Version 3.0; Last updated on September 11, 2023
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 firstname.lastname@example.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 TransactionsWhile 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.
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.
Bases for Processing Your Personal InformationWe 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 InformationYour 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 DataUnless 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 StatesIf 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.
5. DISCLOSURE OF INFORMATIONIt 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 DisclosureWe 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.
- 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.
Third-Party RecipientsWhile 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.
Public Access to InformationIn 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 MinorsFAF 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. SECURITYFAF, 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.
8. UPDATES, INFORMATION REQUESTS AND CONSENTIf 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 RequestsAs 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: email@example.com.
Note that We will respond to any requests for access to information in accordance with any applicable statutory requirements.
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 firstname.lastname@example.org. Further, if you believe that FAF lacks a lawful basis for using your personal data, please notify Us at email@example.com.
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 firstname.lastname@example.org.
Please allow ample time for Us to process any request to opt out or update your file.
9. REPORTINGYou may report any recommendations, suggestions, or any suspected breaches of privacy or security to Us by Us at email@example.com, 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