Foa & Son Corporations’ Website Privacy Notice
Last Updated: December 6, 2019
What is the Purpose of this Document?
Foa & Son Corporation (“Foa & Son”/”we”/“our”/“our company”) provides insurance brokerage, risk management, employee benefits, and related services to clients. Foa & Son is committed to protecting your privacy and the confidentiality of your Personal Information. “Personal Information” is information that directly identifies or reasonably can be used to identify an individual user of this Website, located at www.Foason.com (“Site”). We have developed this Website Privacy Notice (this “Privacy Notice”) to notify you about our Website privacy practices.
All personally identifiable information collected on this Site by Foa & Son is considered Personal Information and will be treated in accordance with this Privacy Notice. By using this Site and submitting your Personal Information, you agree with and consent to the processing, transfer, usage, and storage of your Personal Information in accordance with this Privacy Notice.
Our Policies and Practices to Protect Your Personal Information
Foa & Son is committed to protecting the privacy of Internet users who visit this Site. Foa & Son’s intent always is to use and, if appropriate, to disclose your Personal Information in a manner consistent with applicable laws and regulations, contractual obligations, and our company’s policies and procedures. We protect Personal Information we collect about you by maintaining physical, electronic, and procedural safeguards designed to meet or exceed applicable laws.
To safeguard your Personal Information, the electronic storage and transmission of Personal Information are secured with appropriate security technologies. Access to this Site’s servers is limited to employees, agents, and contractors of Foa & Son and its affiliated companies, all of whom are required to preserve the confidentiality of Personal Information they receive while performing their jobs and conducting the business of Foa & Son.
Information We Collect
Foa & Son may collect two types of information about you when you visit the Site: Personal Information that you choose to provide to us (including, by way of example, your name, address, telephone number, e-mail address) and non-personal, aggregate information collected by automated means (such as cookies with information regarding the pages on our Site that you have visited and your IP address). Foa & Son does not use technology that recognizes do-not-track signals from your browser. In addition, we will never ask you on this Site, and we strongly discourage you from otherwise providing, highly sensitive financial or identity information through this Site to us (e.g., Date of Birth, Social Security number, and any financial account numbers). If you have the need to provide Foa & Son with such highly sensitive information, please contact us directly so that we may advise you as to the most secure means of conveying this information to us.
When using this Site, you may decide to provide us with Personal Information to help us serve your needs. For example, you may choose to give us your name, e-mail address, and company information in order to use our “Email Signup” function to receive e-mails from Foa & Son concerning company news, compliance issues, and services provided, or in order to use our contact form to send us an inquiry concerning services provided, career opportunities, or other inquiries. You may choose to submit an employment application for a position at Foa & Son through this Site. If you want to provide comments to Foa & Son’s blogs, you will need to provide your name and e-mail address, and you may also choose to provide your website URL. In addition, you may decide to complete one of the online forms that request Personal Information or otherwise enter Personal Information into the Site for the purpose of obtaining an insurance policy quote. If you choose to purchase a policy online, you may need to provide credit card information. In addition, if you contact us, we may keep a record of that correspondence.
Disclosure or Use of Personal Information
Foa & Son will not exchange, sell, or otherwise distribute your Personal Information without your consent, except to the extent required by law, in accordance with your instructions, or as identified in this Privacy Notice. By using this Site and submitting Personal Information to this Site, you consent to the collection, usage, storage, transfer, and disposition of your Personal Information—as set forth in this Privacy Notice—for all purposes set forth in this Privacy Notice, for all purposes required by law, and as instructed by you. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. If you do not consent, do not provide any Personal Information via this Site.
- Disclosure within Foa & Son related companies. We may share your Personal Information with companies within Foa & Son’s related companies. We may use such information to ensure that the content from our Site is presented in the most effective manner for you and your computer; to provide you with information, products, or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes); to carry out any obligations arising from any contracts entered into between you and Foa & Son; to allow you to participate in interactive features of our service (when you choose to do so); and to notify you about changes to our service. By submitting Personal Information through our Site, you consent the transfer to and the processing and usage of your Personal Information within the Foa & Son’s related companies. If you do not consent, do not provide any Personal Information via this Site.
- Disclosure to Third-Party Agents and Service Providers, Generally. We sometimes contract with other companies and individuals to perform functions or services on our behalf. For example, Foa & Son sometimes contracts with entities that host websites; entities that receive employment applications; and entities that send e-mail messages and/or make phone calls on our behalf. They may have access to Personal Information—such as names, e-mail addresses, and telephone numbers—needed to perform their functions, but they are restricted from using such Personal Information for purposes other than providing services for Foa & Son and are required by Foa & Son to maintain the confidentiality of such Personal Information. By submitting Personal Information through our Site, you consent to the transfer to and the processing and usage of your Personal Information by Foa & Son’s agents and service providers. If you do not consent, do not provide any Personal Information via this Site.
- Disclosure of Tracking Information to Certain Third-Party Service Providers. Third parties who provide interactive plug-ins or social networking features (e.g., Facebook’s “Like” button), or send e-mail messages on our behalf to individuals who are listed in their databases, may use cookies or other methods to track the activity on our Site. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your visit to our website and/or your purchases with any of your personally identifying information that they may have. By browsing our Site, you consent to the transfer to and the processing and usage of your Personal Information and purchase data by such third parties as set forth in this paragraph, if applicable. If you do not consent, please disable these cookies in your browser or refrain from browsing our Site. For more information, please see our Cookie Policy.
- Disclosure to Insurance Companies and Intermediaries. In the event you request a quote for issuance of an insurance policy or seek to purchase insurance through the Site, we may share your Personal Information, including, but not limited to, medical, financial, drivers’ license, and/or other Personal Information you choose to provide with insurance companies or intermediaries for purposes of obtaining quotes and placing insurance on your behalf. By submitting your Personal Information via this Site, you consent to the transfer to and the processing and usage of Personal Information, including any sensitive Personal Information, you provide by insurance companies and/or intermediaries. If you do not consent, do not provide Personal Information for purposes of purchasing insurance or obtaining quotes for insurance via this Site.
- Disclosure of Résumés and Applications to Third-Party Vendors Assisting Foa & Son with Recruitment and Employment Processes. This Site provides an opportunity to submit inquiries regarding career opportunities and to submit your résumé and an application form to us to apply for a position in the United States through this Site. If you submit information for such purposes, we will use the Personal Information you provide to evaluate your qualifications and contact you regarding any positions at Foa & Son or any of its affiliated companies in which we believe you may be interested. All applications and other information submitted via this Site will be collected and processed through a third-party vendor. If you are outside of the United States and choose to submit an application and/or a résumé via this Site, information you submit for employment purposes may be transferred to Foa & Son and/or third parties located in the United States and/or other countries not deemed to ensure adequate levels of data protection. By submitting Personal Information for employment purposes, you consent to the processing, transfer, usage, and/or storage outside of your country of residence, and to the processing, transfer, usage, and/or storage of your data by any third-party vendors assisting Foa & Son with recruitment and employment processes. If you do not consent, do not provide Personal Information for employment purposes via this Site.
- Disclosure to Third Parties in Connection with Legal Matters. Foa & Son may preserve, and has the right to disclose without your prior permission, any information about you or your use of this Site if Foa & Son has a good faith belief that such action is necessary to: (a) Protect and defend the rights, property, or safety of Foa & Son or its affiliates, employees, other users of this Site, or the public; (b) Enforce the terms and conditions that apply to use of this Site; or (c) Respond to claims that any content violates the rights of third parties. We may also disclose information as we deem necessary to comply with any applicable law, regulation, legal process, or governmental request. By submitting Personal Information via this Site, you consent to the processing, transfer, usage, and/or storage of your Personal Information for any such purposes. If you do not consent, do not provide Personal Information via this Site.
- Disclosure to Third Parties in Connection with Mergers and Acquisitions. We may disclose your Personal Information to third parties in connection with the sale or purchase of any business or assets. By submitting Personal Information via this Site, you consent to the processing, transfer, usage, and/or storage of your Personal Information for any such purposes. If you do not consent, do not provide Personal Information via this Site.
- Disclosure of Blog Comments and Related Personal Information to Third Parties. If you choose to add a comment to any of Foa & Son’s blogs, we will collect your name and e-mail address, along with any Personal Information you choose to include in your comments. Such information may be transferred to the United States and/or other countries not deemed to ensure adequate levels of data protection. Further, in the event we publish your comments on our Site, your name will be published on our Site, along with your comments. By submitting any such comments, you consent to the processing, transfer, usage, and/or storage of your comments, including any Personal Information you provide. If you do not consent, do not submit comments to Foa & Son’s blogs via this Site.
External Links
Our Site includes links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage our users to read the privacy statements of each and every website they visit. This Privacy Notice applies solely to information collected by Foa & Son when you visit this Site.
Information Storage and Security
Our systems are configured to provide privacy, integrity, and authentication in Internet communications. The security measures we have taken help to ensure that when you visit our Site, your Personal Information is secure and encrypted, so that a third party cannot capture, read, or access your Personal Information while it is in transit between your computer and our system. However, the transmission of information via the Internet is not completely secure, and although we will do our best to protect your Personal Information, we cannot guarantee the security of information as it is transmitted to our Site. As such, any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to help prevent unauthorized access.
We limit internal access to our servers and have physical, electronic, and administrative safeguards in place to guard all Personal Information that we receive from visitors to our Site. At Foa & Son, we adhere to high standards of ethics and integrity in performing our jobs and conducting business. However, it should be noted that there are some things, such as viruses and hacker attacks, which Foa & Son and other website operators cannot control.
Please note that the information we collect from you may be processed, transferred, and/or stored outside of your country of residence. Such location may not be deemed to have the same level of privacy protections as your country of residence; however, Foa & Son will take all steps reasonably necessary to help ensure that your Personal Information is treated securely and in accordance with this Privacy Notice. By submitting your Personal Information, you agree to this processing, transfer, usage, and/or storage outside of your country of residence.
Foa & Son disposes of Personal Information in a secure manner by destroying or permanently erasing electronic data, and by disposing of hard copy data via burning, pulverizing, or utilizing shredding methods designed to ensure that Personal Information cannot be read or reconstructed.
Accessing, Correcting, or Removing Your Personal Information
If you would like to review your Personal Information, correct the Personal Information you have provided to us, and/or request that we remove your information from our records, contact Foa & Son’s Compliance Counsel via the contact detail noted below with the access, correction, or removal request. Each request will be reviewed and responded to in accordance with applicable laws. In order to cover internal costs for responding to access requests, Foa & Son may charge a reasonable fee to individuals desiring access to their Personal Information.
International Users
This Privacy Notice is provided in accordance with, and is subject to, U.S. law. Certain non-U.S. jurisdictions, including but not limited to the European Economic Area, may provide for additional rules and regulations such as the GDPR. By using our Site, international users understand and agree that the requirements of your local rules and regulations may differ from those applicable in the U.S.
California Residents
The California Consumer Privacy Act, or CCPA, is a new law that provides California consumers certain rights in relation to their personal information. Generally speaking, the CCPA gives California residents the following rights:
- Right to know what personal information a business has collected about you.
- Right to tell a business not to sell your personal information.
- Right to request deletion of personal information.
For more details, please feel free to visit the State of California CCPA web site:
https://oag.ca.gov/privacy/ccpa.
Should you wish to contact us regarding any of your CCPA rights, or any other matter relating to this privacy policy, please feel free to do so as outlined in the “Contact Information….” Section.
Minors and COPPA
Foa is committed to protecting the privacy needs of children. Our services are marketed towards adults, and we do not knowingly collect online information from children under the age of 13. If we are notified that we have collected personal information, as defined by the Children’s Online Privacy Protection Act (“COPPA”), of a child under the age of 13, we will delete the information as expeditiously as possible.
Updates
We reserve the right to make changes to this Privacy Notice at any time. We encourage you to periodically review this Site for any updates or changes. Foa & Son will advise users of this Site of material changes to this Privacy Notice by posting a prominent notice on the Site homepage. Your continued access or use of this Site shall be deemed your acceptance of all terms and conditions contained in this Privacy Notice.
Contact Information for Questions and Requests
If you have any questions or concerns about our data privacy and security policy, the handling of your personal data, or to make a request to access your information, please contact Foa & Son’s Compliance Counsel via e-mail at Compliance@FoaSon.com or by mail to Foa & Son, Attention: Compliance Counsel, 68 S. Service Rd., Ste 210, Melville, NY 11747.
