PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy (the “Policy”) is effective as of February 28, 2022.

Find Know Do LLC, (“FKD” or “we”), which operates this website (the “Site”) is committed to protecting individuals’ privacy rights, which is why we have developed and implemented this Policy.

This Policy explains:

• the types of Personal Data we collect about you;
• the means by which we obtain your Personal Data;
• the ways in which we use your Personal Data;
• the bases on which we use your Personal Data;
• who we share your Personal Data with;
• the length of time for which we keep your Personal Data;
• how we protect your Personal Data; and
• where and why we transfer your Personal Data outside of the EU.

We may collect your Personal Data as a visitor or subscriber to the Fried Frank Regulatory Intelligence website www.findknowdo.com and/or our newsletter (collectively, the “FKD Offerings”).

2. DATA CONTROLLER AND RESPONSIBLE OFFICER

Find Know Do LLC, a New York limited liability partnership located at One New York Plaza, New York, NY 10004, is the Data Controller responsible for the implementation of this Policy.

Should you have any questions about this Policy or how FKD handles your Personal Data, please email [email protected].

3. THE TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect your Personal Data when conducting our business, including when you contact us, seek information from us, visit the Site, or subscribe to the FKD Offerings. Such Personal Data may include:

• personal identifying information, such as your name, email address, company name and job title, telephone number, and postal address;
• technical information (for example, the number of visits you make to the Site, or your receipt and use of materials and communications we send to you electronically via the FKD Offerings); and
• any other information relating to you that you may provide to us.

4. HOW WE RECEIVE YOUR PERSONAL INFORMATION

We come into possession of your Personal Data in many ways, including:

• during the monitoring of our technology, such as the FKD Offerings;
• when you provide information to us, or during your interactions with us directly, such as face‑to‑face interaction and through telephone calls with our staff and online interactions using the Site or email; and
• from third-party sources (including, for example, LinkedIn and other social media).

5. HOW WE USE YOUR PERSONAL INFORMATION

We collect and process your Personal Data in a variety of ways, including when you use the Site and the Newsletter. When we collect and process Personal Data, we do this to:

• manage and administer our relationship with clients, vendors and other third parties in the conduct of the FKD Offerings’ business;
• market our services, including sending publications and the details of events to our clients and friends;
• administer the FKD Offerings, including our monitoring of their use;
• deliver and enhance our services;
• make available information requested by you; and
• meet any of our legal, regulatory and risk management obligations.

A. Services

When we provide services to our subscribers and visitors, we may collect, develop, retain and use Personal Data.

We process Personal Data in order to onboard new subscribers, including as part of our finance, administration and marketing processes. To the extent reasonably necessary in connection with our services, we may need to share Personal Data with third parties. Please also see sections 7 and 9 below.

B. Marketing and other emails

If you receive our FKD Offerings and any other marketing materials, we may use your Personal Data to try to understand:

• whether you open our emails or other materials, either by downloading images in the emails or clicking links;
• whether you click on the web links, unsubscribe links or event RSVP links included in our emails and marketing materials; and
• how you visit the Site after you click on links we have shared with you, both immediately and on future visits. We do this by using software that places a cookie on your device that tracks this activity and records it against your email address. Please see our Cookie Policy, which is posted on the Site, for more information on how to manage and remove cookies.

If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time by emailing [email protected].

C. Meetings, events and seminars

When you attend meetings and events organized by FKD or one of its business partners, including the law firm Fried, Frank, Harris, Shriver & Jacobson LLP (“Fried Frank”), or contractors, we may collect and process Personal Data about you in relation to your attendance, including your contact information, name and employer. We also may collect special categories of Personal Data, including dietary requirements, allergies or access requirements, so that we can appropriately cater to your needs and meet any other legal or regulatory obligations we may have. We may share your information with our business partners, including Fried Frank, and contractors who are involved in organizing or hosting the relevant events.

D. Using the Site

When you access or use the Site, you may be asked to provide us with Personal Data; for example, when you sign up to the Fried Frank Regulatory Intelligence news resource, you will be asked to provide your name and contact information. When you provide us with Personal Data in this way, we only use it for the purposes stated to you at the time we collect that information.

We also use cookies on the Site. Please see our Cookie Policy, which is posted on the Site, for more information on how to manage and remove cookies.

6. THE BASES ON WHICH WE USE YOUR PERSONAL INFORMATION

We use your Personal Data on the following bases:

• legitimate business purposes, which are described more fully above in section 5;
• your explicit consent;
• in order to comply with legal and regulatory obligations; and
• the establishment, exercise or defense of legal claims and proceedings.

7. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may share your Personal Data with Fried Frank, a law firm headquartered in New York, with additional offices in Brussels, Frankfurt, London, and Washington D.C. in accordance with contractual agreements we have put in place with Fried Frank. Information that you provide to us may be shared with and processed by any of the Fried Frank offices, and any future Fried Frank offices or third parties, should Fried Frank’s business structure change in the future.

We may also share your Personal Data with other third parties in accordance with the contractual arrangements we have put in place with them, including with:

• our professional advisers and auditors; and
• third‑party suppliers we engage to conduct certain services on our behalf, including consultants, content and subscription managers, meeting planners, event organizers and IT service providers.

We also may share Personal Data with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies where such disclosure is necessary to comply with legal or regulatory requirements. Unless we are restricted from doing so by law, we will use reasonable endeavors to notify you before we make any such disclosure.

We do not allow Personal Data to be made commercially available to any third party unless we have first obtained your prior permission.

8. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We retain your Personal Data for as long as necessary to comply with our legal and regulatory obligations.

9. TRANSFERRING YOUR PERSONAL INFORMATION TO OTHER COUNTRIES

When providing our services, we may need to transfer your Personal Data outside of the country in which you are located for the purposes set out in this Policy. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”), Switzerland or the United Kingdom (“UK”) to outside the EEA, Switzerland or UK, or from outside the EEA, Switzerland or UK to a location within the EEA or UK. Please see section 7 for more detail on how the information may be shared with third parties.

The level of information protection in countries outside the EEA or the UK may be less than that which is offered within the EEA or the UK. Where this is the case, we will implement appropriate measures to ensure that your Personal Data remains protected and secure in accordance with applicable data protection laws. Where our third‑party service providers process Personal Data outside the EEA or UK in the course of providing services to us, appropriate measures, usually standard contractual clauses, will be included in our written agreement for the service provision.

10. DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means and the applicable legal requirements.

11. HOW WE PROTECT YOUR PERSONAL DATA

Consistent with applicable data protection laws, we utilize technical and organizational measures to protect your Personal Data from unauthorized access, use, disclosure, alteration or destruction. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your Personal Data transmitted to our Site, and we urge you to use caution on the internet. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. If you have reason to believe that your interaction with the Site is no longer secure, please immediately notify us in accordance with the “Data Controller and Responsible Officer” section above.

12. YOUR LEGAL RIGHTS

Subject to certain limitations, you have rights under data protection laws in relation to your Personal Data. These include the rights to:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. Note that we may refuse to comply with a request for access if the request is manifestly unfounded, excessive or repetitive in nature.
• Request correction of your Personal Data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Note that we may refuse to comply with a request for correction if the request is manifestly unfounded, excessive or repetitive in nature.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note that we may refuse a request for erasure, for example, where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims.
• Request restriction of processing your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Note that we may refuse to comply with a request for restriction if the request is manifestly unfounded, excessive or repetitive in nature.
• Request transfer of your Personal Data. We will provide to you, or a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies where your Personal Data is processed by us with your consent or for the performance of a contract, and when processing is carried out by automated means.
• Right to withdraw consent. You can withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Right to object. You have a right to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive, including the FKD Offerings.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. For example, we may refuse to comply with a request if it is manifestly unfounded or excessive.

13. EXERCISING YOUR LEGAL RIGHTS

If you wish to exercise any of the rights set out above, including withdrawing consent, please contact us at [email protected] and give us specific details regarding which right(s) you choose to exercise.

Making a Complaint

If you have concerns relating to your data privacy or the processing of your Personal Data, please bring it to our attention by contacting us at [email protected].

You can find out more about the rights you may have under the GDPR or UK GDPR by contacting a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/. Information regarding the Swiss data protection authority is available at: https://www.edoeb.admin.ch/edoeb/en/home.html.

14. CHANGES TO OUR PRIVACY POLICY

It is FKD’s policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on the Site’s home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Site and this privacy policy to check for any changes.

COOKIE POLICY

INFORMATION ABOUT OUR USE OF COOKIES

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable a website to function or to provide information to the owners of a website. A cookie cannot read data from your hard disk or read cookie files created by other site.

Why do we use cookies?

The Site (www.findknowdo.com) uses cookies to distinguish you from other Site users. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site, you are agreeing to our use of cookies.

In broad terms, we use the following cookies:

• Session management cookies. The software that runs our Site uses cookies for technical purposes needed by the internal workings of our servers and applications. For instance, we use cookies to keep track of information about a user’s session and determine which options or pages to display in order for the Site to function.
• Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, such as the Site member login portal, available at https://www.findknowdo.com/sitemember/login.
• Analytical/performance cookies. These cookies allow us to recognize and count Site visitors and to see how visitors move around our Site when they are using them. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. For these purposes, we may store the following information:
  • your browser type;
  • the name of the domain from which you accessed the internet;
  • the date and time you accessed our Site;
  • the advert or internet address of the site from which you linked directly to our Site;
  • the pages you accessed while visiting our Site and the links you followed;
  • the device from which you accessed our Site;
  • the location from which you accessed our Site; and
  • the search terms you used.

In addition, we use third party service providers to provide certain analytics services to us in connection with the operation of the Site, including (without limitation) the collection and tracking of the data and information listed above. We may disclose visitor data, including Personal Data, to enable those third party service providers to provide their services. This data may be sent to those third party service providers and their local overseas suppliers, where the standard of data protection may be lower than the country in which you reside.

• Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. For example, if you click through to our Site from one of our emails or landing pages, we use cookies to connect the marketing you have received with your website journey. This helps us to provide you with the best user experience and relevant content.
• Functionality cookies. These cookies are used to recognize you when you return to our Site and enable us to remember the choices you make when using our site.
• Subscribers: The information collected is supplied by the user or the company who signed them up. This information includes at present:
  First and Last name
  Professional Field
  Company Name
  Department
  Job Title

Subscribers may also set bookmarks to pages on our Site or subscribe to a weekly alerts bulletin. These opt-in choices are also stored on our Site.

Subscribers' web browsing logs are kept for up to 6 months and include the user's IP address as well as their username and the pages they have visited.

Third party cookies

Please note that, when you visit our Site, you may also receive cookies set by third parties (including, for example, advertising networks and providers of external services such as web traffic analysis services). We have no control over these cookies; however, they are likely to be analytical/performance cookies or targeting cookies.

Amending cookie preferences

If you prefer not to receive cookies through our Site, you may set your browser to warn you before accepting cookies and refuse the cookies when your browser alerts you to their presence. You may also delete cookies that have already been placed on your device or refuse all future cookies by turning them off in your browser. Cookies are required to access some pages within our Site at www.findknowdo.com.

The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. But you may find further guidance, together with more information on cookies, at: www.allaboutcookies.org.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below: