing emails. To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us.
Our Do Not Track Policy. Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our Sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
RIGHTS FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM
Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights that may be subject to limitations and/or restrictions.
You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the purpose or to object to the processing of your personal information as well as a right to data portability.
Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.
You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.
If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to operations@fowpartners.com.
For the purposes of EEA and UK data protection laws, we are the data controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information.
For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are when it is necessary for the performance of any contractual relationship with you, where in our legitimate interests for the purposes described in this Privacy Policy, or, only when expressly requested, your consent.
RIGHTS FOR INDIVIDUALS IN CALIFORNIA
If you are a California resident, California law requires us to provide you with certain information about how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”). Please note that this California Privacy Notice (“Notice”) applies only to information we collect from California consumers, and does not apply to any individual in their capacity as (a) a FoW investor or (b) a FoW employee. For more information about the privacy practices of our individual businesses, please see each business’s main Privacy Policy.
A. Sale/Sharing of Personal Information
The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes with third parties who do not act as service providers to that business. FoW makes personal information available to non-service provider third parties only when individuals have affirmatively agreed to such disclosure (for example, where a site visitor has opted in to our use of advertising cookies) or where the disclosure of personal information is otherwise exempt from the CCPA (such as disclosing information to secure the Services). As such, FoW does not “sell” or “share” personal information within the meaning of the CCPA.
Please note, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.
B. Your Personal Information Rights
California residents may make certain requests about their personal information under the CCPA, subject to certain limitations and/or restrictions. Specifically, under California law you have the right to:
- Request that we disclose information about the personal information that we have collected, used, disclosed or sold;
- Request access to a copy of the personal information we maintain about you;
- Request correction of inaccurate personal information;
- Request that we delete personal information collected from you; and
- Not receive discriminatory treatment for exercising your privacy rights.
A consumer may use an authorized agent to submit a request on their behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at operations@fowpartners.com.
If you require this notice in an alternative accessible format, please email us at operations@fowpartners.com.
We have instituted a process for verifying that the person making an access, correction or deletion request is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the personal information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary. For online requests to delete, we will use a two-step process where the consumer must first submit the deletion request and then separately confirm that they want their personal information deleted. If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.
For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.
If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at operations@fowpartners.com; or (ii) contact us at +1 207-210-0022.
C. Shine the Light
California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
FOW SITES AND CHILDREN
Our Sites are meant for adults. We do not knowingly collect personal information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.” Parents and guardians may learn more about how to protect children’s privacy on-line here.
HOW WE SECURE DATA
We maintain reasonable security procedures and practices. But the Internet is not 100% secure. We cannot promise that your use of our Sites or software will be completely safe. We encourage you to use caution when transmitting personal information over the Internet. We keep personal information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep personal information as otherwise required by law or for internal compliance or record-keeping purposes.
WE STORE PERSONAL INFORMATION IN THE UNITED STATES
Personal information we collect may be transferred to and stored within the United States. Our Sites are subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. Where required to do so by applicable data protection law, we use the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your personal data that is transferred outside the European Economic Area or United Kingdom.
WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL
If you click on a link to a third party website, you will be taken to website(s) that we do not control. This Privacy Policy does not apply to the privacy practices of such third party website(s). Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).
FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS
If you have any questions about this Privacy Policy or other privacy concerns, please contact us at: operations@fowpartners.com
We may update this Privacy Policy
From time to time, we may change our privacy policies. We will notify you of any material changes to our Privacy Policy as required by law by posting a notice on our Site prior to the change becoming effective. We will also post an updated copy on our Site. Please check our Site periodically for updates. You are bound by any changes to the Privacy Policy when you use the website after such changes have been first posted.