Farragut Privacy Policy
Effective Date: October 25, 2024
Introduction
At Farragut, safeguarding your privacy is our top priority. This Privacy Policy explains how Farragut (“we,” “us,” “our”) collects, uses, discloses, and safeguards your personal data in compliance with applicable data protection laws. Whether you’re a client, partner, visitor to our website (the “Site”), or engaging with our other services (collectively, the “Online Services”), we are committed to maintaining transparency and security in all interactions with your information.
Farragut mainly processes personal data as a “data processor,” which means we handle data on behalf of our clients, such as businesses, municipalities, and government agencies. In these cases, our clients are the “data controllers” and decide how the data is used. However, Farragut also acts as a “data controller,” where we decide how and why personal data is processed directly.
We reserve the right to update this Privacy Policy periodically. Any changes will be posted on our website and will take effect immediately. By continuing to use the Online Services after updates are made, you accept these changes. If you do not agree with the policy, we advise you not to use the Farragut Platform.
You can jump to particular topics by going to the headings below:
- What Constitutes Personal Information?
- Data Roles: Data Processor and Data Controller
- Personal Information We Collect
- Data Collection, Usage, and Sharing (Processor & Controller)
- How We Collect Your Personal Information
- How We Use Your Personal Information
- Google Analytics and Cookie Policy
- How We Share Your Personal Information
- Your Privacy Rights
- Information Security
- How We Retain Your Personal Information
- Other Important Information
- Children’s Policy
- Changes to Our Privacy Policy
- Contact Information
- Supplement California Privacy Rights Statement
What Constitutes Personal Information?
The term “personal information” in this Privacy Policy refers to any information or data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular identifiable natural person or household, or any other information or data that constitutes “personal information”, “personal data,” or “personally identifiable information.”
An identifiable natural person, or “Data Subject,” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Data Roles: Data Processor and Data Controller
Data Roles: Data Processor and Data Controller
Depending on your relationship with Farragut, we may act as either a data Processor or data Controller of your personal information.
When acting as a data processor, Farragut processes personal data according to our client’s instructions. For example, if you interact with any of our applications on behalf of one of our clients, the Farragut client manages your data and should be contacted for any questions regarding your data.
When Farragut acts as a data controller, we determine the purposes and methods of processing your personal data. This often occurs when you interact directly with Farragut services, websites, or applications. In this situation, you may reach out to Farragut directly if you have any questions or concerns about how your personal information is being used.
Personal Information We Collect
We collect the following information in the course of providing you with our Online Services:
| Context | Types of Information | Primary Purpose for Collection |
|---|---|---|
| Client & Prospective Client Contact Information | We collect the names, emails, and contact data of our clients, prospective clients, and their employees with whom we may interact. | We are executing on a contractual obligation in contacting our clients and a legitimate interest in contacting our prospective clients, to communicate with them concerning normal business administration such as billing, registration, and our services. |
| Client and User Account Information | We collect personal information from our clients and users of our Online Services when they create an account to access and use the Online Services. This information could include business contact data such as name, email address, title, company information, phone number and password for the Online Services. | We are executing on a contractual obligation by providing account-related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. |
| Client Tax & Workers’ Compensation Information | Our clients use our Online Services to collect and process tax and workers compensation related information. This may include information such as the client’s name, business contact data, Employer Identification Number (EIN), financial data, and other relevant tax and workers’ compensation information. | We are executing on a contractual obligation to provide our clients with our Online Services. Our clients provide us with this information directly and consents to Farragut processing this information to fulfil its contractual obligations to the client. This information will be processed in accordance with applicable local laws and regulations. |
| Employment-related Information | If you apply for a job posting or become an employee of Farragut, we collect the information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number, date of birth, address, phone number, and banking information. Providing this information is required for employment. | We use information about current employees to fulfil our contract of employment or the anticipation of a contract. In some cases, we are required by law to collect employee data to ensure efficient staffing and workforce operations. |
| Cookies and First-Party Tracking | We use cookies on our website. “Cookies” are small pieces of data that a website sends to a computer’s hard drive while a website is viewed. | We have a legitimate interest in making our website operate efficiently and improving our marketing efforts and Online Services. |
| Cookies and Third-Party Tracking | We participate in the gathering of analytics using third-party cookies. This means that a third- party uses technology (e.g., a cookie) to collect data about your use of our website so that they can provide us with website and user analytics, as well as for the purposes of advertising products and services tailored to your interests on our website, or on other websites. | We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics in improving our marketing efforts. You can manage your cookie consent preferences via our website's cookie banner. |
| Email Interconnectivity | If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners contained within. | We have a legitimate interest in understanding how you interact with our communications to you. |
| Feedback and Support | We collect personal information from you contained in any inquiry you submit to us regarding the Online Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. | We have a legitimate interest in receiving and acting upon your feedback, issues, or inquiries to improve support and service offerings. |
| Payment Information | We collect payment and billing information when you pay for our Services. For example, we ask you to designate a billing representative, including name and contact information. You might also provide payment information, such as payment card details, which we collect via secure payment processing methods. | We are executing on a contractual obligation in obtaining payments for certain Online Services, ensuring secure and compliant transactions. |
| Website Interactions | We use technology to monitor how you interact with our Online Services. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our Online Services to improve them and detect and prevent fraud. |
| Social Media | When an individual interacts with our Services through social media networks, such as when someone follows us or shares our content on LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The information we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. | We use this information to update and maintain our social media presence and improve product outreach. You should review your privacy settings on social networks before sharing information. |
| Web Logs, Device and Usage Information | We collect information, including your device and browser type, operating system, operating system and browser version, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), derived IP address location, domain name, click-activity, referring website, and/or a date/time stamp for visitors. Additionally, we collect user account activity to include when an activity is completed, the type of activity taken, and the related data for the activity (for example, if a user sends a message, etc.). | We have a legitimate interest in monitoring our networks and visitors to our Online Services. Among other things, it helps us to monitor performance and to understand which of our Online Services and features are the most popular. |
| Mailing List and Demo Requests | When you sign up for our mailing lists, or when you submit a demo request, we collect contact information such as your name, email address and company affiliation. | We share information about our Online Services with individuals that consent to receive such information to keep users informed about product updates and provide relevant demonstrations based on user needs. |
| Surveys | When you participate in a survey, we collect data that you provide through the survey. If the survey is provided by a third-party service provider, the third-party’s privacy policy applies to the collection, use, and disclosure of your information. | We obtain consent for any surveys and use them to gain an understanding of your opinions and collecting data relevant to our organization. |
Data Collection, Usage, and Sharing (Processor & Controller)
Regardless of whether we are acting as a processor or controller, Farragut follows consistent methods for collecting, using, and sharing personal data.
How We Collect Your Personal Information
In addition to the information we collect directly from you, Farragut may receive information about you from other sources, such as third parties, business partners, affiliates, or publicly available records. For example, if you apply for a job or become an employee, we may conduct background checks.
Farragut is committed to complying with data protection laws in all the regions where it operates and provides its Online Services. These laws, collectively referred to as “Data Protection Laws,” govern individual privacy and breach notification requirements.
If you are located in a U.S. state with privacy protection legislation, please refer to the “Your Privacy Choices” section for additional details.
How We Use Your Personal Information
We use the personal information that you provide to us to perform our Online Services as outlined in this Privacy Policy. When you are our prospective or current business client or use our Site, we use personal information about you to:
- deliver the Site;
- carry out “Know Your Client” checks and screenings prior to starting a new engagement;
- carry out client communications, services, billing, and administration;
- configure our Online Services and your dashboard access, and other professional services that you may request;
- secure client feedback;
- deal with client complaints and requests;
- create marketing materials such as white papers, case studies, and social media content; or
- contacting and marketing to our clients.
We also process personal information about our clients/prospective clients and employees of our clients/prospective clients to:
- contact our prospects and clients in relation to current, future, and proposed engagements;
- send our prospects and clients newsletters, know-how, promotional material, and other marketing communications; or
- invite our prospects and clients to events (and arrange and administer those events).
When you are a visitor to our Site or request marketing information, we may use your personal information to:
- monitor the performance of our Site and analyze trends, usage, and activities in connection with our Site;
- deliver targeted advertising where permitted by applicable law; or
- respond to your requests, deliver information (including marketing information) to you based on your needs and interest.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent, unless there is an exception which applies under applicable law, such as those listed in the section below. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations.
Google Analytics and Cookies Policy
Farragut uses Google Analytics to help analyze how visitors use our website. Google Analytics collects information such as how often users visit our site, what pages they visit, and other actions they take while interacting with the site. This data helps us improve the performance and user experience of our website.
Google Analytics may collect information about your device and browsing activities, including:
- IP Address
- Browser Type
- Operating System
- Pages Visited
- Time Spent on Pages
- Geolocation Data (Approximate Location)
Please note that Google Analytics operates through cookies, small text files placed on your device to track activity. These cookies may remain on your device after your session has ended. To opt-in or opt-out of the use of Google Analytics, you can manage your cookie consent preferences in the cookie consent manager via our website’s cookie banner. Additionally, you can manage your preferences through your browser settings, including blocking or deleting cookies.
You can also opt out of Google Analytics tracking entirely by installing the Google Analytics Opt-out Browser Add-on, which prevents Google Analytics from collecting information on websites you visit.
For more information on how Google collects and processes data through Google Analytics, please visit Google’s Privacy Policy.
If you prefer not to be tracked by Google Analytics, you may:
- Adjust your browser settings to block or delete cookies.
- Use the Google Analytics Opt-out Browser Add-on as mentioned above.
While disabling cookies or opting out of Google Analytics may limit certain functionalities on the Farragut website, it will not prevent you from using the site.
If you have further questions about the use of Google Analytics on our site, please contact us at info@farragut.com.
How We Share Your Personal Information
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information we collect from you:
(1) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others
(2) to our authorized service providers such as our contractors and other third parties we use to support our business;
(3) to fulfil the purpose for which you provide it;
(4) to a buyer or other successor in the event of a sale, merger, reorganization or transfer of some or all of our business or assets;
(5) for any other purpose disclosed by us when you provide the information;
(6) to comply with any court order, law or legal process, including responding to any government or regulatory request;
(7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; or
(8) with your consent. We do not sell your personal information or otherwise share personal information with third parties for direct marketing purposes.
Your Privacy Rights
You have control over your personal data in several ways:
- Right to Access Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
- Right to Data Portability. You may have the right to obtain a copy of the personal information that you previously provided. We will provide this information in a portable format, to the extent technically feasible, readily usable format that allows you to transmit your personal information to another controller without hindrance, where the processing is carried out by automated means. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. Please refer to the Supplemental California Privacy Rights Notice for additional information.
- Right to make Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.
- Right to Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
- Right to Object to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in the e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
- Revocation Of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
Please address written requests and questions about your rights to info@farragut.com.
As required by law, Farragut will need to verify your identity before processing any requests related to your personal information. We may verify your identity through a phone call or email. Depending on the nature of your request, we may ask for information such as your name or account details. In some cases, we may also request a signed declaration confirming your identity. After receiving your request, we will make reasonable efforts to provide, correct, or delete your personal information as requested.
In certain cases, you may appoint an authorized agent to make privacy requests on your behalf. Farragut will require verification that you have granted the authorized agent permission to act on your behalf. You will need to provide a copy of the signed authorization permitting the agent to make the request, and you must verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, please include the following:
- A notarized statement completed by both you and the individual, confirming you are authorized to act on their behalf.
Information Security
At Farragut, we prioritize the security of your personal information. We have implemented measures designed to protect your data from accidental loss, unauthorized access, and disclosure. For more details about our security practices, you can visit our Trust Center, accessible at trust.farragut.com.
Access to your personal information is restricted to authorized individuals who require it to provide services to you and who have been trained on the importance of safeguarding personal information. Our service providers and business partners are also contractually obligated to keep your information confidential and to use it only for authorized purposes. However, no method of transmission over the internet or electronic storage is completely secure.
While we make reasonable efforts to secure your personal information, we cannot guarantee its absolute security. Any transmission of personal information through our website or other electronic means is done at your own risk. Should we be legally required to notify you of a personal data breach, we may do so via electronic communication, written notice, or phone, as permitted by law.
How We Retain Your Personal Information
Farragut retains personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by law. Typically, personal information is kept for as long as your account remains active or until you request deletion. The exact retention periods vary based on the type of information and why it is collected. Factors we consider include the volume and sensitivity of the data, potential risks of unauthorized use or disclosure, and legal requirements.
We may anonymize your personal information, ensuring it can no longer be associated with you, for research, statistical, or business purposes. We may retain this anonymized data indefinitely. Personal information may also be kept for backup, archival, or audit purposes, and to comply with legal obligations or resolve disputes. For further details on retention periods, please contact us at info@farragut.com.
Other Important Information
- Third-Party Providers: Some of the services on our Site or Web App may be embedded or linked from third-party providers. These third parties may use cookies or other tracking technologies to collect information about you, including for interest-based advertising. We do not control their privacy practices, and this Privacy Policy does not apply to any third-party website or service you may access through our Site. Please contact the third-party provider directly with questions about their privacy policies.
- Non-Personal Information: This Privacy Policy does not limit our use or disclosure of aggregated, anonymized, or non-personally identifiable information.
- Accessibility: If you require this Privacy Policy in an alternative format due to a disability, please contact us at info@farragut.com for assistance.
Children’s Policy
The Farragut website and its services are not intended for use by children under the age of 18. We do not knowingly collect or contact personal information from children under 18. For more information on how to protect children’s privacy online, please visit https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.
Changes to Our Privacy Policy
Any changes to this Privacy Policy will be posted on our website. If material changes are made to how we treat your personal information, we may notify you via email or through a notice on our website’s homepage. By continuing to use our Site or Online Services after changes are posted, you accept these revisions. The date of the last revision is stated at the top of this Privacy Policy. It is your responsibility to ensure we have a current and valid email address and to periodically review this Privacy Policy for updates.
Contact Information
For questions or comments about this Privacy Policy, you can reach us at info@farragut.com or by mail at the following address:
Farragut Systems, Inc.
2775 Meridian Parkway
Durham, NC 27713
Supplemental California Privacy Rights Notice
Effective Date: October 25, 2024
California Privacy Disclosures
The California Consumer Privacy Act (hereafter: ‘CCPA’) and the California Privacy Rights Act (hereafter: ‘CPRA’) provide California consumer residents who reside in California with specific rights regarding their personal information (which we also refer to as personal data). In addition to the above this section describes your CCPA/CPRA rights and explains how to exercise those rights.
The following does not apply to de-identified or aggregated personal data or data publicly available, which are not considered Personal Information since they do not identify any individual.
Your Rights
“Right to Know”: You may have the right to request that we disclose to you what personal data of yours we collect, use, and/or disclose.
“Right to Delete”: You may have the right to request the deletion of your personal data collected or maintained by us. Depending on your Choices, certain offerings may be limited or unavailable. Upon verifying the validity of a deletion request, we will delete your personal data from our records and instruct any service providers or third parties to delete your information, when applicable.
“Right to Control Use”: You may have the right to control or limit the use of your personal data, including:
- Right to Opt-Out of Sales/Sharing/cross-context behavioral advertising.
- Right to Object to or Opt-Out of automated decision-making/profiling.
- Right to Opt-Out of processing/Limit Use of Sensitive personal data.
“Right of Access”: You may have the right to access your personal data, and to transmit it to another entity.
“Right of Correction”: You may have the right to request amendments to your personal data if it is inaccurate or outdated in any way. Upon verifying the validity of a verifiable correction request, we will use commercially reasonable efforts to correct your personal data as directed, considering the nature of the personal Data and the purposes of maintaining your personal data.
Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA/CPRA. Based on the complexity of the request and the applicable regulations, we may charge a fee for your request. We may offer a CCPA/CPRA-permitted financial incentive, participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Exercising Your Rights
You may make a verifiable request to exercise your privacy rights by contacting us via email at info@farragut.com or by providing a written request by mail to Farragut at 2775 Meridian Parkway Durham, NC 27713. You may also contact us on 1.888.422.2626.
Please note that the above rights depend on a few things, and we may refuse requests if there are exceptions under the applicable law.
If we cannot verify you (or your authority to act on behalf of another person) we have the right to deny the requests. While verifying your identity we generally avoid requesting additional information from you for verification purposes. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used to verify your identity while you are seeking to exercise your rights under applicable law, and for security or fraud-prevention purposes.
We delete any new Personal Information collected for verification as soon as practical after processing your request, except as required to comply with applicable legislation.
An “authorized agent” means a natural person, or a business entity registered with the Secretary of State that you have authorized to act on your behalf, conditioned you have:
- Provided the authorized agent written permission to do so, and we could verify this; and
- Verified your own identity directly with the business.
Subsection 1 does not apply when you have provided the authorized agent with a valid power of attorney.
We do our utmost to timely respond to a verifiable Individual, and in a portable format unless it is excessive, repetitive, or materially unfounded. If we require more time, we will inform you of the reason thereof and the extension period in writing.
Do Not Sell or Share My Personal Information
We do not respond to “Do Not Sell” requests as we do not sell your Personal Information to third parties. In the twelve months before the effective date of this Privacy Notice, we have not sold any Personal Information of Clients, as per the definition of the CCPA/CPRA and similar laws.
After receiving your opt-in consent, we sometimes disclose Personal Information collected via cookies for cross-contextual behavioral advertising purposes, which may qualify as sharing your Personal Information under the CCPA/CPRA. To opt-out of this use, you can adjust your cookie preferences on our website’s cookie banner to block our advertising cookies. Additionally, you can change your device settings to block cookies or install a third-party plugin to control how cookies interact with your device.
