Information We Collect
The following summary highlights the information we collect and our data policies. On this page you can learn:

• What kinds of data do we collect?
• How do we use the data we collect?
• How do you keep my data secure?
• What’s your data retention policy?
• How do I control my data?
• Where can I learn more?

What kinds of data do we collect?
Things you share
We collect the information that you choose to share with us. This may include the opinions you express and the interests you choose to share.

• Survey and study responses
• Discussions and chats
• Likes and comments
• Media such as images, videos, and documents you upload

Things that make you “you”
When you join this website, we keep the information that you share with us. This can include personally identifiable information including:

• Name
• Email address
• Password
• Birthday
• Gender
• Phone number
• Address
• Country

We may also ask you about your household to help us better understand the interests relevant to you.
From time-to-time we may ask you to update your information. We may supplement this information with data from other sources and our partners. The information we collect can viewed by you in the Your Data section.
You will only be asked about your personally identifiable information in the private and secure areas of our website. Please do not volunteer personally identifiable information in areas viewable by others like discussions and comments. We will never ask you to share highly sensitive information such as passwords, social security numbers, credit cards, bank accounts, and financial information.
Web Browser and Device Information
We collect information about the devices you use to access our website and mobile app. The purpose of this information is to authenticate users, comply with applicable regional regulations, understand the quality of the user experience, and general website usage metrics with our users.
This information may include the following:

• Connection information such as the name of your internet service provide (ISP), mobile operator, phone number, and IP address
• Browser/device information such as browser, language, time zone, operating system, hardware version, device identifiers, and device settings
• Device locations such as specific geographic locations, such as through GPS, Bluetooth, or WiFi signals

Cookies & Other Storage Technologies
Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this policy, we refer to all of these technologies as “cookies.” We use cookies to manage user sessions. We do not link the information we store in cookies to any personally identifiable information.
Information from third-party partners.
We exchange information about you and your activities on-and-off this website from integrations and third-party partners, such as information about your experiences or interactions on this website and with partners. The data exchanged with partners is pseudonymized. This means we do not share data about you thats classified as sensitive personally identifiable information that specifically identifies you, such as your full name and address.
How do we use the data we collect?
Our website is designed to give you a platform to share your experiences and opinions. The information you share with us helps us understand our audience and make better decisions about our company based on information you provide.
We may include information you share in company internal reports and presentations without permission, including suggestions, responses, and uploaded media created and shared by you. The purpose of this is to highlight your experiences and opinions to our broader team and to help inform our company decision making.
Your personally identifiable information is protected. We practice pseudonymization so that your identity is masked whenever and wherever possible. We do not share information that can identify you with partners or third-parties.
How do you keep my data secure?
Our servers are protected by high-end firewall systems. We secure data with sophisticated controls and access restrictions. All data is encrypted at rest for maximum security.
What’s your data retention policy?
Typically, we maintain data for as long as it remains relevant to the stated purpose of this website, i.e. understanding our audience and inform company decision making. We erase your personally identifiable information when it’s no longer pertinent to this purpose, or when instructed by you using the data controls on the Your Data section of this website.
How do I control my data?
We support your right to be informed about your data and make choices about your information. Visit the Your Data section to learn more.
Where can I learn more?
The full detail of our policies is available in our Privacy Policy. The purpose of this page is to highlight specific details from that policy. If you have additional questions you may contact us.

 
Updated and effective as of November 1, 2019

This Privacy Policy forms part of our Terms of Service which is available at https://fuelcycle.com/legal/terms-of-service/ (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms. If you have any questions, you may contact us. See the “Contacting Us” section below. We may change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See “Changes to this Privacy Policy” below for more information. You acknowledge that you accept the practices described in this Privacy Policy by visiting and/or using our Site or Service.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy explains how Fuel Cycle Inc. and its subsidiaries (“Fuel Cycle”, “we”, “us”, “our”) collect, receive, use, store and share information and the options available to you through all digital formats, including the Internet and mobile, from users and users of our clients who: (i) visit www.fuelcycle.com (each, together with its sub-domains, other websites owned and operated by us, including our career pages and our client and user interfaces, a “Site”); and (ii) use our software applications, use any online community that we conduct on behalf of our corporate clients, use our social media pages such as LinkedIn, Twitter, and Facebook, or receive email messages from us or send email messages to us (collectively, the “Service”).

This Privacy Policy covers our Site and Service which allows us and our clients to collect data using surveys, discussion boards, focus groups, video, text, and images. We may also receive information about you from our third party service providers.

This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), such as our corporate clients and any service providers. Our clients create online research communities through which they collect information from their users and use the data in accordance with their terms. If you have questions about a particular online community, please contact the creator of the online community. See “Third Parties” below for more information.

Choice and Opting Out: see “Choices” below for information about your choices regarding opting out of email marketing communications, opting out of Fuel Cycle’s cookies, opting out of interest-based advertising from third party cookies, and opting out of use of precise location.

Access and Rights: see “Access and Rights regarding Personal Information” below for information about how to be informed, the right to data portability, the right to object, your rights in relation to automated decision making and profiling, and the right to access, rectification, erasure, and restrict the processing of, the personal information that Fuel Cycle maintains about you.

THIRD PARTIES

We may receive and/or procure certain information, including Personal Information, from third parties, such as its service providers, sales and marketing tools, which all relate to your preferences and your use of the Site and/or Service. This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), including any third parties operating any site or service to which our Site/Service link. The inclusion of a link on the Site/Service does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies. If, when using the Site and/or Service, you integrate with a third party service, we will connect that third party service to ours. The third party provider of the integration may share certain information about your account with us. However, we do not receive or store your passwords for any of these third party services. The Site and/or Service may enable you to interact with or contain links to your Third Party account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services, except where required by applicable law. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

We may share your Personal Information with our third party service providers and partners, but only to assist us with our business operations and to provide our Service to you and other users. Such service providers may include, but not limited to, Salesforce, AWS, and our FCX Partners. Such information may be transferred to other countries. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information. We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of our clients (including our clients who create their own online research communities through our Service), app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers (except as required by applicable law), including any Personal Information you disclose to other organizations through or in connection with the Site/Service. These third parties are bound by their own privacy policies.

COLLECTION OF INFORMATION

This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site and/or the Service. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

The Service and/or the Site may be available for use via a web browser or applications. We do not host ourselves any of the Site and/or Service all hosting is done by third party service providers that we engage. This means that data you provide us or that we collect from you (including any Personal Information) – as further described in this Privacy Policy – is hosted with such third party service providers on servers that they own or control. Regardless of where such third party service providers are located (in the US or elsewhere), their servers may be located anywhere in the world (including the US). Your data may be replicated across multiple servers located in multiple countries. Be aware that you are consenting to your data being transferred to various third party service providers around the world (including the US).
We and our third party service providers may collect the following personal information from you from the Services:
Name
Email address
Phone number
Fuel Cycle username
Last four digits of your credit card number and for job applicants
Name
Phone number
Email address
Home address
Employment history
Professional references
Education
For example, we collect your personal information when you request information about the Site/Service, you sign up to use the Site/Services through our client login and user interfaces, you request access to our resources, you pay via credit card for our Site/Service as a user of one of our clients, or you apply for a job at Fuel Cycle through our career pages. The decision to provide this information is optional, however, if you elect not to provide such information, you will not be able to access the information you had requested to access or use.

We and our third party service providers may also collect other information that is linked or reasonably linked to a particular computer or device. This information includes the following:
Browser information, including browser type
Device information, including screen dimensions, device brand and model
Operating system of mobile device
Language
Time spent on the Services and your activities on the Services, including date and time, clickstream data, the web page from which you came, and the web page(s) that you accessed during your visit
Your location data as derived from IP address
Unique identification numbers, including IP address and mobile device identifier
Data as provided by the client
Information provided by you
Aggregated information
We and our third-party service providers may collect this information in a variety of ways, including through: your browser or device; your mobile device identifier; your use of our applications; the use of pixel tags and other similar technologies; your IP address; the aggregation of information; and cookies (see Cookies and Similar Technologies below).

Our clients may also collect information about you that they choose to pass to us either directly or through our Services. The information such clients may share includes demographic information such as age and gender and behavioral information.

COLLECTION OF JOB APPLICANT DATA

We may collect the following information from you in connection with your job application:
Name, address, telephone number, e-mail address, and other contact information
Username and password
Work authorization status
CV, résumé, cover letter, previous work experience and education information
Skills
Professional and other work-related licenses, permits and certifications held
Information relating to references
Background information through background checks
Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships)
We ask that you avoid submitting the following sensitive information, except where such information is legally required: race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, genetic information, or trade union membership information.

To the extent the personal information you provide contains details of your: racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health or condition; sexual orientation; commission (or alleged commission) of an offence or related proceedings; job evaluations or educational records, you expressly authorize Fuel Cycle to handle such details for the purposes of your job application.

Any information you submit through the career pages of the Services (including any pages hosted by a third party service provider) must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.
We may also obtain information about you from your references or from a background check report in connection with your application, as permitted by applicable law.

USE OF INFORMATION

We may collect information about how you are accessing and using the Site and /or Service, which may include administrative and support communications with us and information about the Fuel Cycle channels, people, features, content, and links you interact with, and what third party integrations you use (if any). Such information may include Personal Information. We and our third-party service providers may use personal information (such as name, phone number and email address) collected from the Services:
To respond to your inquiries and fulfill your requests
To send administrative information to you
To communicate with your concerning your account and customer service issues
To provide access to and use of the Services
To manage users’ accounts
To bill your credit card for our fees, in which case our service provider will use your entire credit card number
To send you communications that we believe may be of interest to you, including any communications for marketing purposes related to the Services
To provide the Services to our business clients who may contact you regarding goods and services that may be of interest to you
To enhance users’ experience using our Services
To personalize and customize the Services,
for our business purposes, such as data analysis, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our campaigns, and technical functioning purposes
With respect to job applicants: to process your employment application; to assess your capabilities and qualifications for a job; to conduct reference checks; to respond to your inquiries and communicate with you about your application, and to send you information regarding the career pages and changes to our terms and policies; to comply with or monitor compliance with any applicable law or regulation; and to conduct background checks if we offer you a position, as permitted by applicable law.

As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things).

We and our third-party service providers may use other information from the Services that is linked or reasonably linked to a particular computer or device:
To operate, improve, analyze and manage the Services, including improve the user experience
To ensure the Services function properly
To track your use of the Services to improve the design, functionality and effectiveness of the Services
To measure and report on the success of advertising and marketing campaigns and content
To understand users’ navigation behavior
To understand opportunities to develop new product
To diagnose server problems, administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your internet service provider) and ensure the technical functioning of the Services, an
To provide you with personalized location-based services and content through the use of your device’s physical location (where permitted by law)
As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things)

We may partner with certain third parties to collect other information about you to engage in analysis, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons. See “Cookies and Similar Technologies.”

In some instances, we may combine information from the Services that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.

SENSITIVE INFORMATION

If we ask you to provide sensitive personal information (i.e. information specifying medical or health conditions, personal financial information, social security number, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information regarding your sex life, among similar such information), we will require that you first affirmatively agree (i.e., opt-in) to provide such information before we collect it from you. The information we request is not designed for any discriminatory purpose and you are not required to provide any such sensitive information if you do not wish to do so, although your use of our Services may be affected thereby.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies in connection with our Services. A cookie is a small data file that we store on your computer’s or mobile device’s memory. Some cookies help you navigate our Services, including setting a cookie to remember your login details and to validate your identity. Other cookies collect information about how you use our Services and analyze trends, which highlights areas we can improve, how we can otherwise improve the quality of our Services and how to tailor our Services to meet our users’ personal interests. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. We may receive reports based on the use of these cookies on an individual as well as aggregated basis.

If you submit name and email and similar personal information to us via the Services, that personal information will not be stored in cookies or tied back to you for interest-based advertising purposes across websites and applications. However, you may receive email marketing communications from us and you may receive targeted advertising from third parties based on the information stored in a third party’s cookie. To opt out of marketing communications and to opt out of interest-based advertising from third party cookies, see “Choices.”

We may also use “pixel tags,” “web beacons”, “clear GIFs” or similar means (individually or collectively “Pixel Tags”) to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited our Services, and pages within our Services, and to help determine the effectiveness of promotional or advertising campaigns.
Third parties may also use cookies or similar technologies on visitors of our websites to serve interest-based advertisements to such visitors when they visit other websites and mobile applications, including advertisements promoting our Services. The collection of information through cookies or similar technologies by such third parties will be governed by such third parties’ own privacy policies and principles, which we do not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. However, please note that certain features of the Fuel Cycle website may not work if you delete or disable cookies.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

To read about your choices with regard to Fuel Cycle’s and third parties’ uses of cookies in our services, please see “Choices.”

We do not currently track users when they cross to third party websites, and therefore we do not respond to Do Not Track (DNT) signals.

INFORMATION SHARING

Your personal information (such as name, phone number and email address) collected from the Services may be shared:
Among our affiliates for the purposes described in this Privacy Policy (Fuel Cycle Inc. is the party responsible for the management of the information jointly used by it and its affiliates)
With the particular client on whose behalf we have collected your personal information through our Services
With our third-party service providers who provide services such as email management, billing (e.g., charging your entire credit card for our fees), and marketing analytics and other services
With our third-party service providers who provide services relating to our career pages, recruiting, background check processing and similar services
Directly by you on profile pages and blogs and other services to which you are able to post information and materials yourself (including, without limitation, our social media pages)
With a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things)
We and our third party service providers may share other information from the Services that is linked or reasonably linked to a particular computer or device:
Among our affiliates for the purposes described in this Privacy Policy (Fuel Cycle Inc. is the party responsible for the management of the information jointly used by it and its affiliates)
With our clients to allow them to analyze the effectiveness and performance of our Services
With our third-party service providers who provide services that enhance our Services, including cloud storage vendors, marketing, analytics and other services
With a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things).
We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above in this section “Information Sharing.”

We ask our service providers to confirm that their privacy and security practices are consistent with ours and maintain the confidentiality of personal information received from us, we provide our service providers with only the personal information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by Fuel Cycle.
There may be areas of the Services (e.g., message boards, discussion rooms, and other online forums) in which you are able to post information that will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas and as such, immediately upon posting, the materials or information you post shall be considered public information.

If you identify any of your information as public within your account settings, you are authorizing us to share such information publicly in any manner we elect at any time.

ACCESS AND RIGHTS REGARDING PERSONAL INFORMATION

For registered users, if you would like to modify or delete any personal information stored in your profile that we maintain in our database, or if you would like to delete your profile completely, you can do so as follows: log into the Fuel Cycle client online community and proceed to the “My Account” section where you have the ability to edit your information or close your account. We will use all reasonable efforts to implement these changes within ten (10) calendar days. Please note that any personal information that we have copied in connection with providing our Services may remain in secure back-up storage for some period of time after your request. Note that we are unable to recover any personal information from any Fuel Cycle business client once it has been transferred to such business client. You may contact that business client directly to access information about your personal information that is in their possession.

In addition to the foregoing, if you are a resident of the European Economic Area, including Switzerland, users of our Services (including respondents of our clients) are provided specific rights in regard to the handling of their information. Respondents of our clients may request the following from the data controller (the client) using our automated form:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.
Other users who are not our clients’ respondents and are residents of the European Economic Area, may email us at eurep@fuelcycle.com to exercise the rights in the list above.

If you reside outside the European Economic Area and Switzerland, and you would like to review, correct, update, suppress, or delete the personal information that Fuel Cycle maintains about you, or you would like to request a copy of your personal information held by us, you may email us at privacy@fuelcycle.com
To opt out of receiving marketing communications from us, please see “Choices.”
To opt out of Fuel Cycle’s cookies, please see “Choices.”
To opt out of interest-based advertising from third party cookies, please see “Choices.”
To opt out of the use of precise location, please see “Choices.”
INTERNATIONAL INFORMATION TRANSFERS

Please be aware that the information we collect, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. Please be advised that we process and store information in any country where we have facilities and/or employees, including the United States, or in which we engage service providers. Your consent to this Privacy Policy or your use of any of the Services or your submission of your information to us or any of our clients, represents your consent to such transfer, storage and processing outside of your country of residence, including the United States, which may have different data protection rules than those of your country of residence.

PRIVACY SHIELD

FUEL CYCLE is a participating member of and complies with the EU-U.S. Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. FUEL CYCLE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of 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 our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, FUEL CYCLE commits to resolve complaints about your privacy and our collection and/or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact FUEL CYCLE at:
11859 Wilshire Blvd., Suite 400
Los Angeles, CA 90025
Tel: (323) 556-5400
Email: eurep@fuelcycle.com

FUEL CYCLE has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information about how to file a complaint, provided that you first contact us to resolve this issue. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield panel.

FUEL CYCLE is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

FUEL CYCLE’s accountability for Personal Information that it receives from a participating European Union or Swiss member of the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles which can be found online at: https://www.privacyshield.gov. In particular, FUEL CYCLE remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process Personal Information on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless, and subject to the Privacy Shield Principles, FUEL CYCLE proves that it is not responsible for the event giving rise to the damage. Please see Section 12 for more information on this subject matter.

LEGAL BASIS RELIED ON FOR PROCESSING PERSONAL INFORMATION OF EUROPEAN ECONOMIC AREA INDIVIDUALS

Our clients are the data controller to their end users and respondents. Our Services enable our clients to communicate their privacy statements to their end users and respondents.

Fuel Cycle acts as a data processor with respect to the personal data collected or received by us when we receive such information from our clients (the data controllers). Where we operate as a data processor, we are processing the data on behalf of our clients (the data controller(s) of the data) based on their instructions, and it is the responsibility of the data controller to establish an appropriate legal basis for the processing of the data. For example, we may process data when the individual has consented to such processing. On certain occasions we may rely on legitimate interest as a basis for processing, when it is in our clients’ and our legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include performing our obligations with respect to providing the Services and improving our Services.

Fuel Cycle acts as a data controller with respect to the account information of our Services’ users. When a user creates an account, we collect the account creation information. Where Fuel Cycle operates as a data controller, we rely on legitimate interests to process personal data to provide our Services. On certain occasions, we may also rely on the consent of the individual to process personal information (for example, in some jurisdictions, when the user inputs personal information into the Services and consents to receive marketing communications). On other occasions, we may process personal information when we need to do this to fulfill a contract or where we are required to do so by law.

RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or an individual requests deletion in accordance with applicable law. See “Access and Rights regarding Personal Information.”

CHOICES

Opting Out of Marketing

We give you choices regarding our use and disclosure of your personal information for marketing purposes.

You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@fuelcycle.com or by clicking on the opt-out link within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.
Opting Out of Fuel Cycle’s Cookies

You may disable cookies, including Fuel Cycle cookies, by modifying the settings in your browser. However, please note that certain features of the Services may not work if you delete or disable cookies.
Opting Out of Interest-Based Advertising from Third Parties’ Cookies

Some third parties who use cookies when you visit our websites, also have opt-out mechanisms either directly from their website or through an industry-developed web page. When you opt out of receiving interest-based advertising, note that the opt-out only applies to the applicable browser in which you set it. Note also that most opt-out tools are cookie-based. This means that, if you have cookies blocked, you will not be able to use it. Note also that if you delete cookies entirely then you will need to opt out again. Finally, note that once the opt-out has been completed, you will still receive advertisements, but such advertisements will not be interest-based ads.

If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.
Opting Out of Use of Precise Location

To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.

Android
For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).

iOS
In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.

SECURITY

Fuel Cycle maintains a strong commitment to secure software development practices. We practice regular code scans, penetration tests, and are SOC II, Type 2 certified. Our security procedures and practices are reasonably designed to help protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.

USE OF SERVICES BY MINORS

We are committed to protecting the privacy needs of minors and we encourage parents and guardians to take an active role in their children’s online activities and interests. The Services are not intended for and may not be used by minors under 18 or the legal age of majority in the applicable jurisdiction. We do not knowingly collect information from minors under the age of 18 or the legal age of majority in the applicable jurisdiction, and we do not direct the Services to, or encourage the use of the Services by, minors under the age of 18 or the legal age of majority in the applicable jurisdiction.

CHANGES TO THIS PRIVACY POLICY

We reserve the right, at our discretion, to change this Privacy Policy at any time. Your continued use of the Site and/or Services thereafter means that you accept those changes. Please see the date at the top of this page to view when this Privacy Policy was last revised. Where required by law, we will obtain your consent to make these changes.

CONTACTING US

For any questions about this Privacy Policy or Fuel Cycle’s privacy practices, please contact us by email at privacy@fuelcycle.com, or by mail at:
Fuel Cycle Inc.,
11859 Wilshire Blvd., Suite 400
Los Angeles, CA 90025

For EEA Residents: Please contact our EU Representative at eurep@fuelcycle.com. Alternatively, they can be reached by post (DPO Centre, 50 Liverpool Street, London, EC2M 7PR) or +44 203 797 6340
www.dpocentre.com