The Forthalia Online Privacy Statement applies to Forthalia's websites that link to this Statement but does not apply to those Forthalia websites that have their own privacy statement or do not link to this statement.

Forthalia respects and is committed to protecting your privacy and your personal information. Our privacy policies reflect current global principles and standards on handling personal information - notice and choice of data use, data access and integrity, security, onward transfer and enforcement/oversight. Our personal information handling practices are described below.


Personal Information

"Personal Information" is any information that can be used to identify an individual, and may include name, address, email address, phone number, payment card number or other relevant information.

We collect personal information for legitimate interest and purposes for a variety of reasons, such as general processing purposes, processing an order or inquiry, providing a newsletter, a newsletter subscription, direct marketing, personalizing your experience, in connection with a job application and for the purpose it was collected or as required by applicable laws, and for all other cases of legitimate interest and purposes.

When we collect personal information for other reasons we will inform you of the purpose for collecting personal information when we collect it from you and keep it to fulfill our legitimate interest and purposes for which it was collected, for general processing purposes, processing an order or inquiry, providing a newsletter, a newsletter subscription, direct marketing, personalizing your experience, in connection with a job application or as required by applicable laws, and for all other cases of legitimate interest and purposes.

We may combine the information we collect from you with information obtained from other sources to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you.

If you choose to provide third party Personal Information (such as name, email, phone number or other information), we will assume that you have the third party's permission to provide us the information. Examples include forwarding reference material to a friend or job referrals. This information will not be used for any other purpose other than our legitimate interest and purposes: general processing purposes, processing an order or inquiry, providing a newsletter, a newsletter subscription, direct marketing, personalizing your experience, in connection with a job application or as required by applicable laws, and for all other cases of legitimate interest and purposes.

We may also collect information relating to the use of our websites through the use of various technologies, including cookies, web logs, web beacons and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of the website. Please read the "Cookies" section below for more information.


Uses of Your Personal Information

We do not sell or share your Personal Information to third parties for marketing purposes unless you have granted us permission to do so.

We will only use your Personal Information for our legitimate interest and purposes for general processing purposes, processing an order or inquiry, providing a newsletter, a newsletter subscription, personalizing your experience, in connection with a job application and for the purpose it was collected or as required by applicable laws or for legitimate purposes. We will not subsequently change the way your Personal Information is used without first asking for your permission. Some of the ways we may use Personal Information include our legitimate interest and purposes to deliver a product or a service that you have requested, support our service, contact you for customer satisfaction surveys, personalise websites and newsletters to your preferences, administer and process our interactions with you, or communicate for marketing purposes, and for all other cases of legitimate interest and purposes.

You can contact us to modify your preferences at any time (see Data Access and Integrity and Access to and Accuracy of Your Personal Information below).


Use of Cookies and other Web Technologies

Like many websites, Forthalia may use automatic data collection tools, such as cookies, embedded web links and web beacons. These tools collect certain standard information that your browser sends to our website such as your browser type and the address of the website from which you arrived at our website. They may also collect information about your Internet Protocol (IP) address (a number automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer, which is a unique address assigned to your PC by your Internet Service Provider or Information Systems Department on a TCP/IP network) and clickstream behavior (for example, the sequence of the pages you view and the links you click). These tools help make your visit to our website easier, more efficient and more valuable by providing you with a customised experience and recognising you when you return. To learn more, you may search the internet or read specialised books on the subject.

Our website may include widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying ads, the news, opinions, music, etc), which are outside our control and not covered by this Online Privacy Statement. Personal information, such as your email address, may be collected through the widget. Cookies may also be set by the widget to enable it to function properly. Information collected by this widget is governed by the privacy policy of the company that created it.


Linked Websites

We may provide links to other third-party websites and services which are outside our control and not covered by this Online Privacy Statement. We encourage you to review the privacy statements posted on those websites (and all websites) you visit.


Forums/Chat Rooms

If you participate in a discussion forum or chat room on a Forthalia website, you should be aware that the information you provide there will be made broadly available to others, and can be read, collected or used by other users of these forums, potentially inside or outside Forthalia, who have access to that discussion forum or chat room, including search engines or web scrapers. This information could also be used to send you unsolicited messages outside our control. Also, please recognise that individual forums and chat rooms may have different and/or additional rules and conditions. Each participant's opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Forthalia. We are not responsible for the Personal Information or any other information you choose to submit in these forums or someone else has submitted in these forums or chats. Forthalia may not be held responsible for any illegal actions of the users or the viewers of the forums or of the information posted in the forums.


Children's Privacy

Forthalia does not knowingly collect Personal Information from children. If we learn that we have collected Personal Information of a child, we will delete that data from our systems. Please note that the Personal Information collected by third parties websites is subject to the privacy statement posted on those third parties websites along with any applicable privacy supplement, and Forthalia may not be held responsible for any illegal actions of those third parties.

Forthalia encourages parents and guardians to go online with their children. Here are a few tips to help make a child's online experience safer:

Teach children never to give Personal Information (such as name, age, address, phone number, school, etc.) unless supervised by a parent or responsible adult.
Know the sites your children are visiting and which sites are appropriate.
Look for website privacy policies and know how your child's information is treated.

For more tips on protecting children's privacy online, please read specialised information material, carry out extensive search and ask expert's advice.


Notice and Your Choices of Data Use

We will use your personal information for our legitimate interest and purposes for processing, processing your order or inquiry, providing you with a newsletter subscription, personalizing your experience, or in connection with a job application and for the purpose it was collected and will not use it for a different purpose without first asking for your permission.
We will ask your permission before we share your personal information with third parties for any purpose other than for our legitimate interest and purposes such as processing, processing your order or inquiry, providing you with a newsletter subscription, direct marketing, personalizing your experience, or in connection with a job application and the reason you provided it or as otherwise stated in our Online Privacy Statement.
For information relating to your use of our websites, you may turn off cookies in your browser. However, turning off cookies may affect and reduce your experience using our websites.


Data Access and Integrity

To update your personal information and communication preference, contact privacy@forthalia.com.


Access to and Accuracy of Your Personal Information

We need your help in keeping your Personal Information accurate and up to date so please notify us of any changes to your Personal Information. To update your Personal Information and communication preferences, you can contact privacy@forthlia.com. In addition, if and when the functionality is availbale, you may have the ability to view or edit your personal information online, or by contacting us.

We make good faith efforts to honor your reasonable request to access and correct your data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate purposes. We will respond to your request to access at the earliest possible and in any case within 90 days.


Your Choices and Selecting Your Communication Preferences

We give you the choice of receiving a variety of information that complements our Services. You can manage your communication preferences and unsubscribe using one of the following methods:

Each promotional email from us includes instructions on how you can unsubscribe from that particular mailing.

Sending a message via email at privacy@forthalia.com or via mail to Forthalia, Legal Department, Via Vincenzo Monti 8, 20123 Milan, Italy. Please be sure to include your name, email address and specific relevant information about the material that you no longer wish to receive.

These choices do not apply to the receipt of mandatory service communications that are considered part of certain Services, which you may receive periodically unless you cancel the Service in accordance with its terms and conditions.


Consent to Transfer, Processing and Storage of Personal Information

As a global company, we may transfer your personal information to any Forthalia subsidiary or affiliate worldwide or to third parties acting on our behalf located inside or outside of the country where the data is collected where data protection standards may be different. By providing any Personal Information to us, you fully understand and unambiguously consent to the transfer, processing and storage of such information outside of your country of residence where data protection standards may be different. Our Online Privacy Statement and our practices are designed to provide a globally consistent level of protection for Personal Information all over the world. This means that even in countries whose laws provide for less protection for your information, Forthalia will still handle your information in the manner described here.
We do not transfer your personal information to third parties unless those third parties promise to give the information the equivalent level of protection that we provide.

We may share Personal Information in the following ways:

• Within Forthalia or with any of our worldwide subsidiaries or affiliates for general processing purposes, processing an order or inquiry, providing a newsletter, a newsletter subscription, personalizing your experience, in connection with a job application and for the purpose it was collected or as required by applicable laws or for legitimate purposes.
• With business partners, service vendors, authorized third-party agents or contractors to provide a requested service or transaction, including processing orders and credit card transactions, hosting websites, hosting seminar registration and providing customer support. We only provide these third parties with the minimum amount of Personal Information necessary to complete/provide the requested service or transaction. We do not allow third parties to use your Personal Information for a different purpose.
• To comply with the law or legal process (such as responding to subpoenas or court orders) and to exercise our legal rights or defend against legal claims.
• To investigate, prevent, or take action regarding illegal activities, suspected or potential fraud, brand protection matters, situations involving potential threats to the physical safety of any person, violations of Forthalia's terms of use, or as otherwise required by law.

Security of Your Personal Information

We are committed to protecting the Personal Information you share with us against unauthorized use or disclosure and utilize a combination of industry standard security technologies, procedures, and organisational measures to help protect your Personal Information from unauthorised access, use or disclosure. We recommend you to take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. When you enter sensitive information on our forms, we may or may not encrypt this data using SSL or other technologies. Please look for more tips for using security features when connected to the Internet.


Important Information

We follow privacy policies and data protection practices not only to comply with the law but to earn the trust and confidence in Forthalia.
We address inquiries or complaints regarding personal information promptly and courteously.


Updates to this Forthalia Online Privacy Statement

We may update this Online Privacy Statement at any time, so please review it frequently. If we change our Online Privacy Statement, we may keep the revised version, with an updated revision date. If we make significant changes to our Online Privacy Statement, we may also notify you by other means prior to the changes taking effect, such as sending an email or posting a notice on our website.


References

For additional information about our privacy and security practices, you are welcome to contact us at privacy@forthalia.com.

REVISED AND POSTED AS OF: MAY 25, 2018. Please note this version does not substantively change the way we treat personal information compared to the previous version of our Online Privacy Statement.