Privacy Policy

Clifford Fischer & Company Privacy Statement

This Privacy Statement is effective as of April 1, 2020.

Clifford Fischer & Company, and its affiliates (collectively “Fischer Solutions”) seeks to protect your personal information and is committed to complying with applicable data protection laws in countries in which Fischer Technology operates. In order to meet this goal, Fischer Technology has implemented measures related to the nature, scope, context and purposes of our handling and processing of personal data. This Privacy Statement describes Fischer Technology’s general privacy practices which apply to personal information Fischer Technology collects, uses and shares about consumers and other individuals within its clients, business partners, supplier and other organizations and information collected from its primary website [https://www.fischercre.com/] and through your general email inquiries to Fischer Technologies (the “Services”).

Fischer Solutions may provide additional or more specific information on the collection or use of personal information on other Fischer Solutions websites or related to a specific product or service. This Privacy Statement does not apply to those websites that have their own specific privacy statement. This Privacy Statement also does not apply to instances where Fischer Solutions merely process information on behalf of clients for the clients’ benefit as a data processor.

Fischer Solutions may supplement this Privacy Statement with additional information, policies and procedures. By using the Services, you agree to the collection and use of information in accordance with this Privacy Statement.

HOW TO CONTACT US

If you have a question related to this Privacy Statement, please contact us:

By email: [email protected]

By mail: Clifford Fischer & Company, Attn: Data Privacy Team, 13727 Noel Road, Suite 900, Dallas, Texas 75240

Your message will be forwarded to the appropriate member of Fischer Solutions' Data Privacy Team.

You have the right to make a complaint at any time to the applicable supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

For the purposes of the EU General Data Protection Regulation (GDPR), for information collected through the Services, the controller of your personal information is Clifford Fischer & Company 13727 Noel Road, Suite 900, Dallas, Texas 75240, unless indicated otherwise. Where Fischer Technology or a subsidiary it controls (not established in the European Economic Area (EEA)) is required to appoint a legal representative in the EEA, the representative for all such cases is Clifford Fischer & Company, 13727 Noel Road, Suite 900, Dallas, Texas 75240.

TYPES OF DATA COLLECTED

Personal Information: While using our Services, we may ask you to provide us with certain personal information that can be used to contact or identify you. Personal information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State/Province, City and ZIP/Postal code
If required by written agreement, tax payor identification information
Cookies and usage data

Usage Data: We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device. This usage data may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. When you access the Services with a mobile device, this usage data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Aggregated Data: We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data with other users to calculate the percentage of users accessing a specific website feature. We may use and share aggregated data for any purpose. However, if we combine or connect aggregated data with your personal information such that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Statement.

Special Categories of Personal Data: We do not collect any special categories of personal data about you as defined by applicable law (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Tracking Cookies Data: We use cookies and similar tracking technologies to track the activity on our Services and collect certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of cookies we use:

Session Cookies. We use Session Cookies to operate our Services.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Third-Party Cookies. We use certain third-party cookies as identified in the Data Sharing section below.

WHY AND HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Fischer Solutions may collect your personal information as an individual for various purposes, such as the following:

Access and use of websites or other online services
When entering or using the Services, we will record information necessary to provide you with access and for us to comply with security and legal requirements in relation to our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to help us improve and further develop our websites, products and services and to notify you about changes to our Services.

Responding to your request for information, order, or support
When you contact Fischer Solutions in connection with a request for information, or services or to provide you with support, we collect information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you. For instance, we collect your name and contact information and details about your request. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you.

When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our Services.

Contacting employees of our clients, prospects, partners and suppliers
In our relationship with clients or prospects, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfilment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.

Visitor information
We register individuals visiting our sites and locations (name, identification and business contact information) for security and safety, as well as for regulatory purposes.

Marketing
Most information we collect about you comes from our direct interactions with you. We collect such information to develop to better conduct our business and for marketing purposes. For example, we may use your personal contact information and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (direct marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You may opt out of receiving any, or all, of the marketing communications from us by following the unsubscribe link or the instructions provided in any email we send or by contacting us as set forth herein.

We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes (third-party marketing).

When we collect and use your personal information subject to the EU Privacy Legislation this may have consequences for your rights.

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

LEGAL BASIS FOR PROCESSING OF PERSONAL INFORMATION UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA) or the UK, Fischer Solutions' legal basis for collecting and using the personal information described in this Privacy Statement depends on the personal information we collect and the specific context in which we collect it.

Fischer Solutions may process your Personal Data because:

We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purpose for which we will use your personal information: We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user	Identifying data; contact information	Performance of a contract with you
To process and complete your service request	Identifying data; contact information; financial information; transactional correspondence; marketing correspondence	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us; direct marketing)
To manage our relationship with you, including: (a) notifying you about changes to our terms or privacy statement, (b) asking you to leave a review or take a survey	Identifying data; contact information; marketing correspondence	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to keep our records updated; direct marketing); (c) Necessary to comply with a legal obligation
To administer and protect our business and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identifying data; contact information; usage data; aggregate data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise); (b) Necessary to comply with a legal obligation
To deliver relevant Services content to you and measure or understand the effectiveness of the content we serve to you	Identifying data; contact information; marketing correspondence; usage data; transactional correspondence; aggregate data	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Usage data; aggregate data	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identifying data; contact information; marketing correspondence; usage data; transactional correspondence; aggregate data	Necessary for our legitimate interests (to develop our products/services and grow our business)

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURE AND SHARING OF PERSONAL INFORMATION

Fischer Solutions has implemented global policies, standards and procedures for consistent protection of personal information. Fischer Solutions may share information about you with our subsidiaries and transfer it to countries in the world where we do business in accordance with this Privacy Statement.

Between Fischer Solutions controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, Fischer Solutions uses suppliers located in various countries to collect, use, analyze, and otherwise process personal information on its behalf.

Where appropriate, Fischer Solutions may also share your personal information with selected partners and service providers to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes and we require that all third-party service providers respect the security of your personal information and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. Current categories of service providers with whom Fischer Technology shares personal information include:

Amazon Web Services, Inc.

Google Analytics, Inc.

If Fischer Solutions decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is Fischer Solutions' practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of Fischer Solutions, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

INTERNATIONAL TRANSFERS

Your information, including personal information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there. Fischer Solutions may transfer your data to third parties as set forth herein, but shall maintain responsibility for such data in cases of onward transfer to third parties as required under applicable law. Your consent to this Privacy Statement followed by your submission of such information represents your agreement to that transfer.

Fischer Solutions will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information (which may include Privacy Shield certification, an EU adequacy decision, or standard contractual clauses, approved by the European Commission).

INFORMATION SECURITY AND ACCURACY

We intend to protect your personal information and to maintain its accuracy, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Fischer Solutions implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.

RETENTION PERIOD

Fischer Solutions will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims where we do business. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR PERSONAL INFORMATION RIGHTS

You can request to access, update or correct your personal information. You also have the right to opt out of direct marketing. You may have additional rights pursuant to your local law applicable to the processing.

EEA and UK Data Privacy Rights

For example, if you are in the European Economic Area (EEA) or the UK, you have certain data privacy rights. Fischer Technology aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal information. If you wish to be informed about what personal information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data privacy rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your personal information to the extent the processing is based on our legitimate interest.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Fischer Solutions relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

California Data Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information over the last 12 months. If you are a California resident you have the right to request the disclosure of:

the categories of personal information we collected about you;
the categories of sources from which the personal information is collected;
the business or commercial purpose for collecting or selling personal information;
the categories of third parties with whom we share personal information; and
the specific pieces of personal information we have collected about you.

You have the right to request that we delete any personal information that we have collected, subject to certain exceptions defined in CCPA.

To exercise your access and deletion rights described above you must submit a verifiable request to us by email: [email protected] and by mail: Clifford Fischer & Company, Attn: Data Privacy Team, 13727 Noel Road, Suite 900, Dallas, Texas 75240. The verifiable request must contain sufficient information to allow us to verify you as a person and to properly understand and respond to your inquiry. As part of our verification process we will contact you to verify your identity. Once the verification process is complete we will delete the requested information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We will respond to your verifiable request within 45 days of receipt. If we require more time (up to 90 days) we will provide you with notice and explanation of the reason.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Furthermore you have the right to request that in the case that we sell your personal information, or disclose it for a business purpose, we disclose to you:

The categories of personal information that we collected about you;
The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and
The categories of personal information that we disclosed about you for a business purpose.

Fischer Solutions does not sell your personal information as defined in CCPA.

You may use an authorized agent to submit a request to access, delete and to opt-out on your behalf if you provide the authorized agent written permission to do so and verify your own identity directly with us. “Authorized agent” means a natural person or a business entity registered with the Secretary of State that a consumer has authorized to act on their behalf. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf, unless you have provided the authorized agent with power of attorney, pursuant to Probate Code sections 4000 to 4465. We do not knowingly collect personal information from California residents between the ages of 13 and 16.

In the preceding 12 months, we have collected the following categories of personal information about California residents:

Category	Examples	Collected?	Business/ Commercial purpose for collecting	How is it shared?
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers	Yes. Source: you.	Security of the Services; debugging/repair of the Services; performing services on behalf of the business or service provider; advancing a person’s commercial or economic interests; quality, safety maintenance and verification of the Services; enabling or effecting a commercial transaction	With our service providers and affiliates, including those to whom you instruct us to send this information
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	Yes. Source: you (b) Necessary for our legitimate interests (to recover debts due to us; direct marketing)	Security of the Services; debugging/repair of the Services; performing services on behalf of the business or service provider; advancing a person’s commercial or economic interests; quality, safety maintenance and verification of the Services; enabling or effecting a commercial transaction	With our service providers and affiliates, including those to whom you instruct us to send this information
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	No.
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Yes. Source: you.	Performing Services on behalf of the business or service provider; advancing a person’s commercial or economic interests	With our service providers and affiliates, including those to whom you instruct us to send this information
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	No.
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	Yes. Source: from you, through your use of our Services.	Security of the Services; debugging/repair of the Services; performing services on behalf of the business or service provider; advancing a person’s commercial or economic interests; quality, safety maintenance and verification of the Services; enabling or effecting a commercial transaction	With our service providers and affiliates, including those to whom you instruct us to send this information
G. Geolocation data	Physical location or movements	No.
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No.
I. Professional or employment-related information.	Current or past job history or performance evaluations	No.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	No.
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Yes. Source: you, through your use of our Services.	Performing services on behalf of the business or service provider; advancing a person’s commercial or economic interests; quality, safety maintenance and verification of the Services	With our service providers and affiliates, including those to whom you instruct us to send this information

In the preceding twelve (12) months, we have sold the following categories of personal information to the following categories of third parties:

None.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose to service providers, affiliates, and third parties to whom you authorize us to disclose your personal information in connection with services we provide you:

Identifiers;
Personal information (under California statute);
Commercial information;
Internet or similar network activity;
Sensory data; and
Inferences drawn from other personal information.

We do not discriminate against you because you exercised any of your rights under CCPA, including, but not limited to, by:

Denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to you; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may charge you a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your data (e.g., your identifiers). We may enter you into a financial incentive program only if you give us prior opt in consent which clearly describes the material terms of the financial incentive program, and which may be revoked at any time. We shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

Under California law, a California resident with whom Fischer Solutions has an established relationship has the right to request certain information with respect to the types of personal information Fischer Solutions has shared with third parties for their direct marketing purposes (if any), and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, Fischer Solutions is allowed to provide a cost-free means to opt-out of such sharing.

Since Fischer Solutions does not provide your personal information to third parties for their direct marketing purposes, it is not necessary for us to establish this procedure; however, if you do not want Fischer Solutions to use your personal information to provide information about our programs, please follow the cost-free opt-out procedures in this policy.

Nevada Data Privacy Rights

Nevada residents may opt out of the sale of their covered information, as those terms are defined in Nevada law, by submitting such request to our designated email address: [email protected]. Please note that Fischer Solutions does not sell your covered information as defined by Nevada law.

OUR POLICY ON “DO NOT TRACK” SIGNALS AND THIRD-PARTY WEBSITE TRACKING UNDER THE CALIFORNIA ONLINE PROTECTION ACT (CALOPPA)

We do not support “Do Not Track”. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

We do not engage in the collection of Personal Data over time across third-party websites, and we do not permit third parties to gather information passively on our website for behavioral advertising purposes.

LINKS TO OTHER WEBSITES

Our Services may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHILDREN’S PRIVACY

Our Services are not directed at or intended for anyone under the age of 18. We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

PRIVACY SHIELD FRAMEWORK

As Fischer Solutions is a US-based company, personal information will be primarily stored in the United States. In order to provide an adequate level of protection according to EU laws, Fischer Solutions has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access and recourse, enforcement and liability and is supervised by the U.S. Federal Trade Commission (FTC). If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Fischer Solutions' certification, please visit https://www.privacyshield.gov/welcome. To view Fischer Solutions' certification on the Privacy Shield list, see the U.S. Department of Commerce’s Privacy Shield certification list located at https://www.privacyshield.gov/list.

If your personal information is subject to the Privacy Shield, and you do not believe Fischer Solutions has adequately addressed your privacy concerns, you can also address your concerns regarding the use of your personal information to the Judicial Arbitration and Mediation Services Inc. (“JAMS”) free of charge. JAMS contact information:

JAMS

3800 Howard Hughes Parkway, 11th Floor

Las Vegas, NV 89169

To file a complaint/inquiry, visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim

For information about JAMS and their Privacy Shield program visit: https://www.jamsadr.com/eu-us-privacy-shield

In cases where the issue cannot be resolved by us or through the alternative dispute resolution proceedings you may invoke binding arbitration as further described in the Privacy Shield. See Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

RIGHT TO LODGE A COMPLAINT

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint directly with Fischer Solutions by contacting us at: [email protected].

CHANGES TO OUR PRIVACY STATEMENTS

From time to time we may update this Privacy Statement, as well as any other specific privacy statement. When making changes to this Privacy Statement, we will add a new date at the top of this Privacy Statement. We will let you know of such changes via email and/or a prominent notice on our Services, prior to the change becoming effective. You are advised to review this Privacy Statement periodically for any changes. Changes to this Privacy Statement are effective when they are posted on this page.

The U.S. subsidiaries of Clifford Fischer & Company also adhering to the Privacy Shield Principles, which are identified in its Privacy Shield submission under “Other Covered Entities” are as follows:

CLIFFORD FISCHER & COMPANY – A TEXAS CORPORATION (PARENT)

Subsidiaries/affiliates:

Fischer Pacific, Inc. – A California Corporation
Fischer Financial, Inc. – A Texas Corporation
Fischer Northwest, Inc. – An Oregon Corporation
Fischer Chicago – An Illinois Corporation
Fischer Management Services Inc. – A Texas Corporation
Fischer Solutions, Inc. – A Delaware Corporation
Fischer Southeast, Inc. – A Georgia Corporation
Fischer & Company, Inc. – A Pennsylvania Corporation
Fischer VM Holdings, LTD. – A Texas Limited Partnership
Fischer Visual Manager, LLC – A Texas Limited Liability Company