PRIVACY POLICY

Version 3.0; Last updated on September 11, 2023

1. OVERVIEW

The Financial Accounting Foundation (FAF), Financial Accounting Standards Board (FASB), and Governmental Accounting Standards Board (GASB, and together with FAF, FASB, and any affiliates or applicable representatives thereto, collectively referred to as “We” or “Us” or “Our”) understand how important the protection of your personal information is to you. This Privacy Policy governs the privacy practices used by Us on Our “Websites” (http://www.accountingfoundation.org/, http://www.fasb.org/, http://www.gasb.org/, and on any other sites maintained or held by Us); offline data collection, use, and disclosure activities; and how We use your “Personal Information.” Data may be shared by and among Us. Please also read any Terms and Conditions posted on Our individual Websites, or areas of Websites, governing your use thereof. Our Privacy Policy and related activities are consistent with any requirements to which We are subject under the general data protection regulation or similar U.S. privacy laws.

2. CHANGES TO PRIVACY POLICY

This Privacy Policy is subject to change to adjust to Our business needs, preferences, or regulatory requirements. Whenever there are changes, the modified Privacy Policy will be posted on the Websites. Accordingly, it is recommended that you regularly check the Websites for updates to this Privacy Policy; We will provide a version number and date at the top of the document for your convenience for all major changes. If you are unable or unwilling to comply with the changes to the Websites or Our accommodations, you are expected to discontinue your use of the Websites and of any content therein.

3. COLLECTION OF PERSONAL INFORMATION

“Personal Information” is any data that can be used to identify, or is attributable to, a specific individual.

We may gather Personal Information from you in both Our online and offline processes. The types of information collected may include, but are not limited to, your name, email address, IP address, organizational affiliations, personal preferences, phone number, payment information, residential and/or business postal addresses, and “user journey” information regarding your engagement with Our Websites. You are not required to provide Us with all of the Personal Information listed above, but if you do not do so, We may not be able to effectively provide you with Our offerings, services and information.

We may gather Personal Information from you in both Our online and offline processes. The types of information collected may include, but are not limited to, your name, email address, IP address, organizational affiliations, personal preferences, phone number, payment information, residential and/or business postal addresses, and “user journey” information regarding your engagement with Our Websites. You are not required to provide Us with all of the Personal Information listed above, but if you do not do so, We may not be able to effectively provide you with Our offerings, services, and information.

We collect "sensitive" personal information when the relevant individuals voluntarily provide Us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political beliefs, religious or similar beliefs, physical or mental health, or criminal record. Please use discretion when providing sensitive information to Us, and under any circumstances, do not provide sensitive information to Us unless you thereby consent to Our use of that information for business purposes and that you consent to the transfer to—and storage of—such information in Our databases, or the databases of any third party providers acting on Our behalf. If you have any questions about whether the provision of sensitive information to Us is, or may be, necessary or appropriate for particular purposes, please contact Us at privacyupdate@f-a-f.org.

In the course of providing you with the services you find on Our Websites, Our Web, and application server might collect “user journey” or usage-related information including: the URLs that you access through Our Website; the date and time of your usage, your Internet protocol (IP) address, your Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, number of clicks, and your browser type.

We may collect Personal Information in one or more of the following ways:

  • From communications, requests, comment letters, submission of academic papers, submission of transition resource group issues (where applicable), surveys, technical inquiries and suggestions submitted by you through Our Websites, any Website portals, or outside of Our Websites
  • Through phone, fax, mail or email communications, including communications you originate from the "Contact Us" page or other Website areas
  • Through any credentialing processes for access to certain types of Website use or requests
  • Through third-party service providers, including products and service fulfilment and distribution (See “Financial Transactions”)
  • Through registrations to attend or participate in a meeting, event, Webcast, information session, or other activities in connection with Our standard setting operations, or oversight of the same (either for Us or a third party)

Financial Transactions

While We do not maintain a webstore, We may, from time to time, offer certain products or services on a fee basis. If you make a payment for any of Our products or services, you will be engaging in a “Financial Transaction.” If you provide to Us any financial information through Our website or electronic communication, such financial information may be collected and processed through a third-party provider. We—and the third-party providers—use technology designed to encrypt the transmission of data to Us through the system, as well as financial information We receive, transfer or maintain. Any payment details you provide are used solely for payment processing. We do not store confidential payment information on Our servers, and only authorized employees at FAF can view transaction information.

Use of Cookies

Like most websites, We may employ "cookies" or similar technologies on certain pages of Our Websites. Cookies make the use of the Websites easier by, among other things, saving your preferences or delivering content tailored to your interests, e.g., to statistically analyze usage of Our Websites, and to improve and customize Our content and other offerings.

Types of cookies We may use on Our Websites include:

  • Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We may use session cookies to grant Our users access to content and to enable actions such as remembering application or payment information as you are in the process of entering it.
  • Persistent cookies: These cookies usually have an expiration date in the future and remain in your browser until they either expire, or you manually delete them. We may use them to better understand usage patterns to improve the Websites for Our users, e.g., to remember your choices on the Websites.
  • Third-party cookies: We may permit third-party service providers to place cookies through Our Websites to provide Us with better insights into the use of the Websites or user demographics or to provide relevant services to you. These third parties may collect information about a user's online activities over time and across different websites when he or she uses Our Websites. We do not control the use of third-party cookies or the resulting information and We are not responsible for any actions or policies of such third parties. For example Google Analytics may collect and process data (e.g., how users use the Websites, the number of users visiting the Websites, where they came from, and the pages visited). For more information on Google Analytics, please see Google’s privacy policy and Google Analytics help pages (located at https://www.google.com/policies/privacy/ and https://support.google.com/analytics/?hl=en#topic=3544906). To opt out of being tracked by Google Analytics across all websites, please visit https://tools.google.com/dlpage/gaoptout.
Your use or access of Our Websites will be deemed to be your consent to the storing, accessing and placement of cookies on your computer or other devices. If you do not want to receive cookies through Our Websites, you can adjust your browser preferences to reject all cookies, to allow only "trusted" websites, or to accept only those cookies from sites you are currently on. Unless you have adjusted the setting of your browser accordingly, Our system may issue cookies when you log on to Our Websites. If your browser is set to reject cookies, or if your browser notifies you that you are about to receive a cookie and you reject it, then your use of Our Websites may not be fully functional or as efficient as it would be if the cookie were enabled.

4. USE OF INFORMATION

All Personal Information obtained from you is treated with care to protect your privacy. Except as otherwise discussed within this Privacy Policy (including in this Section and in Section 5), FAF authorizes only specific employees, agents performing duties on behalf of FAF, FASB and GASB, and contractors to access the information you choose to provide.

Bases for Processing Your Personal Information

We will process your Personal Information in furtherance of its legitimate interests in operating Our Services and business on the following bases:

  • Our interests include:
    • For providing and enhancing the provision of Our products, services and information in furtherance of Our standard setting activities;
    • For the performance of a task in the public interest or in the exercise of official authority vested in the party who controls such data; or
    • For legitimate interests pursued by the controller or third party, other than instances where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
  • Where such processing is necessary to fulfil any obligations to you
  • As necessary to comply with Our legal obligations or contractual agreements.

Use of Information

Your Personal Information may be used:

  • As part of Our standard setting activities, and due process, as individuals and as aggregated information in a non-attributable form
  • To provide Our products, materials and services to you
  • To enhance and improve Our products and services, for example, by performing internal research, analyzing user trends and measuring demographics and interests
  • To process invoices or payments from or to you (including reimbursements or payments for any products or services)
  • Internal purposes, such as website and system administration or internal audits and reviews
  • To respond to your requests and inquiries
  • In connection with, your participation in surveys, focus groups, meetings, events, Webcasts, information sessions, or other initiatives which help Us to gather information used to further Our standard setting activities, or oversight
  • To comply with applicable law(s) or to carry out internal investigations
  • For internal administration and record keeping
  • To support Website operation (e.g., account maintenance, capacity planning, and troubleshooting, security issues).

Retention of Data

Unless a longer retention period is required by applicable law or Our own internal data retention requirements, We will retain your information for as long as any account or stakeholder interaction is active, as well as for an additional period afterwards to cover any outstanding issues or queries that may arise in relation to your engagement with Us or Our Websites (for example, outstanding obligations). This period of retention is subject to Our discretion.

Consent to Transfer of Information from Outside the United States

If you access the Websites from outside of the United States, information that We collect about you will be transferred to servers inside the United States (or as part of cloud-based services) and maintained, which may involve the transfer of information out of your country of origin. By allowing Us to collect information about you, you consent to such transfer and processing of your data by Us or any third party acting on Our behalf.

We will not collect your Personal Information through the Websites unless you have provided it to Us voluntarily or the collection is pursuant to one of the lawful bases set forth above. Whenever Personal Information is transferred to entities based in countries outside of the European Economic Area, We will make sure that the data is transferred in accordance with this Privacy Policy and as indicated by applicable laws and rules regarding the protection of data in the communication of data to third parties as described above.

5. DISCLOSURE OF INFORMATION

It is Our commitment that your Personal Information is disclosed only to third parties to the extent needed to deliver a business-related service or program or in compliance with FAF, FASB, and GASB standard setting process or related operations. Vendors are prohibited from using this information for any purpose outside of the scope of the prescribed activities.

Bases for Third-Party Disclosure

We may disclose your Personal Information to third-parties from time to time under the following circumstances:

  • You request or authorize the disclosure of your Personal Information to a third party.
  • The Personal Information is disclosed as permitted by applicable law(s) and/or in order to comply with applicable law(s), or applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, or to enforce Our Terms of Use or other agreements, or to protect Our rights, property or safety or the rights, property or safety of Our users or others.
  • Personal Information may be provided to Our agents, vendors or service providers who perform functions on Our behalf.
  • Personal Information may be disclosed as part of the standard setting process or supporting internal operations, e.g. to:
    • Third-party contractors and processors who perform services for Us: (i) in connection with the Websites, (ii) to complete or confirm a transaction or series of transactions that you conduct with Us, or (iii) to enable that party to perform business, professional or technical support for Us.
    • Complete internal and externally based audits
    • In connection with the standard setting process
    • In the aggregate as part of research on Our users' demographics, interests, and behavior based on the information We collect.
    • As part of a transfer of assets or related interests of FAF.
Note that We cannot guarantee compliance by—nor are We responsible for—any entity receiving such information, with all the terms of this Privacy Policy.

Third-Party Recipients

While the specific identity and categories of such third-party recipients may change, Personal Information disclosure may be made to the following types of categories of third-party service providers who perform functions on Our behalf:

  • Hosting providers for the secure storage and transmission of your data;
  • Database software providers for the management and tracking of your data
  • Legal and compliance consultants, such as external counsel, external auditors, or tax consultants;
  • Marketing, authentication, fulfilment, distribution and payment solution providers for the secure offering, fulfillment of Our products and services, and/or processing of payments you provide to us;
  • Publishers, providers, or strategic partnerships who develop products on Our behalf;
  • Technology providers who assist in the development and management of Our web properties or technology solutions and support;
  • Our volunteers, advisory council, trustee, or committee members who perform various functions on Our behalf, or in support of Our standard setting activities
  • Survey and research providers who perform studies on Our behalf; and
  • Strategic or professional advisory service providers or consultants acting on Our behalf, or providing services.
We require Our third-party service providers to use your Personal Information as necessary to provide the requested services to Us.

Public Access to Information

In addition, there are public disclosures made as part of the standard setting process. Specifically, communications or materials that the FAF, FASB, or GASB receives that could be viewed to be part of the standard setting process—and that We determine to be part of Our due process public record—may be posted or otherwise made available for public inspection. Individuals or entities providing such materials or communications are thus agreeing to full use by FAF, FASB, or GASB and public accessibility by virtue of making such communications or sharing such materials.

6. Privacy of Minors

FAF Websites are not to be used by persons under the age of 16. If We become aware that a person under the age of 16 is using Our Websites and are asked to delete any data that We have collected about that minor, We will do so.

7. SECURITY

FAF, FASB, and GASB are committed to maintaining the security of information under Our control. We take steps to protect all user data We collect against any unauthorized access. However, you should keep in mind that the Websites run on software, hardware, and networks—any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond Our control. In addition, you also play a role in protecting your information.

Please also be aware that despite the guidelines outlined in this Privacy Policy, no data transmission over the Internet or encryption method can be guaranteed to be completely secure. We cannot guarantee the security of any information you transmit to Us or from Our Websites, and therefore, you use Our Websites at your own risk.

Links to Other Websites

Our Websites may contain links to other websites, including social media websites hosted by third-party providers; however, this Privacy Policy only addresses the FAF’s use and disclosure of your information collected through Our Websites, if any. If you choose to link to an external website from Our Website, We are not responsible for the privacy practices of any third-parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

8. UPDATES, INFORMATION REQUESTS AND CONSENT

If you supply FAF, FASB, or GASB with certain information, you may receive communications from FAF, FASB or GASB.  However, you are entitled to request that We cease or limit Our use of your Personal Information in certain circumstances—for example, if We have no lawful basis to use your data, if you believe your personal data is inaccurate, or if you wish to modify or withdraw previously provided consent to use certain data.

User Rights and Information Requests

As a user, you have the right to:

  • Be informed of the policies regarding use of your Personal Information; and
  • Request information regarding how your personal information is being used by Us, including:
    • The reasons why your data is being processed;
    • The description of the personal data concerning you; and
    • Third-party processing or access of data.

To the extent permitted by law, a fee may be assessed in connection with Our responding to such a request.
 
You may seek to exercise any of these rights by updating your information online (where possible) or by sending a written request to: privacyupdate@f-a-f.org.

Note that We will respond to any requests for access to information in accordance with any applicable statutory requirements.

Opting Out

If you do not wish to receive mass communications from the FAF, FASB, or GASB, you can opt out of receiving them by contacting Us at privacyupdate@f-a-f.org.  Further, if you believe that FAF lacks a lawful basis for using your personal data, please notify Us at privacyupdate@f-a-f.org.

Note that even if you opt out of receiving emails, you may still receive communications related to the FASB and GASB standard setting activities or otherwise as required by law. Also note that We may need to keep information We have collected about you for record keeping, research and other purposes.

NOTE THAT OPTING OUT OR UPDATING PREFERENCES WITH A THIRD-PARTY PROVIDER DOES NOT CONSTITUTE AN OPT OUT OR UPDATE WITH FAF. ONLY THOSE REQUESTS MADE DIRECTLY TO FAF WILL CONSTITUTE A REQUEST WITH RESPECT TO INSTANCES OF DATA HELD AND CONTROLLED SOLELY BY FAF.

Updating Your Data on File with the FAF, FASB, or GASB

Individuals are responsible for providing accurate and complete personal information, and for contacting Us if correction of such information is required at privacyupdate@f-a-f.org.

Please allow ample time for Us to process any request to opt out or update your file.

9. REPORTING

You may report any recommendations, suggestions, or any suspected breaches of privacy or security to Us by Us at webmaster@accountingfoundation.org, or to the address below.  All reports of suspected breaches will be investigated by Us. Any controversy or claim related to privacy that cannot be settled to your satisfaction shall be settled by arbitration, in accordance with its arbitration rules, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.

Financial Accounting Foundation
801 Main Avenue
P.O. Box 5116
Norwalk, CT 06856-5116
ATTN: Webmaster
×