Global Privacy Policy

FADEL understands that visitors to our website (“the Website”), potential customers, and Users of FADEL products (“Products”) care about how their information is collected, used, processed, transferred, stored, and shared. This Global Privacy Policy describes FADEL’s commitment to protecting your privacy. It forms a part of our Standard Terms of Service, and all other documents incorporated therein (“Terms”). Any capitalized terms not defined in this Global Privacy Policy are defined as set out in the Terms.

Please familiarize yourself with this Global Privacy Policy. This Global Privacy Policy is formally reviewed annually and is updated as often as necessary. Updates will be posted publicly on the Website. If we make substantive changes to the purposes and policies set out here, we will update this page and we will inform Product Users by email or in-application notification.

This Global Privacy Policy provides information on how FADEL handles data as a data controller, meaning all data we process for our own purposes. Where FADEL is a processor or a sub-processor of data, that activity is generally governed by a Data Processing Agreement.

• What We Collect and How We Use It

• Website

• When you visit the Website, you are not required to actively provide any information, but we may collect some of your Personal Data and Navigation Information, as set out in the section entitled “Collected Data” below. We collection some Personal Data, and we may collect some Navigation Information, when you contact us via the Website, sign up to download or receive information from us, or sign up to use our Products. Some information is collected via the Website using cookies. See our Cookies Policy.

• FADEL Products

• We may collect Personal Data and Navigation Information from Users of our Products to help us provide, administer, and improve our Products. In order to use the Products, you will need to provide your full name and email address to us.

• Collected Data

• “Personal Data” refers to any information that can be used to identify you personally. For our purposes, this may include your (first and last) name, email address, User ID, company name, address, phone number and information about you that is publicly available online via sites like Facebook, LinkedIn, Twitter, and Google, data you write in a contact form, your uploads, your preferences and your account settings.
• “Navigation Information” refers to information about your computer, device, visits to the Website, and use of the Products. For our purposes, this includes which website you visited prior to visiting us or which link or campaign you clicked on to reach our website, your IP address, geographical location (city and/or country), browser type and version, ISP information, referral source, length of visits, pages viewed, language preferences and heat mapping.
• In some cases Navigation Information may also be Personal Data.
  Generally, we may use your Personal Data and Navigation Information for the following purposes:

1. Managing your FADEL account in performance of our agreement. We retain Personal Data processed for this purpose until we receive an actionable request to delete a User’s Personal Data, or in the case of termination or expiration of our agreement with a customer, we delete Personal Data as agreed in the Terms;
2. Understanding User preferences for the legitimate purpose of improving our Products. We may retain Personal Data processed for this purpose until you withdraw your consent;
3. Contacting you for direct marketing purposes. We may retain Personal Data processed for this purpose until you withdraw your consent.

• Supporting Suppliers

• The Products may  integrate some services provided by third parties. We may share some of your information with these suppliers so they can provide their services, including payment processing, analyzing data, and customer service.
• To ensure that your Personal Data is collected, processed, used, stored, and transferred securely and in accordance with applicable law, FADEL uses third parties that provide sufficient guarantees to implement appropriate technical and organizational measures to protect your information. For such third parties that may transfer Personal Data outside the European Economic Area, FADEL confirms that it implements appropriate safeguards for such transfers (e.g. EU Standard Contractual Clauses, and binding corporate rules).
• Please note, the terms and privacy policies of such third parties may apply to you as well, in particular: Google Analytics, Google Optimize, Google Tag Manager, Google Recaptcha, Stripe, and Freshdesk. Your acceptance of applicable third party terms is required to access the Website and Products.
• Disclaimer: This overview of supporting suppliers provides a current view. FADEL strives to keep this list as up to date as reasonably possible.

• Customer Testimonials

• We publish customer testimonials on the Website or in other marketing materials which may contain some Personal Data. FADEL obtains consent from the customer and the featured individuals prior to publication. This consent may be withdrawn by email to privacy@fadel.com.

• Information of Children

• The Website and Products are for business use and are not intended for or targeted toward children under 16 (“Children”). We do not knowingly collect any information about Children. We encourage parents and legal guardians to monitor the internet usage of their Children and ensure they do not provide personal information to FADEL. If you believe that we have collected information about Children, please contact us at privacy@fadel.com so that we can delete the information.

• We Do Not Sell Personal Data

• We do not sell your Personal Data.

• Personal Data Retention and Security

• Retention of Personal Data

• We retain Personal Data for as long as we reasonably consider it to be necessary for the purposes for which it was collected, after which time we will delete the information. You can request deletion of your Personal Data as described in the section entitled “Your Data and Your Rights” below.

• Security of Personal Data

• Data security is a matter of critical importance. FADEL uses a wide range of security measures to safeguard your data against unauthorized access and disclosure and we continually evaluate our security program to ensure its effectiveness. Amazon Web Services provides our servers and maintains them in high-security controlled environments pursuant to the AWS Cloud Security policy.

• Transfer of Personal Data

• As an international company with customers and Users worldwide, we may transfer and access Personal Data around the world, including to and from the United States. To comply with applicable law, we maintain strong data protection and privacy controls to protect your Personal Data during cross-border and international transfers, as well as during periods of storage in foreign countries (e.g. EU Standard Contractual Clauses, and binding corporate rules).
• We believe that your essential privacy rights are not contingent on your nationality or residency. While applicable law always governs data privacy matters, we intend for this Global Privacy Policy to apply generally to Users and their Personal Data around the world. Nevertheless, privacy law is a constantly changing landscape so we reserve the right to deviate from this Global Privacy Policy where applicable law provides for a different approach.

• Required Disclosure of Your Personal Data

• We may use or disclose your Personal Data if we reasonably determine that such use or disclosure is necessary to (a) protect our rights, operations, or Users; (b) comply with applicable laws, a valid court order, or other legal process; or (c) otherwise perform our contractual obligations with our customers.
• We may transfer the data we control, including Personal Data, in the event of a company reorganization, merger, or sale.

Your Data and Your Rights

As a general matter, depending on local data protection laws, you have rights that may include:

• Clear information on our processing of your Personal Data;
• Access your Personal Data that we hold, together with the right to have inaccuracies corrected;
• To have your Personal Data delivered to you in a standard electronic format;
• To object to our processing of your Personal Data, and to prevent solely automated decision making or profiling; and
• To restrict our processing of your Personal Data, or have your Personal Data deleted.

Exercising Your Rights

If you wish to exercise your rights with respect to your Personal Data, you can email your request to privacy@fadel.com or send postal mail to:

Fadel Partners, Inc
PO Box 708
Rye, NY 10580
Attn: FADEL Legal Team – Privacy

We will generally respond to your request within 30 days.

If you want to raise a complaint about the way we process your Personal Data or the way we have handled a request, please contact us. You may file a complaint with the data protection authority of any country where you live or work or where FADEL operates.

Please note that the use of some cookies and the collection, processing, use, sharing, storage, and transfer of your Personal Data may be necessary for you to make use of our services and that FADEL customers and Users cannot unsubscribe from important User emails.

California Consumer Privacy Act (CCPA) Supplement

• The CCPA is effective January 1, 2020. If you are a resident of California, this supplement to the Global Privacy Policy sets out additional rights and information for you.
• Many obligations under the CCPA are addressed in other provisions of the Global Privacy Policy. This Supplement is meant to fill in the gaps for California residents and the terms used in this Supplement are either defined in the Global Privacy Policy or in the text of the CCPA.

• CCPA Consumer Rights

• The right to access, and to know both the categories of personal information and the specific personal information we collect;
• The right to have your personal information deleted, subject to some legal limitations;
• The right to request disclosure of the personal information collected; and
• The right to disclosure of information disclosed for valuable consideration.

• Submitting Requests under CCPA

• California residents may submit requests for information under the CCPA to FADEL by email to privacy@fadel.com.
• Please be as specific as possible when you exercise your rights under CCPA and submit a request regarding your personal information. Under the CCPA, we are obligated to verify your identify before we process your request.

• No Discrimination

• FADEL will not discriminate against you in pricing, user experience, or any other way for exercising any of your rights under the CCPA.

EU-U.S. Data Privacy Framework (EU-U.S. DPF)

FADEL complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce.  FADEL has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

General Obligations and Liabilities

As a USA based company we are aligned to and are under the the investigatory and enforcement powers of the Federal Trade Commission (FTC).

You are entitled, under certain conditions, to invoke binding arbitration as applicable. Specifically our organization is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to your organization and has followed the procedures and conditions set forth in Annex I of the DPF Principles.

Should it be required we may disclose personal information in response to lawful requests by public authorities, required to meet national security or law enforcement requirements as applicable.

While we do not share any information we collect with third-parties we are liable for any actions by any third-party with regards to onward transfers of personal information.

The Global Privacy Policy was last updated and reviewed on 29 September 2023