Last Modified:  August 12th, 2020

 

AFS Technologies, Inc., and its family of companies (collectively, “AFS Technologies,” “AFS,” “we,” “us,” or “our,” as applicable) values the privacy of our users, customers, and partners. AFS respects your privacy and is committed to using responsible practices in the collection, maintenance, and use of your information. This Privacy Statement, as modified from time to time, describes our practices in connection with information collected through our www.afsi.com website (together with all subdomains, related websites, and related mobile device applications, the “Website”) and all software solutions provided to our customers (together with all related mobile device applications, the “Software Solutions”). This Privacy Statement applies only to information we obtain from you when you are online while visiting or using the Website or Software Solutions. It does not apply to information we have obtained or may obtain offline through other traditional means.

 

If you are in the European Union, the AFS subsidiary or affiliate who owns and operates the Website that you are visiting will be the data controller responsible for the collection and use of your Personal Information. Where Personal Information is provided by a customer in connection with our Software Solutions, AFS is the data processor responsible for processing Personal Information on behalf of the customer.  If you have a query about how your Personal Information is being used, you can contact the data controller through the Global Privacy Officer whose contact details appear below.

 

As a general principle, information you provide to us will only be used or shared by AFS as outlined in this Privacy Statement. By visiting or using the Website or Software Solutions, you agree to the practices and policies set forth in this Privacy Statement. If you do not agree to the terms of this Privacy Statement, you may not use the Website or Software Solutions.

 

1. What information do we collect and process?

We collect two basic types of information from you in conjunction with your use of the Website and Software Solutions – Personal Information and non-Personal Information.

“Personal information” is any information that can individually identify you and includes, as an illustrative example and without limitation, your name, postal address, email address, telephone number, job title, location, etc.

“Non-Personal Information” includes information that does not personally identify you, but may include, as an illustrative example and without limitation, tracking and usage information about your location, use of the Website and the Internet, use of the Software Solutions, etc.

 

Personal Information

There are a number of circumstances in which you voluntarily supply us with your Personal Information. The following lists the most common ways in which we collect your Personal Information:

  • Registration for an account on the Website;
  • Submission of Personal Information when doing business with us, including through our Software Solutions, or providing services to us;
  • Sign up to receive information, promotional information, or related services from us;
  • Participation on social media accounts involving AFS;
  • Submission of questions, comments, or feedback through the Website, the Software Solutions, or otherwise; or
  • Any other place on the Website or Software Solutions where you knowingly volunteer Personal Information.

AFS also collects Personal Information from third party sources, including advertising partners and marketing platforms. Please note, however, that we will comply with the privacy policies of the corresponding platform and we will only collect and store such Personal Information that we are permitted to collect.

 

Personal Information of End-users

If you create an account and register on the Website or in our Software Solutions on behalf of your company, or as a company contact person, we may need to collect your personal data which may include data such as account information, email address, name, job title, logs and operation history of the application, information which you enter into the Software Solution, your location from time to time derived from the Software Solution and any other Personal Information necessary for our Purposes.  For account registration, please also confirm that you have the requisite corporate power and authority for using Software Solutions, and we may collect your login information, such as the username and password in your registration and use of the service.

The user may withdraw consent to the collection, use and/or disclosure of his/her Personal Data by giving us reasonable notice. The user should be aware that the withdrawal of such consent, may result, amongst others, in the user being unable to continue using the Application or any other services offered by us. The User’s request for withdrawal of consent can take the form of an email or letter to the contact information provided below.

 

Social Media Sites

When you interact with an AFS account on or through a social media platform, such as Facebook, Twitter, or LinkedIn, we collect the Personal Information that you make available to us on that page or account, including your user ID and/or username, and any information you have made public in connection with that social media service. Please note, however, that we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such Personal Information that we are permitted to collect by these social media platforms.

Our Website includes social media widgets, such as Facebook, Twitter, and LinkedIn widgets. These features collect information about your IP address and which page you’re visiting on our Website, and they set a cookie to make sure their features function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with those features are governed by the privacy policies of the companies that provide them.

 

Children’s Online Privacy

AFS respects the privacy of children, and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). We do not intentionally collect Personal Information from children. If you are under the age of thirteen (13), you may not register for an account on the Website or use the Software Solutions. If we learn that a child under 13 has provided Personal Information to us without verification of parental consent, we will take commercially reasonable steps to delete that information.

If you are under 16 years of age and reside in the European Union, you must provide an email address for your parent or legal guardian, and before you can access or use the Website or the Software Solutions, AFS must receive your parent’s or legal guardian’s express consent. You will not receive access or the ability to use the Website or the Software Solutions, and we will not collect additional Personal Information from you, until we receive your parent’s or legal guardian’s consent. Your parent or legal guardian may revoke consent at any time, and AFS will take reasonable steps to delete all Personal Information collected from you. AFS will also provide your parent or legal guardian with the ability to request to review your Personal Information, prohibit further collection of your Personal Information, and delete, or instruct the deletion of, your Personal Information.

 

Non-Personal Information

Some information is automatically received and sometimes collected from you when you visit or use the Website or Software Solutions. The following lists the most common information that is automatically received or collected:

  • The name of the domain and host from which you access the Internet, including the Internet Protocol (IP) address of the device you are using and/or the IP address of your Internet Service Provider (ISP);
  • The type and version of Internet browser software you use and your operating system;
  • Websites visited before or after you visit our Website;
  • The date and time you access the Website, the length of your stay, and the specific pages that you access while visiting the Website; and
  • Information concerning the country of origin of your device and the language(s) used by it.

We use this information to monitor the usage of our Website and Software Solutions, assess performance, ensure technological compatibility with your device, and understand the relative importance of the information provided on the Website and Software Solutions. We may also use this data to conduct statistical analyses on visitors’ usage patterns and other aggregated data.

 

Use of Cookies/Tracking Technology

When you interact with the Website and/or our Software Solutions, we automatically receive and record information on our server logs from your browser, including your IP address, “cookie” information, and the page you requested.

Cookies and other tracking technologies (such as pixels and beacons) are comprised of small bits of data that often include a de-identified or anonymous unique identifier. Websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer, so the website can access information when you make subsequent requests for pages from that service. We may use these technologies to collect and store information about your usage of the Website or Software Solutions (such as the pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen), which information is then used to understand your preferences so as to enable us to provide you with improved services in future visits, and to compile aggregate data about site traffic and interactions so that we can offer better experiences and tools in the future.

Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available through the Website.

We utilize email tracking systems that provide us with data such as who opened or forwarded an email, the time it was opened, and whether the reader clicked certain links within the email.

 

Analytics

We, as well as third-party vendors acting on our behalf (such as Google), may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers to gather anonymous analytics and statistics about our Website and how it is are being used by our visitors so we can improve our Website. Our web server storage logs may collect the domain names, internet protocol addresses, the types of web browsers, and certain data of visitors to the website.

Data about your activities online may be collected for use in providing advertising tailored to your individual interests, either by us, our affiliates, or third parties. We may work with third parties such as network advertisers and ad exchanges to serve advertisements across the internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content.

We and these third-party vendors, including Google, may use third-party technologies (such as a Facebook Custom Audience Pixel) together with our own first party technologies in order to analyze ad impressions, your use of ad services, and interactions with these ad impressions and ad services. The information collected may also include information about your visits to our Sites, include the pages you have viewed and what content you have seen. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the effectiveness of the advertisements that have been delivered to you.

You can opt out of certain advertising by visiting the Network Advertising Initiative consumer opt out page at http://optout.networkadvertising.org/, by using the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout, or by visiting the Digital Advertising Alliance’s opt-out page at https://www.aboutads.info/choices. Please note, at this time we do not respond to browser-based “do not track” signals.

 

Email and Other Communications

We may contact you by email or other means at an email address that you have provided to us. For example, we may send you account information or promotional offers. If you do not want to receive email from us, please let us know through the “unsubscribe” feature included in our communications.

 

2. How do we use your information?

We use the information we collect from you and about you to help us personalize and continually improve your experience with the Website and the Software Solutions. You have no obligation to provide us with any of your information, but you may not be able to use or access certain portions of the Website or the Software Solutions if you do not provide us with your Personal Information (and you cannot use our Website or Software Solutions without agreeing to the terms of this Privacy Statement).

As non-limiting examples, we use the information we collect from and about you in the following ways:

  • When we perform our obligations under a contract: We may use your Personal Information to carry out our obligations under the contract that we have with you or your company.
  • Providing the features, products, services and support you request: We may use the information we collect about you to fulfill your requests for, and enable your use of, our features, products and services.
  • Registration and promotions: We may use your information to register you for certain features, products and services in line with your chosen marketing preferences.
  • To communicate with you and provide you with information: We may use your information to communicate with you, to respond to your questions or comments, to provide you with updates and news. We also may use your information to provide you with personalized content and information, and to send you brochures, samples, offers, and other information concerning the Software Solutions or our family of companies.
  • To deliver to you relevant advertising: We may purchase and use opt-in e-mail lists to contact potential customers who we believe may be interested in products or services from the AFS family of companies. We will honor opt-out requests and ask those providing lists to give us assurances that e-mail contact information is provided only for those consumers who have expressed a desire to receive offers and information by e-mail. We also may use demographic and preference information to allow advertising related to AFS products and services to be targeted to the users for whom they are most pertinent. This is designed so that users will see advertising that is most likely to interest them, and advertisers can display their ads to people who are most likely to be receptive.
  • To provide you with other offers: Sometimes we will make offers and information available to you through the mail. For example, when customers place an online order or sign up for to receive information online we may add them to the list to receive information by mail. We may also use lists we have received from third parties or public sources to send you this information, and, as is routinely done in the mailing list business, may exchange names and addresses (but not e-mail addresses absent consent) of our customers with companies who may also contact you by mail. You may “opt-out” of receiving offline communications from us any time.
  • To improve our websites, features, products and services: We may use the information that we collect to improve the AFS family of product offerings, services, as well as our websites and features.
  • To fulfill operations related requirements including, but not limited to, security and risk management, internal audits and regulatory compliance.

We will store your information only for as long as we need to use your information for the above purposes.

 

3. How do we share and disclose your information?

We will only share Personal Information as provided in this Privacy Statement, and within our company and corporate affiliates. We do not and will not sell or trade your Personal Information to any third party outside of AFS.

 

Service Providers

We may make your information available to certain third-party service providers, such as contractors or vendors, who help us manage or provide services offered on our Website or Software Solutions, such as hosting, analytics, customer service, etc. We may need to share your Personal Information with them, but we require that all of our service providers keep Personal Information confidential and not disclose it to third parties and not use it for any other purpose.

 

Emergency Situations

We may also use or disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us, the Website, or the Software Solutions; (b) respond to requests from public and government authorities; (c) protect and defend our rights or property, the Website, the Software Solutions, or our users; or (d) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, the users of the Website or Software Solutions, or the public.

 

Merger, Sale, Or Bankruptcy

If we sell all or part of our business, or make a sale or transfer of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business, or are involved in a bankruptcy, AFS may transfer your information to the party or parties involved as part of that transaction.

 

California Disclosures

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of Personal Information we have shared with third parties, if any, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to the contact information provided below. California law also permits residents of California to opt-out of AFS’s disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request in writing to the contact information provided below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.

For more information about your rights under the California Consumer Privacy Act, please click here

 

How Information is Stored and Processed

Personal information collected on our Website and Software Solutions, or received by AFS from you or third parties, may be stored and processed in the United States or any other country where we or our service providers maintain facilities.

The servers and databases in which information is be stored may be located outside the country from which you accessed the Website or Software Solutions, and in a country that does not have the same privacy laws as your country of residence. The Personal Information (including the personal information of the end-users of our Software Solutions) you provide us may be transmitted abroad for the purpose described in this Privacy Statement, but we will collect, process and use Personal Information only in accordance with this Privacy Statement.

If you are a customer of ours, your personal data which you have given us via application form, internet or other means, during the service subscription period will be retained for a reasonable period after termination of your subscription. We will erase any unnecessary personal data from our system in accordance with our internal policy. Secure deletion/shredding software is used or physical destruction of the media for irreversible, secure removal of data.

 

International Transfer of Information

If you choose to provide us with Personal Information (including the personal information of the end-users of our Software Solutions), we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world such as the United States of America, Slovakia, Australia, United Kingdom, the People’s Republic of China, Singapore and Canada in accordance with legal requirements.  AFS will take reasonable steps as required by applicable laws and regulations to safeguard your Personal Information. AFS uses European Union Commission Standard Contractual Clauses for data transfers from the European Union to countries outside the European Economic Area.

 

4. How do we secure your information?

We are committed to ensuring that your information is secure. We use commercially reasonable efforts to protect your Personal Information collected, used, stored, shared, or transferred through the Website or the Software Solutions from access, loss, misuse, alteration, or destruction by any unauthorized party. Please understand, however, that no transmission of data over the internet or any other public network can be guaranteed to be 100% secure. We do not promise, and you should not expect, that your Personal Information or private communications will always remain private. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse such as by maintaining the confidentiality of your username and password and logging out of your account when not using the Website or Software Solutions.

 

5. Links to or from other websites

This Privacy Statement applies solely to information collected by, or on behalf of, AFS. Please note that the Website may link to other websites and online services operated by third parties. These websites and applications operate independently from us, and we do not control their privacy policies, which may be different from ours. AFS is not responsible for the data collection, use, disclosure, or storage practices (or any action or omission) of companies or organizations to which our Website may provide links. We encourage users to be aware when they leave our Website and to read the privacy policies of any third-party website, application, or other platform that requests or collects Personal Information from or about you.

 

6. Notice to non-U.S. users

As the Internet is a global environment, collecting and processing Personal Information may involve the transmission of this data internationally. Therefore, by communicating electronically with us, you acknowledge and agree to your personal data being processed in this way.

Specifically, if you are located outside of the United States, please be aware that by using the Website or Software Solutions, your Personal Information may be transferred to the United States or other third-countries, the privacy laws of which may be deemed by your country to have inadequate data protection. If you are located outside of the United States and voluntarily submit Personal Information to us, you thereby consent to the general use of such information as provided in this Privacy Statement and to the transfer of that information to, and/or storage of that information in, the United States or other third-countries.

 

European Union Disclosure

If you reside in the European Union, you have certain rights under the European Data Protection Regulation (“GDPR”), including:

  • The right to be informed of the Personal Information we collect and how we process and use that data;
  • The right to request access to your Personal Information;
  • The right to request that inaccurate Personal Information be rectified, or completed if incomplete;
  • The right to request erasure of your Personal Information;
  • The right to restrict our processing or use of your Personal Information;
  • The right to obtain and reuse your Personal Information for your own purposes;
  • The right to object to our processing or transferring your Personal Information;
  • The right to withdraw your consent for us to use your Personal Information; and
  • The right to lodge a complaint with a supervisory authority under the GDPR.

We have a legitimate interest in collecting and processing your information for the purposes we have outlined in this Privacy Statement and so that we can optimize your experience with the Website and Software Solutions. We retain and store your Personal Information only for as long as we have a legitimate business purpose to do so and in accordance with our data retention policies and this Privacy Statement.

In response to receiving a request for one of the rights set forth above, AFS will timely comply with the request within the time periods set forth in the GDPR for each right. Several of the above rights are not absolute and apply only in certain circumstances. AFS will comply with requests for those rights as set forth in the GDPR. We are intent on resolving any issues relating to our handling of your Personal Information, and you may contact us at any time regarding any questions or concerns.

We do not make any decisions about you based on automated processing of your Personal Information.

 

Honk-Kong Disclosure

The Personal Information Collection Statement is available here. It gives you information that we are required by the Personal Data (Privacy) Ordinance (Cap 486, the Laws of Hong Kong) (the “Ordinance”) and applicable laws to provide to you in relation to the personal data we may collect from you.

 

Singapore Disclosure

By using the software application and services licensed by AFS Technologies and its family of companies, you, the “User”, irrevocably and unconditionally agree to the terms and conditions in relation to the collection, use and disclosure of your Personal Data as defined here.

 

China Disclosure

We may transfer the Personal Information of end-users from the PRC to other foreign countries or areas where our affiliates are located. AFS will comply with requirements and obligations relating to the cross-border data transfer under all applicable laws and regulations of PRC. For example, AFS may conduct self-assessment for the data transfer if it is required by the applicable PRC law. And AFS will take reasonable steps as required by applicable laws and regulations to safeguard your Personal Information, during the transmission and alongside the entire time of the storage of your Personal Information.

( 公司隐私声明 )

 

Taiwan Disclosure

If you reside in Taiwan, you have certain rights under The Personal Data Protection Act (“PDPA”), including:

  • The right to be informed of the Personal Information we collect and how we process and use that data;
  • The right to make an inquiry of and to review his/her personal data;
  • The right to request a copy of his/her personal data;
  • The right to supplement or correct his/her personal data;
  • The right to demand the cessation of the collection, processing or use of his/her personal data;
  • The right to erase his/her personal data.

In response to receiving a request for one of the rights set forth above, AFS will timely comply with the request. We are intent on resolving any issues relating to our handling of your Personal Information, and you may contact us at any time regarding any questions or concerns.

( 隱私權聲明 )

 

South-Korea Disclosure

If you reside in South-Korea, you have certain rights under The Personal Information Protection Act (“PIPA”), including:

  • The right to be informed of the Personal Information we collect and how we process and use that data;
  • The right to request access to your Personal Information;
  • The right to request that inaccurate Personal Information be rectified;
  • The right to request erasure of your Personal Information;
  • The right to restrict our processing or use of your Personal Information;
  • The right to obtain and reuse your Personal Information for your own purposes;
  • The right to object to our processing or transferring your Personal Information;
  • The right to withdraw your consent for us to use your Personal Information; and
  • The right to lodge a complaint with a supervisory authority.

In response to receiving a request for one of the rights set forth above, AFS will timely comply with the request. We are intent on resolving any issues relating to our handling of your Personal Information, and you may contact us at any time regarding any questions or concerns.

( 개인정보 보호정책 )

 

7. Changes to Privacy Statement

We reserve the right to revise this Privacy Statement from time to time in our sole discretion. We will post and maintain the most recent version of the Privacy Statement on the Website. We may not notify Website visitors or Software Solutions users of any such revisions by email, phone, or other personal contact. You are responsible for reviewing this Privacy Statement upon each visit to the Website or use of the Software Solutions. You can determine if the Privacy Statement has been revised since your last visit by referring to the “Last Modified” date at the top of the Privacy Statement.  In the event of any conflict or inconsistency between the English version and the other language version of this Privacy Statement, the English version shall prevail.

 

8. Contact Us

We are committed to working with you to resolve any complaints you may have regarding this Privacy Statement or the treatment of your Personal Information. If you have any questions about this Privacy Statement or its implementation, please contact us:

By Mail:
AFS Technologies Inc.
Attn: Chief Technology Officer
5201 W Kennedy, Suite 200
Tampa FL  33609

By Email:  [email protected]