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.

Privacy policy is available at https://aws.amazon.com/privacy/

• Google Analytics, Inc.

Privacy policy is available at https://policies.google.com/privacy?hl=en

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: privacy@fischercompany.com  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: