Privacy Notice

FDE Privacy Notice

Effective date: September 18, 2026

Last updated: October 05, 2026

I. Introduction

Your privacy is important. This Privacy Notice (the “Privacy Notice”) together with its addendums, Terms of Use, and any other documents referred to in this Privacy Notice explains how FDE complies with applicable privacy requirements and sets out minimum standards for how we deal with all personal data that we collect from you, or that you provide to us, including through any FDE website, platform, application or other digital service that FDE may make available from time to time (collectively, the “Websites”). For the purposes of this Privacy Notice, “FDE,” “we,” “us” or “our” means FDE US, LLC and its group companies, including FDEco, LLC, FDE UNIco, LLC and FDE UKco Limited, as applicable. FDE US, LLC is the primary data controller responsible for this Privacy Notice, unless another FDE group company is identified as the controller for a specific relationship, service, jurisdiction or processing activity.

This Privacy Notice sets out the basis on which FDE collects, stores, uses and discloses personal data we receive in writing, through our Websites, through our AI consultancy, workforce transformation, talent development, training and deployment services, or through other interactions with our stakeholders, customers, learners, program participants, consultants, contractors, deployed personnel, suppliers and business contacts. It therefore applies to personal data that you provide to FDE telephonically, electronically (including email) and in person.

This information may be updated from time to time, and should be read in the context of any additional specific information such as that provided in privacy policies applicable to specific businesses or local areas as displayed on the relevant Website or distributed to you from time to time.

This Privacy Notice also informs you how we obtain and use information gained by us through your use of the Websites, including by using “cookies” and third party vendors.

Please read the following carefully to understand our views and practices regarding your personal data, how we will treat it and your rights.

This Privacy Notice applies to FDE globally. The first part of the Privacy Notice is general and applies globally. The second part of the Privacy Notice is comprised of country-specific addendums, and where applicable, FDE will handle Personal Data relying on certain exemptions under local law. Please be sure to check the addendums below to see if there is one that applies to your country or local jurisdiction. In the event of a conflict between the general part of this Privacy Notice and an addendum, the addendum prevails.

II. Who are we?

FDE is an AI talent, training, and transformation consultancy firm that helps businesses understand, adopt and implement artificial intelligence. We work with organizations to identify practical opportunities for AI, develop tailored strategies, deliver AI consulting and transformation services, and build the capabilities needed to use AI effectively and responsibly. FDE also provides talent creation, reskilling and training services, including programs designed to help individuals and customer teams develop practical AI, technology and career-related skills. FDEco, LLC, a Delaware limited liability company; FDE UNIco, LLC, a Delaware limited liability company; and FDE UKco Limited. If you want to contact FDE or any of its group companies, please complete the form located here.

You can contact FDE about this Privacy Notice or about how we handle Personal Data by emailing privacy@fdeco.com or by sending written correspondence to the relevant FDE entity at the addresses below.

FDE US, LLC; FDEco, LLC; and FDE UNIco, LLC

301 Commerce Street, Suite 3300
Fort Worth, TX 76102
United States

FDE UKco Limited

Duo Level 6, 280 Bishopsgate

London

United Kingdom

EC2M 4RB

Email: privacy@fdeco.com

III. Who does this Privacy Notice protect?

This Privacy Notice protects individuals throughout the world who access our Websites, receive services from us, interact with FDE as a customer, learner, program participant, consultant, contractor, deployed personnel, supplier, business contact or stakeholder, or otherwise provide Personal Data to FDE. An FDE “client” or “customer” means an organization that has contracted with FDE, is in the process of doing so, or with whom FDE may interact in connection with its business, including in relation to AI consultancy, workforce transformation, talent development, training and deployment services. FDE US, LLC acts as the primary data controller for Personal Data covered by this Privacy Notice unless another FDE group company is identified as the controller for a specific relationship, service, jurisdiction or processing activity.

IV. What information will we collect?

Some of the data that we collect and receive from you is personal data which means that it is information that could personally identify you (“Personal Data” or “PII”). The Personal Data that we may collect from all users of our Websites and users of our AI consultancy, workforce transformation, talent development, training and deployment services may include any of the following:

Your name;
Your gender;
Your voice when recording or transcribing phone or web calls;
Contact details e.g. street address, email address, cell (or mobile) or home telephone numbers;
Work Experience;
Job Title;
Professional Certifications;
Education & Qualifications;
Skills;
Career History;
Salary Range;
Right to work status \ citizenship;

Other information relevant to help us assess, onboard, train, support, deploy or provide related services;
References from past employers; and
IP address
Training, assessment and program information, including course enrollment details, attendance, progress, assessment results, certifications, feedback, learning preferences and records of participation in FDE training or talent creation programs.

For Consultants, Contractors and Deployed Personnel (individuals who are engaged, trained, assessed, supplied, deployed, made available or otherwise involved in supporting FDE customer projects, consultancy engagements, training programs or service delivery)

In addition to the Personal Data listed above, FDE may collect the following from you where relevant to onboarding, training, deployment, contractual fulfilment, eligibility checks, customer requirements, payment administration or service delivery:

Tax details and proof of payment and submission;
Commercial insurance information; and
Bank and payment details.

While this information may relate to your company or your employer rather than being your Personal Data, we have listed this information for transparency.

If your provision of Personal Data to FDE is necessary to enter into a contract with your company or your employer, your failure to provide us with accurate Personal Data may result in FDE not being able to offer or provide services to you, your company or your employer.

V. Why do we process your Personal Data?

Generally, we use your Personal Data for our business and activities, and in our efforts to expand and improve our business. Examples include:

A. All users of the Websites and/or our services

To provide our AI consultancy, workforce transformation, talent development, training and deployment services to you, your employer, your company or the relevant customer;

To assess individuals for programs, consultancy engagements or deployment opportunities, deliver training, match skills and experience to customer project requirements, manage onboarding and deployment, administer performance, support customer reporting, and fulfil contractual or service delivery requirements;
Where permitted by applicable law and unless you tell us otherwise, we (or a third party to whom we have provided your Personal Data under part VI below of this Privacy Notice) may send you emails, SMS messages, text messages (standard SMS or text message rates may apply), or we may make or receive phone or web calls to/from you;
To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;
To improve our customer service and to make our services more valuable to you (including tailoring the Websites when you log on to enrich your personal online experience);
To send you electronically or by mail surveys, reports, FDE event details, promotions, offers, networking and client events, training program information, course updates, learning opportunities and general information about relevant industry sectors which we think might be of interest to you, where you have consented to being contacted for such purposes (and we will provide you with an opportunity to opt out);
To identify you, and respond to and process your requests for information and provide you with a product or service;
To amend records to remove personal information;
To use your information on a pseudonymized basis to monitor compliance with our equal opportunities policy, other FDE policies and any legal or compliance requirements;
To use your information on a pseudonymized basis to create marketing materials such as a salary survey; and
To carry out our obligations arising from any contracts entered into between you and us, and for other everyday business purposes that involve use of Personal Data.

B. Business Contacts, Learners, Participants, Consultants, Contractors and Program Applicants

To collect any money due, or allegedly due, to FDE or any FDE client (or FDE’s client’s client);
To obtain or inquire about any property (including computers and confidential business information) owned, or allegedly owned, by FDE or any FDE client (or FDE’s client’s client);
To establish, exercise or defend any legal claims; and

C. Learners, Participants and Program Applicants

To assess your suitability for, enrol you in, administer and deliver FDE programs, training or related learning services;
To provide learning materials, program communications, assessments, feedback, mentoring, support and certification-related administration;
To monitor attendance, engagement, progress and completion of training activities and to report relevant program outcomes to you, your employer, your company or the relevant customer where appropriate; and
To help you build or improve AI, technology and career-related skills and, where relevant, connect training outcomes with customer workforce planning, consultancy or transformation requirements.

D. Individuals who work for FDE clients (i.e. a “client contact”)

To negotiate and fulfil any aspect of your company’s or employer’s contract with FDE;
To resolve any issue with the issuance, payment, collection or enforcement of an FDE invoice;
To establish, exercise or defend any legal claims.

E. Individuals who participate in awards’ competitions

a) To provide our awards’ competition services to you;

b) To facilitate the awards’ competition process, including but not limited to:

- Publishing contest rules;
- Collecting, qualifying and submitting participants, contest applications, judges, and winners;
- Facilitating the acceptance, rejection, or delivery of contest awards;
- Providing post award follow up.

VI. Who do we send your Personal Data to?

A. All users of the Websites and/or our services

To third parties where we have retained them to provide services that we or you have requested or that FDE clients have requested including references, qualifications and background reference checking services and to verify the details you have provided from third party sources.
To third parties to provide data storage, CV/resume parsing, data cleansing and marketing services to FDE where such third parties have agreed to maintain the confidentiality of, and to protect, your Personal Data in accordance with applicable law.
To third party service providers when you are making, transcribing, or receiving calls to/from us.
To third parties to assist with credit control and payment management
To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, in connection with legal proceedings or other similar cause or circumstance.

To FDE affiliates, whose locations can be found at https://www.fdeco.com/contact . These entities will process your Personal Data in accordance with this Privacy Notice.

In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets, or a controlling interest in the equity, of FDE (or any of its group companies) provided that such counterparty(ies) to any such transaction agrees to adhere to the terms of this Privacy Notice (or a similar document) and applicable law.

B. Participants, Learners, Program Applicants, Consultants, Contractors, Deployed Personnel and Business Contacts

To third parties that you authorize us to send your personal data to such as “umbrella” companies, insurance brokers and insurance carriers;

To FDE clients, customers, training providers, certification bodies, assessment providers, learning platform providers, instructors, mentors or employers where this is necessary to assess suitability for, administer, deliver, support or report on programs, consultancy engagements, deployments, customer projects or related services.

VII. What will FDE do if my Personal Data is breached?

FDE has put in place reasonable technical, administrative and physical safeguards intended to prevent a breach of your Personal Data. That being said, FDE cannot guarantee that your Personal Data will not be breached.

A breach can take many forms, including, without limitation, the loss of your Personal Data or the unauthorized access to, disclosure, modification, copying and transfer of your Personal Data.

Once FDE becomes aware of the breach, FDE will take reasonable steps to isolate the breach, stop the breach, determine the root cause, determine the Personal Data breached, fix the root cause and determine if notice to you and/or the appropriate government agency(ies) is required. FDE will comply with all applicable law in reacting to, and dealing with, a breach of Personal Data.

If you believe, for any reason, that your Personal Data has been breached while in FDE’s care, custody or control, please email FDE immediately at privacy@fdeco.com.

If FDE obtains your Personal Data from someone other than you, this Privacy Notice includes all information required under applicable law except that FDE shall not provide you with this information if you already possess this information, providing you with such information is against (or not mandatory under) applicable law, is subject to an obligation of professional secrecy, proves impossible, would involve a disproportionate effort or would render impossible or seriously impair the achievement of the objectives of the processing, in which case, FDE shall take appropriate measures to protect your rights, freedoms and legitimate interests. If you have any questions, please contact FDE at privacy@fdeco.com.

VIII. Will my Personal Data be transferred to another country?

Yes, FDE may transfer your Personal Data to the categories of third parties described in this Privacy Notice, including FDE group companies and service providers such as FDE where FDE processes Personal Data on FDE’s behalf, some of whom are located outside of the country in which you provided your Personal Data to FDE or the country of collection.

If so, FDE will take reasonable steps to ensure that your Personal Data is protected and treated in accordance with this Privacy Notice and local applicable law. The countries where FDE may transfer your Personal Data will have varying levels of data security practices and laws, some of which may be less stringent or protective than your country. FDE will use all reasonable efforts to require that any of its suppliers and vendors who receive your Personal Data are contractually bound to (a) keep your Personal Data confidential and (b) take, at a minimum, reasonable efforts to maintain the privacy and security of your Personal Data.

Under certain circumstances, FDE may share your Personal Data with one or more of its group companies who may be located in a country other than yours or other than the country in which FDE collected your Personal Data. In such cases, FDE will comply with applicable laws and its Intercompany Data Processing Agreements (“DPAs”). The DPAs are incorporated by reference into this Privacy Notice.

IX. How long will FDE store my Personal Data for?

We are required by applicable law to store your Personal Data for as long as is necessary to comply with our legal, regulatory and contractual obligations. This period of time will vary based on the law in your country and in the country where FDE stores your Personal Data.

In addition, FDE will keep your Personal Data for the identified purposes until it reasonably believes that it no longer needs it, that there is no reasonable chance that you, your employer or your company will do business with FDE, and there is no reason to believe that we will need the Personal Data for any special circumstances such as the issuance or defense of legal proceedings, audit, investigation or collections.

X. Sending FDE Personal Data over the internet

Your Personal Data is held on servers hosted by FDE, by service providers acting on FDE’s behalf, including FDE where applicable, or by third party vendors with whom FDE has a contract. The transmission of information via the internet is not completely secure. Although we will take the efforts set forth in this Privacy Notice to protect your Personal Data, we cannot guarantee the security of any data transmitted through or to our Websites. Any transmission of data by you to us over the internet is at your own risk.

XI. How we collect and aggregate information about visitors to our Websites

We also collect information about the way visitors use the Websites in order to improve our services, to understand our users better, and to determine aggregate trends, most popular pages, etc. By using the Websites, you agree that we may share de-identified aggregate data with selected third parties to assist with these purposes. We may also undertake marketing profiling to help us identify services, programs or content which may be of interest to you. We may process Personal Data that you submit to us through the Websites under one or more of the permissible bases for processing Personal Data set forth in the Privacy Notice.

XII. Technology and Tools

Like many companies, we use technology and tools that tell us when a computer or device has visited or accessed our content. Those tools include services from search engines and other companies that help us to tailor our products and services to better suit our customers and potential customers. Search engines provide facilities to allow you to indicate your preferences in relation to the use of those tools in connection with computers and other devices controlled or used by you.

We also set out further information below about Cookies and Web Beacons.

A. What are cookies?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies. Cookies are used by many websites, including FDE’s Websites.

B. How do we use cookies and plug-ins?

We use “cookies” and plug-ins to: (1) make the Websites function properly and as a user would normally expect of a commercial website, (2) monitor Website user traffic patterns and Website usage; and (3) help us to advertise services, programs, events or content we think you, your company or your employer will be interested in. Our use of these tools helps us to understand how our users use our Websites so that we can develop and improve the design, layout and functionality of the Websites and to provide more efficient and relevant services to you.

C. There are different kinds of cookies with different functions.

The cookies we use are explained below:

Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
Strictly necessary cookies: these cookies are essential to enable you to use the Websites effectively and therefore cannot be turned off. Without these cookies, the services available to you on our Websites cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: these cookies enable us to monitor and improve the performance of our Websites. For example they allow us to count visits, identify traffic sources and see which parts of the Websites are most popular. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our Websites work. Personalization cookies: the FDE Websites use personalization cookies to help us advertise services, programs, events or content that we think may be of interest to you. These cookies are persistent and mean that when you log in, or return to, the particular FDE Website, you may see advertising for services, programs, events or content that are similar to services, programs, events or content that you have previously browsed.
Personalization cookies: the FDE Websites use personalization cookies to help us to advertise services, programs, events or content that we think may be of interest to you. These cookies are persistent and mean that when you log in, or return to, the particular FDE Website, you may see advertising for services, programs, events or content that are similar to services, programs, events or content that you have previously browsed.
Targeting cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

For information on how to reject these cookies, see Section E below.

D. Cookies and Plug-ins set by FDE or Third Parties used by FDE

In addition to our various branded Privacy Preference Centers (see the blue shield in the bottom left-hand corner of your screen), below is a table of the cookies that you may encounter on our Websites and the purpose for which we use each one and the duration that the cookie remains in place (unless you take action to reject the cookie). FDE may update this table and its Privacy Preference Centers from time to time. Most of the cookies on our Websites are set by third parties. FDE works with several third parties to provide services which help us to keep the Websites tailored to your needs. Some of these vendors use cookies to help them deliver these services.

Host	Cookie	Description	Type ⇅	Duration
fdeco.com	_ga_xxxxxxxxxx	Used by Google Analytics to identify and track an individual session with your device.	Performance Cookies	729 Days
linkedin.com	lidc	This domain is owned by LinkedIn, the business networking platform. It typically acts as a third party host where website owners have placed one of its content sharing buttons in their pages, although its content and services can be embedded in other ways. Although such buttons add functionality to the website they are on, cookies are set regardless of whether or not the visitor has an active Linkedin profile, or agreed to their terms and conditions. For this reason it is classified as a primarily tracking/targeting domain.	Functional Cookies	1 Days
linkedin.com	bcookie	This domain is owned by LinkedIn, the business networking platform. It typically acts as a third party host where website owners have placed one of its content sharing buttons in their pages, although its content and services can be embedded in other ways. Although such buttons add functionality to the website they are on, cookies are set regardless of whether or not the visitor has an active Linkedin profile, or agreed to their terms and conditions. For this reason it is classified as a primarily tracking/targeting domain.	Functional Cookies	731 Days
fdeco.com	_ga_xxxxxxxxxx	Used by Google Analytics to identify and track an individual session with your device.	Performance Cookies	729 Days
linkedin.com	lidc	This is a Microsoft MSN 1st party cookie that ensures the proper functioning of this website.	Functional Cookies	1 Day
linkedin.com	li_gc	Used to store guest consent to the use of cookies for non-essential purposes.	Strictly Necessary	5 months 4 weeks
hs-scripts.com	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
hsadspixel.net	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
hs-banner.com	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
hsforms.com	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
hubspot.com	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
hs-analytics.net	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
linkedin.com	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
hsforms.net	__cf_bm	Used to distinguish between humans and bots. This is beneficial for the website in order to make valid reports on the use of their website.	Strictly Necessary	~30 Minutes
fdeco.com	__hssc	This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics.	Performance Cookies	~30 Minutes
fdeco.com	__hssrc	This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics.	Performance Cookies	Session
fdeco.com	__hstc	This cookie name is associated with websites built on the HubSpot platform. It is reported by them as being used for website analytics.	Performance Cookies	5 months 4 weeks
fdeco.com	_ga_K7TKDNS2N1	This cookie is used by Google Analytics to persist session state.	Performance Cookies	1 year 1 month
fdeco.com	_ga	This cookie name is associated with Google Analytics and is used to distinguish unique users by assigning a randomly generated client identifier. It is included in each page request and used to calculate visitor, session and campaign data for analytics reporting.	Performance Cookies	1 year 1 month
fdeco.com	hubspotutk	This cookie name is associated with websites built on the HubSpot platform. HubSpot reports that its purpose is user authentication. As a persistent rather than a session cookie, it cannot be classified as Strictly Necessary.	Functional Cookies	5 months 4 weeks

E. How to reject cookies

If you don’t wish to receive cookies that are not strictly necessary to perform basic features of our Websites, you may choose to opt out of them by selecting the blue shield in the bottom left-hand corner of any of the Websites, called “Privacy Preference Center”.

Note that most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept or reject some or all cookies in your browser’s privacy settings. Rejecting all cookies means that certain features of the Website(s) cannot then be provided to you and accordingly you may not be able to take full advantage of all our Websites’ features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

For more information generally on cookies, including how to disable them or change cookies’ settings, please refer to aboutcookies.org (http://www.allaboutcookies.org/). You will also find details on how to delete cookies from your computer. Find out how to manage cookies on popular browsers:

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

F. Web Beacons

FDE may use or include web beacons in emails or other electronic communications that FDE sends to you. We use web beacons to help us analyze the effectiveness of our communications to you. For example, we may use web beacons to understand when and if you opened our email, how many times you opened the email, if you have forwarded the email to another email address, or if you clicked on a link in an email that we sent to you. The web beacons do not collect or give us your PII but they do provide information to us about your actions after receiving a communication from us. If you would like to stop receiving emails with web beacons from us, you may unsubscribe by clicking the “Unsubscribe” link in the email. However, you may receive auto generated emails from FDE after you create an account on the Websites or take some other affirmative action on the Websites which contain web beacons but do not contain an “Unsubscribe” link. In those cases, just simply email privacy@fdeco.com if you would like to stop receiving emails from FDE with web beacons.

Also, FDE works with third parties to help manage online advertising who embed web beacons in online job postings and job advertisements that FDE requests these third parties to post online. One such third party that we use is Broadbean. These web beacons allow Broadbean to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by a third party that Broadbean uses such as Google Analytics. These files enable Google Analytics to recognize a unique cookie on your web browser, which in turn enables Broadbean to learn which advertisements bring users to our Websites or websites on which Broadbean placed our advertisements. The cookie on your web browser was placed by Broadbean, or by another advertiser who works with Google Analytics. With both cookies and web beacon technology, the information that Google Analytics (either directly, see cookie/plug-in chart above) or Broadbean collects and shares with us is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. For more information about Google Analytics, including information about how to opt out of these technologies, go to www.google-analytics.com. For more information about web beacons and cookies placed by Broadbean, please click https://www.broadbean.com/uk/privacy-policy/.

XIII. Links to other websites

Please note that clicking on links and banner advertisements and RSS (Rich Site Summary) feeds may result in your transfer to another website, where data privacy practices may be different than described in this Privacy Notice. It is your responsibility to check other website privacy notices and policies to ensure that you are happy for your personal information, including Personal Data, to be used in accordance with those third parties’ privacy notices and policies. We accept no responsibility for, and have no control over, third party websites, links, adverts or RSS feeds or information that is submitted to or collected by third parties.

XIV. Changes to our Privacy Notice

We reserve the right to change this Privacy Notice from time to time by updating this Privacy Notice on our website. Any changes to this Privacy Notice or any of its addendums will be posted on this Website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We encourage you to check this Website frequently for updates. Your continued use of this Website or any FDE services shall constitute your acceptance of the revised Privacy Notice.

FDE will interpret and enforce this Privacy Notice in accordance with all applicable law.

The effective date of this Privacy Notice is September 17, 2026. This Privacy Notice was updated on September 17, 2026, September 18, 2026 and September 23, 2026.

This Privacy Notice was last updated on October 05, 2026.

United Kingdom Addendum

I. Who is FDE’s Supervisory Authority for Data Protection Purposes?

FDE has designated the UK Information Commissioner’s Office (“ICO”) as the supervisory authority for purposes of Data Protection Act of 2018 (“DPA 2018”) and UK General Data Protection Regulation (“UK GDPR”).This addendum applies to the United Kingdom only.

II. How do we lawfully process your data?

In order to process your Personal Data lawfully FDE must have a legal basis to do so. FDE relies on three main legal basis for processing your Personal Data:

where we obtain your affirmative consent to use your Personal Data in this way;
where we have a legitimate interest in processing your Personal Data, which we have balanced against your rights and freedoms and concluded that our processing is justifiable; or

where our handling of your Personal Data is necessary for us to perform the obligations under your company’s or employer’s contract with FDE.

We may rely on one or more legal bases to process your Personal Data.

A. All users of the Websites and/or our services

Legitimate Interests: FDE uses Personal Data that we collect for the following general purposes in the performance of our legitimate interests as a business: to provide services to learners, program participants, consultants, contractors, deployed personnel, clients and customers; to enhance their experience; to improve our services; and to contact individuals and organizations in connection with FDE programs, consultancy engagements, deployments, customer projects and related services.

B. Actual or Prospective Learners, Program Participants, Consultants, Contractors and Deployed Personnel

Consent: If you, whether on your own behalf, or on behalf of your company or your employer, would like to receive general marketing and other communications from us, you will have the option to affirmatively check a box consenting to FDE processing your Personal Data for this purpose. FDE may also ask you via email, text message or SMS (standard SMS or text message rates may apply), or telephone for your affirmative consent to receive marketing and other communications from us.

Legitimate interest: FDE has a legitimate interest in processing your Personal Data in order to provide services, to provide you, your company or your employer with other products and services to help you in your career and to market its products and services to you in order to grow our business, to demonstrate our knowledge of the marketplace and relevant technologies and to enhance the standing and recognition of our brands. FDE also has legitimate interest to process your Personal Data if you apply for, or seek further information about, a program, consultancy engagement, deployment, customer project or related service offered by FDE through the Websites, social media sites, events or other channels.

Necessary for the performance of a contract: FDE can process your Personal Data in the performance of its contract with your company or employer.

C. Individuals who work for FDE clients (i.e. a client contact)

Consent: If you would like to receive general marketing and other communications from us, you will have the option to affirmatively check a box consenting to FDE processing your Personal Data for this purpose. FDE may also ask you via email, text message or SMS (standard SMS or text message rates may apply), or telephone for your affirmative consent to receive marketing and other communications from us.

Legitimate Interest: FDE has a legitimate interest in processing your Personal Data in order to understand your company’s or employer’s requirements for FDE services, and provide you with other products and services relevant to your company or employer and to market its products and services to you in order to grow our business, to demonstrate our knowledge of the marketplace and relevant technologies and to enhance the standing and recognition of our brands. FDE also has legitimate interest to process your Personal Data if you seek or obtain further information about FDE or FDE programs, consultancy engagements, deployments, customer projects or related services.

Necessary for the performance of a contract: FDE can process your Personal Data in the performance of its contract with your company or employer.

With respect to actual or prospective client contacts, learners, program participants, consultants, contractors and deployed personnel, if FDE obtains your Personal Data from someone other than you, FDE shall inform you of the identity and contact details of the person or entity from whom FDE obtained your Personal Data, whether FDE obtained your Personal Data from publicly available sources, the categories of Personal Data that FDE obtained and, if FDE is processing your Personal Data based on its legitimate interest (see Section III below), the nature of FDE’s legitimate interest. FDE shall provide you with the information listed in this paragraph by the earlier of (1) the applicable period required by law after FDE obtains your Personal Data or (2) if FDE uses your Personal Data to communicate with you, the first time that FDE communicates with you.

FDE shall not provide you with the information described in the paragraph immediately above if you already possess this information, providing you with such information is against applicable law, is subject to an obligation of professional secrecy, proves impossible, would involve a disproportionate effort or would render impossible or seriously impair the achievement of the objectives of the processing, in which case, FDE shall take appropriate measures to protect your rights, freedoms and legitimate interests.

III. Your Special Rights under Data Protection Laws

A. Do I have a right to be erased (forgotten)?

Yes. You have the right to request that FDE deletes or removes your Personal Data where there is no compelling reason for us to continue to process it. You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com.

Please note that your right to erasure is not absolute. FDE will remove your Personal Data when:

the Personal Data is no longer necessary in relation to the purpose for which FDE originally collected and/or processed it;
if FDE is processing your Personal Data on the basis of your consent and you withdraw consent;
you object to the processing of your Personal Data and there is no overriding legitimate interest for us to continue to process it;
the Personal Data was unlawfully processed; and
the Personal Data must be erased to comply with a legal obligation.

FDE can refuse to comply with an erasure request in the following limited circumstances:

(a) to exercise FDE’s right of freedom of expression and information;

(b) to comply with a legal obligation or for the performance of a public interest task;

(d) for the establishment, exercise or defence of legal claims.

If we remove your Personal Data per your request for erasure, then we will confirm this with you.

If we have disclosed any of your Personal Data to a third party and you submit an erasure request to us, then we will inform (1) you about the recipients and (2) any such third parties of your erasure request unless doing so is impossible or involves disproportionate efforts.

We will respond to your erasure request without undue delay. Please note that, for your and FDE’s protection, we cannot respond to an erasure request until we have verified the identity of the person making the request. This verification process may extend the response timeframes set forth in this paragraph.

B. Do I have a right of access to a copy of my Personal Data?

Yes. You have the right to:

obtain confirmation that your Personal Data is being processed;
a copy of your Personal Data being processed;
the purposes of the processing;
the categories of personal data being processed;
the recipients or categories of recipients to whom FDE has disclosed your Personal Data; and
the criteria FDE uses to determine how long it will store your Personal Data.

You can exercise this right by sending an email to FDE at privacy@fdeco.com.

This right is in place to ensure that you are aware of and can verify the lawfulness of the processing. In most cases, we will provide you with a copy of your Personal Data free of charge. However, we may charge you a reasonable fee if your request is manifestly unfounded, excessive or repetitive. With respect to unfounded, excessive or repetitive requests, in rare cases, FDE may refuse to respond to your request but will explain the reason(s) for its refusal to you without undue delay and within one month of its receipt of your request. If FDE so refuses, you have the right to file a complaint with the ICO and to seek a judicial remedy.

If you submit your access request to FDE electronically, FDE will provide you with its response, and a copy of your Personal Data (if applicable) via email or other commonly used electronic form.

If FDE did not collect your Personal Data from you, FDE will inform you about the source from which it obtained your Personal Data. Your right of access does not adversely affect your right of erasure (forgotten) and right of rectification, both of which are described in this Privacy Notice.

Generally, FDE will provide you with a copy of your Personal Data without undue delay and within one month of its receipt of your request, provided that FDE may extend this time period for up to two additional months if your request is complex or numerous. If FDE exercises this extension of time, FDE will inform you of its decision to exercise the extension within one month of its receipt of your request, and will explain the reason(s) for the extension. If your request is large or complex, FDE may ask you to specify the particular information or category of information you seek.

Please note that, for your and FDE’s protection, FDE cannot respond to an access request until it verifies the identity of the person making the request for your Personal Data. This verification process may extend the response timeframes set forth in the paragraph above.

C. Do I have a right to object to the processing of my Personal Data, including the processing of my Personal Data by FDE for direct marketing?

Yes, you have a right to object to the processing of your Personal Data where:

FDE’s processing is based on its legitimate interest; or
where FDE is using your Personal Data to directly market to you.

You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com.

If FDE receives an objection request from you for reasons unrelated to direct marketing, FDE will stop processing your Personal Data unless we can show compelling legitimate ground(s) for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of any legal claims.

If FDE receives an objection request from you for reasons related to direct marketing, we will stop processing your Personal Data.

If you receive a direct marketing communication from FDE and you do not wish to receive future direct marketing communications from FDE, you may request to unsubscribe from future marketing communications by sending FDE an email at privacy@fdeco.com In addition, if the direct marketing communication you received was via email, you can click the “Unsubscribe” link at the bottom of the email, fill out the required form and FDE will process your unsubscribe request. Please allow up to ten (10) business days for your unsubscribe request to take effect.

D. Do I have a right to restrict the processing of my Personal Data?

Yes, you have a right to restrict, the processing of your Personal Data. You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com. When you exercise this right, FDE may continue to store your Personal Data but cannot further process it. FDE will cease processing your Personal Data in the following circumstances:

when you file a rectification request with FDE (see the “Do I have a right to have any inaccurate or incomplete Personal Data rectified?” section below) in accordance with this Privacy Notice and applicable law. The restriction shall remain in place until such time as FDE has verified the accuracy of the Personal Data that is the subject of your rectification request;
where FDE is processing your Personal Data based on its legitimate interest and you file a notice with FDE objecting to the processing of your Personal Data (see the “Do I have a right to object to the processing of my Personal Data?” section above) in accordance with this Privacy Notice and applicable law, FDE will cease processing your Personal Data until such time as FDE has made a determination as to whether its legitimate grounds for continued processing override your reasons for objecting to the processing;
when the processing is unlawful and you do not seek or want erasure and you file a restriction request with FDE in accordance with this Privacy Notice and applicable law instead; and
if FDE no longer needs the Personal Data and you require the data to establish, exercise or defend a legal claim.

While the processing of your Personal Data is restricted, FDE may continue to process such data by storing it, processing it with your consent or processing it for the establishment, exercise or defence of legal claims.

FDE will inform you if it decides to lift a restriction on processing.

If FDE has disclosed any of your Personal Data to a third party and you submit a request to restrict processing, FDE will inform (1) you about the recipients if you so request and (2) any such third parties of your restriction request unless doing so is impossible or involves disproportionate efforts.

FDE will act on your restriction request in accordance with this Privacy Notice without undue delay. Please note that, for your and FDE’s protection, FDE cannot act on a restriction request until it verifies the identity of the person making the request. This verification process may extend the timeframe in which FDE acts on your restriction request.

E. Do I have a right to Personal Data portability?

Yes. You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com. This right exists to allow you to obtain and use your Personal Data for your own purposes across different services. Under this right, you can move, copy or transfer your Personal Data from FDE to another data controller.

This right applies where FDE is processing your Personal Data with your consent or for the performance of a contract. It also applies if we process your Personal Data by automated means. If your portability request concerns someone other than you, FDE will have to consider whether providing or porting the Personal Data would prejudice the other person’s or people’s rights.

Generally, FDE will respond to your portability request without undue delay and within one month of its receipt of your request, provided that FDE may extend this time period for up to two additional months if your request is complex or numerous. If FDE exercises this extension of time, FDE will inform you of its decision to exercise the extension within one month of its receipt of your request, and will explain the reason(s) for the extension. Where technically feasible, you may request that FDE transmit your Personal Data to another data controller.

F. Do I have a right to object to decision been taken by automated means?

If FDE uses automated (i.e. non-human) methods to process your Personal Data to make decisions that could potentially have a damaging legal or similarly significant effect on you (each, an “Automated Decision”), you have the right not to be subject to the Automated Decision. This right is inapplicable to any Automated Decision made by FDE that is necessary for entering into or the performance of a contract between you and FDE, is authorized by law or is based on your explicit consent.

If FDE makes any Automated Decisions to which this right applies, FDE will ensure that you are able to obtain human intervention, express your point of view and obtain an explanation of the decision and challenge it.

If FDE engages in “profiling” by automated means, FDE will ensure that appropriate safeguards are in place including (1) ensuring that the processing is fair and transparent by providing you with meaningful information about the logic involved and the significance and consequences of the outcome of the decision, (2) using appropriate mathematical or statistical procedures for the profiling, (3) implementing appropriate technical and organizational measures to enable inaccuracies to be corrected and minimize the risk of errors and (4) securing the Personal Data in a way that is proportionate to the risk to your interests and rights and prevents discriminatory effects.

G. Do I have a right to have any inaccurate or incomplete Personal Data rectified?

Yes. You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com.

Generally, FDE will respond to your rectification request within one month of its receipt of your request, provided that FDE may extend this time period for up to two additional months if your request is complex. In rare cases, FDE may refuse to respond to your request but will explain the reason(s) for its refusal to you within one month of its receipt of your request. If FDE so refuses, you have the right to file a complaint with the ICO and to seek a judicial remedy.

If FDE has disclosed any of your Personal Data to a third party and you submit a rectification request to FDE that FDE is going to honor, FDE will inform (1) you about the recipients and (2) any such third parties of your rectification request as well as any corrected Personal Data, unless doing so is impossible or involves disproportionate efforts.

We will use reasonable endeavours to ensure that your Personal Data is maintained and up to date.

H. What are my rights if the Security of my Personal Data is breached?

A breach of Personal Data (a “Breach”) means a breach of security leading to the destruction, loss, alteration, unauthorized disclosure of, or access to, your Personal Data for which we are responsible under applicable law.

If the Breach is likely to have a significant detrimental effect on your rights and freedoms (such as resulting in discrimination, damage to reputation or financial loss), FDE will notify the ICO without undue delay, and if feasible, within one business day of FDE becoming aware of the Breach. FDE will assess the determination of “significant detrimental effect” on a case by case basis.

If the Breach is likely to result in a “high risk” to your rights and freedoms, FDE will notify you without undue delay. To be clear, the threshold requiring FDE to notify you of a Breach is higher than the threshold requiring FDE to notify the ICO of a Breach so it is possible that FDE will notify the ICO of a Breach but not you. FDE will assess the determination of “high risk” on a case by case basis.

Any Breach notice issued by FDE will contain, where possible, (1) the categories and approximate number of individuals and Personal Data records effected by the Breach, (2) the name and contact details of the Information System Manager (“ISM”) (or other FDE contact representative if FDE does not have a ISM at the time that FDE issues the Breach notice), (3) a description of the likely consequences of the Breach, (4) a description of the measures that FDE has taken, and may take, to stop the Breach and, where appropriate, to mitigate the adverse effects of the Breach and (5) recommendations on actions you can take to protect yourself in light of the Breach.

I. Will my Personal Data be transferred outside the UK?

FDE may transfer your Personal Data to third parties described in this Privacy Notice who are located outside of the UK. If so, FDE will take reasonable steps to ensure that your Personal Data is protected and treated in accordance with this Privacy Notice and local applicable law. Some of the countries outside the UK where your Personal Data may be transferred will be on the ICO’s list of countries that it has deemed to have adequate security controls in place (the “Approved List”). Given the European Court of Justice’s decision in Data Protection Commissioner v. Facebook Ireland and Maximilian Schrems, Case C-311/18 (July 16, 2020) (“Schrems II”) , and absent consent from the Data Subject (or any other reason provided in UK GDPR Article 49(1)(b)-(f) as may be amended from time to time), if FDE transfers your Personal Data to processors (which could be external third party vendors or suppliers) that store, transfer, process, or control your Personal Data in a country not on the Approved List or not in the UK (“Third Countries”), then FDE shall determine whether each processor (and each subprocessor that a processor has provided FDE formal notice of) can store, transfer, process, or control the Personal Data solely within the UK, or a country on the Approved List.

(a) If FDE determines that the processor (and each subprocessor that a processor has provided FDE formal notice of) can store, transfer, process, or control the Personal Data solely within a country on the Approved List or in the UK, we will require such processor (and will require the processor to require each of its applicable subprocessors) to do so.

(b) If FDE determines that the processor (and each subprocessor that a processor has provided FDE formal notice of) cannot store, transfer, process, or control the Personal Data in a country on the Approved List or in the UK, then:

(i) FDE will require such processor (and will require the processor to require each of its applicable subprocessors) to be bound by the model clauses promulgated by the ICO under S119A(1) Data Protection Act 2018, including but not limited to the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses VERSION B1.0, as in force 21 March 2022, any successor versions thereto, and any other valid transfer mechanism promulgated by the ICO (collectively for this Addendum, “Model Clauses”). When relying on the Model Clauses, FDE shall (a) monitor the laws and regulations of Third Countries for the adequate protections of UK. Data Subjects as required by the UK GDPR or other local laws and regulations; and (b) terminate the storage, transfer, processing , or control of Personal Data by a processor (or a subprocessor where the process has informed FDE of the country in which such subprocessor is processing your Personal Data) when (i) such laws and regulations of Third Countries are incompatible with the UK GDPR or other local laws and regulations, or (ii) access to Personal Data is requested by the public authorities of Third Countries and such access is lawful under the laws of the Third Countries but is prohibited under the UK GDPR or other local laws and regulations. If the events described in III(I)(b)(i)(b)(i) or (ii) occur, FDE will confer with the appropriate supervisory authority regarding appropriate actions to safeguard your Personal Data.

(c) FDE shall also require the processor (and will require each processor to require its applicable subprocessors) to determine whether each processor or subprocessor can store, transfer, process, or control the Personal Data solely within the UK, or a country on the Approved List.

If processor (or its applicable subprocessors) can store, transfer, process, or control the Personal Data solely within the UK, or a country on the Approved List, then FDE shall contractually require the processors (and require processor to require its subprocessors to) do so.
If processor (or its applicable subprocessors) must store, transfer, process, or control the Personal Data in a Third Country, then FDE shall require its processors (and require processor to require its subprocessors to) to be bound by the Model Clauses. When relying on the Model Clauses, FDE shall contractually require such processors (and shall also require processors to require their subprocessors) to agree to (a) monitor the laws and regulations of Third Countries for the adequate protections of UK Data Subjects as required by the UK GDPR or other local laws and regulations; and (b) terminate the transfer, processing, or control of Personal Data when (i) such laws and regulations of Third Countries are incompatible with the UK GDPR or other local laws and regulations, or (ii) access to Personal Data is requested by the public authorities of Third Countries and such access is lawful under the laws of the Third Countries but is prohibited under the UK GDPR or other local laws and regulations. If the events described in III(I)(c)(2)(b)(i) or (ii) occur with respect to your Personal Data (and if FDE has formal notice that the events described in III(I)(c)(2)(b)(i) or (ii) have occurred), FDE will confer with the appropriate supervisory authority regarding appropriate actions to safeguard your Personal Data.

Under certain circumstances, FDE may share your Personal Data with one or more of its group companies who may be located in a Third Country. In such cases, FDE will comply with its DPAs. The DPAs are incorporated by reference into this Addendum.

J. How long will FDE store my Personal Data for?

We are required by law to store your Personal Data for as long as is necessary to comply with our legal, regulatory and contractual obligations.

With respect to UK GDPR (and similar laws), we will store and process your Personal Data that we obtain via: (i) your consent, until the earlier of (a) the purpose for which we obtained such information has been fully accomplished or (b) you inform us that you have withdrawn your consent; (ii) our legitimate interest until the earlier of (a) your Personal data is no longer necessary for the purpose for which it is being processed, or (b) FDE concludes that your rights and freedoms outweigh our right to process your Personal Data; and (iii) our necessity for the performance of a contract, until the termination or expiration of the contract including the termination or expiration of FDE’s and your employer’s or company’s duties or obligations that survive any such termination or expiration.

Furthermore, we will store your Personal Data in special circumstances related to the issuance or defense of legal proceedings, outstanding invoices or in connection with any investigation by or of a government authority.

K. What Protections do I have if FDE transfers my Personal Data to the U.S.?

If FDE transferred any of your data to the U.S., you have the protections of the Model Clauses. FDE US, LLC, a Delaware limited liability company, is FDE’s primary affiliate and operating company in the United States (“FDE US Parent”). FDE US Parent has two U.S. subsidiaries, FDEco, LLC and FDE UNIco, LLC, also Delaware limited liability companies (collectively “FDE US Subs;” collectively with FDE US Parent, “FDE US”).

FDE US’s contractual clauses for its clients are in the United States of America Addendum below.

FDE US’s contractual clauses covers Personal Data regarding:

(1) current, former, and prospective employees in connection with the employment relationship which is covered by a separate, employee only, Privacy Notice that has been made available to FDE US employees;

(2) Personal Data regarding client contacts and learners, program participants, consultants, contractors and deployed personnel, such as the sale and delivery of FDE services and the administration of the relevant client and individual relationship; and

(3) Personal Data regarding third parties (such as service providers and independent contractors) and their personnel and employees, in connection with FDE services and the provision and performance of technical professional services to client and, where applicable, their end customers and the management and administration of the business relationships with such third parties.

Our contractual clauses does not cover any disclosure of an individual’s Personal Data to a third party who processes the Personal Data for its own purposes when the disclosure is made at the request of the individual.

FDE US disclose Personal Data to third party service providers in connection with the operation of their respective businesses, including their provision of services to clients, learners, program participants, consultants, contractors and deployed personnel. FDE US ascertain that these third party service providers provide at least the same level of privacy protection as is required by the contractual clauses. FDE US may be liable if both (a) third parties fail to meet these obligations and (b) FDE US is responsible for the event giving rise to the damage.

FDE US may be required to disclose Personal Data to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.

Any questions or complaints concerning FDE US’s contractual clauses, or requests to access, correct, amend, delete, or limit the use or disclosure of Personal Data (opt out) may be directed to privacy@fdeco.com. If FDE US has not been able to satisfactorily resolve the issue, then you may raise it with the Information Commissioner’s Office.

In compliance with the contractual clauses, FDE US commits to cooperate and comply respectively with the advice of the panel established by the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data.

Should your complaint relate to FDE US’s failure to comply with its contractual clauses and remains unresolved, then you may raise it free of charge if you reside in the UK with the Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) Fax: 0162 552 4510 Or via below link : https://ico.org.uk/make-a-complaint/.

ICO regional offices

Scotland

Information Commissioner’s Office
45 Melville Street
Edinburgh
EH3 7HL

Tel: 0303 123 1115
Email: scotland@ico.org.uk

Wales

Information Commissioner’s Office
2nd floor
Churchill House
Churchill way
Cardiff
CF10 2HH

Tel: 0330 414 6421
Email: wales@ico.org.uk

Northern Ireland

Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB

Tel: 028 9027 8757 or 0303 123 1114
Email: ni@ico.org.uk

European Economic Area & Swiss Addendum

This Addendum applies to the European Economic Area (“EEA”) and Swiss residents.

I. Who are FDE’s European Union and Switzerland Representatives for Data Protection Purposes?

FDE’s representative in the European Union for purposes of GDPR Article 27 is Frank Recruitment Group Netherlands B.V. and in Switzerland for purposes of the Swiss Federal Act on Data Protection (“FADP”) is Frank Recruitment Group Sàrl (“Representatives”). FDE is subject to the supervision of the competent data protection supervisory authorities in the EEA in accordance with applicable law and, in Switzerland, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). For this Addendum, the EEA representative and the FDPIC shall collectively be referred to as “Relevant Contacts.”

II. How do we lawfully process your data?

In order to process your Personal Data lawfully FDE must have a legal basis to do so. FDE relies on three main legal basis for processing your Personal Data:

where we obtain your affirmative consent to use your Personal Data in this way;
where we have a legitimate interest in processing your Personal Data, which we have balanced against your rights and freedoms and concluded that our processing is justifiable; or
where our handling of your Personal Data is necessary for us to perform the obligations under your company’s or employer’s contract with FDE (inapplicable where you act solely on your own behalf).

We may rely on one or more legal bases to process your Personal Data

A. All users of the Websites and/or our services

Legitimate Interests: FDE uses Personal Data that we collect for the following general purposes in the performance of our legitimate interests as a business: to provide the services to our learners, program participants, consultants, contractors, deployed personnel and clients; to enhance their experience, to improve our services and to contact learners, program participants, consultants, contractors, deployed personnel and clients.

B. Actual or Prospective Learners, Program Participants, Consultants, Contractors and Deployed Personnel

Consent: If you, whether on your own behalf or on behalf of your company or your employer, would like to receive general marketing and other communications from us, you will have the option to affirmatively check a box consenting to FDE processing your Personal Data for this purpose. FDE may also ask you via email, text message or SMS (standard SMS or text message rates may apply), or telephone for your affirmative consent to receive marketing and other communications from us.

Legitimate interest: FDE has a legitimate interest in processing your Personal Data in order to provide services, to provide you (individual participant) or your company or your employer (consultant, contractor or deployed personnel) with other products and services to help you in your career and to market its products and services to you in order to grow our business, to demonstrate our knowledge of the marketplace and relevant technologies and to enhance the standing and recognition of our brands. FDE also has legitimate interest to process your Personal Data if you apply for, or seek further information about, a program, consultancy engagement, deployment, customer project or related service offered through one of the Websites or a service advertised by FDE on a social media site or other forum.

Necessary for the performance of a contract: FDE can process your Personal Data in the performance of its contract with your company or employer.

C. Individuals who work for FDE clients (i.e. a client contact)

Legitimate Interest: FDE has a legitimate interest in processing your Personal Data in order to meet a service requirement of your company or employer, and provide you with other products and services relevant to your company or employer and to market its products and services to you in order to grow our business, to demonstrate our knowledge of the marketplace and relevant technologies and to enhance the standing and recognition of our brands. FDE also has legitimate interest to process your Personal Data if you seek or obtain further information about FDE or an FDE learner, program participant, consultant, contractor or deployed personnel.

Necessary for the performance of a contract: FDE can process your Personal Data in the performance of its contract with your company or employer.

III. Your Special Rights under Data Protection Laws

A. Do I have a right to be erased (forgotten)?

Please note that your right to erasure is not absolute. FDE will remove your Personal Data when:

the Personal Data is no longer necessary in relation to the purpose for which FDE originally collected and/or processed it;
if FDE is processing your Personal Data on the basis of your consent and you withdraw consent;
you object to the processing of your Personal Data and there is no overriding legitimate interest for us to continue to process it;
the Personal Data was unlawfully processed; and
the Personal Data must be erased to comply with a legal obligation.

FDE can refuse to comply with an erasure request in the following limited circumstances:

(a) to exercise FDE’s right of freedom of expression and information;

(b) to comply with a legal obligation or for the performance of a public interest task;

(d) for the establishment, exercise or defence of legal claims.

If we remove your Personal Data per your request for erasure, then we will confirm this with you.

B. Do I have a right of access to a copy of my Personal Data?

Yes. You have the right to:

obtain confirmation that your Personal Data is being processed;
a copy of your Personal Data being processed;
the purposes of the processing;
the categories of personal data being processed;
the recipients or categories of recipients to whom FDE has disclosed your Personal Data; and
the criteria FDE uses to determine how long it will store your Personal Data.

You can exercise this right by sending an email to FDE at privacy@fdeco.com.

This right is in place to ensure that you are aware of and can verify the lawfulness of the processing. In most cases, we will provide you with a copy of your Personal Data free of charge. However, we may charge you a reasonable fee if your request is manifestly unfounded, excessive or repetitive. With respect to unfounded, excessive or repetitive requests, in rare cases, FDE may refuse to respond to your request but will explain the reason(s) for its refusal to you without undue delay and within one month of its receipt of your request. If FDE so refuses, you have the right to lodge a complaint with a competent data protection supervisory authority in the EEA or, where applicable, with the Swiss Federal Data Protection and Information Commissioner (“FDPIC”), and to seek a judicial remedy. You may contact the Relevant Contacts in relation to matters concerning the processing of your personal data.

If you submit your access request to FDE electronically, FDE will provide you with its response, and a copy of your Personal Data (if applicable) via email or other commonly used electronic form.

C. Do I have a right to object to the processing of my Personal Data, including the processing of my Personal Data by FDE for direct marketing?

Yes, you have a right to object to the processing of your Personal Data where:

FDE’s processing is based on its legitimate interest; or
where FDE is using your Personal Data to directly market to you.

You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com.

If FDE receives an objection request from you for reasons related to direct marketing, we will stop processing your Personal Data.

If you receive a direct marketing communication from FDE and you do not wish to receive future direct marketing communications from FDE, you may request to unsubscribe from future marketing communications by sending FDE an email at privacy@fdeco.com. In addition, if the direct marketing communication you received was via email, you can click the “Unsubscribe” link at the bottom of the email, fill out the required form and FDE will process your unsubscribe request. Please allow up to ten (10) business days for your unsubscribe request to take effect.

D. Do I have a right to restrict processing of my Personal Data?

when you file a rectification request with FDE (see the “Do I have a right to have any inaccurate or incomplete Personal Data rectified?” section below) in accordance with this Privacy Notice and applicable law. The restriction shall remain in place until such time as FDE has verified the accuracy of the Personal Data that is the subject of your rectification request;
where FDE is processing your Personal Data based on its legitimate interest and you file a notice with FDE objecting to the processing of your Personal Data (see the “Do I have a right to object to the processing of my Personal Data?” section above) in accordance with this Privacy Notice and applicable law, FDE will cease processing your Personal Data until such time as FDE has made a determination as to whether its legitimate grounds for continued processing override your reasons for objecting to the processing;
when the processing is unlawful and you do not seek or want erasure and you file a restriction request with FDE in accordance with this Privacy Notice and applicable law instead; and
if FDE no longer needs the Personal Data and you require the data to establish, exercise or defend a legal claim.

FDE will inform you if it decides to lift a restriction on processing.

E. Do I have a right to Personal Data portability?

F. Do I have a right to object to decision been taken by automated means?

G. Do I have a right to have any inaccurate or incomplete Personal Data rectified?

Yes. You can exercise this right, free of charge, by sending an email to FDE at privacy@fdeco.com.

We will use reasonable endeavours to ensure that your Personal Data is maintained and up to date.

H. What are my rights if the Security of my Personal Data is breached?

If the Breach is likely to have a significant detrimental effect on your rights and freedoms (such as resulting in discrimination, damage to reputation or financial loss), FDE will notify the competent data protection supervisory authorities in the EEA in accordance with applicable law and, in Switzerland, the FDPIC without undue delay, and if feasible, within one business day of FDE’s becoming aware of the Breach. FDE will assess the determination of “significant detrimental effect” on a case by case basis.

If the Breach is likely to result in a “high risk” to your rights and freedoms, FDE will notify you without undue delay. To be clear, the threshold requiring FDE to notify you of a Breach is higher than the threshold requiring FDE to notify the competent data protection supervisory authorities in the EEA in accordance with applicable law and, in Switzerland, the FDPIC of a Breach so it is possible that FDE will notify the the competent data protection supervisory authorities in the EEA in accordance with applicable law and, in Switzerland, the FDPIC of a Breach but not you. FDE will assess the determination of “high risk” on a case-by-case basis.

Any Breach notice issued by FDE will contain, where possible, (1) the categories and approximate number of individuals and Personal Data records effected by the Breach, (2) the name and contact details of the Information Systems Manager (“ISM”) (or other FDE contact representative if FDE does not have a ISM at the time that FDE issues the Breach notice), (3) a description of the likely consequences of the Breach, (4) a description of the measures that FDE has taken, and may take, to stop the Breach and, where appropriate, to mitigate the adverse effects of the Breach and (5) recommendations on actions you can take to protect yourself in light of the Breach.

I. Will my Personal Data be transferred outside the EEA & Switzerland?

FDE may transfer your Personal Data to third parties described in this Privacy Notice who are located outside of the EEA or Switzerland. If so, FDE will take reasonable steps to ensure that your Personal Data is protected and treated in accordance with this Privacy Notice and local applicable law. Some of the countries outside Switzerland or EEA where your Personal Data may be transferred will be on the EU Commission’s or Swiss Federal Data Protection and Information Commission’s list of countries that it has deemed to have adequate security controls in place (for this Addendum, the “Approved List”). Given the European Court of Justice’s decision in Data Protection Commissioner v. Facebook Ireland and Maximilian Schrems, Case C-311/18 (July 16, 2020) (“Schrems II”) as well as the September 8, 2020 Swiss Federal Data Protection and Information Commissioner’s Policy paper on the transfer of personal data to the USA and other countries lacking an adequate level of data protection within the meaning of Art. 6 Para. 1 Swiss Federal Act on Data Protection, and absent consent from the Data Subject (or any other reason provided in GDPR Article 49(1)(b)-(f) or Swiss law as may be amended from time to time), FDE transfers your Personal Data to processors (which could be external third party vendors or suppliers) that store, transfer, process, or control your Personal Data in a country not on the Approved List or not in Switzerland or the EEA (for this Addendum, “Third Countries”), then FDE shall determine whether each processor (and each subprocessor that a processor has provided FDE formal notice of) can store, transfer, process, or control the Personal Data solely within Switzerland EEA, or a country on the Approved List.

(a) If FDE determines that the processor (and each subprocessor that a processor has provided FDE formal notice of) can store, transfer, process, or control the Personal Data solely within a country on the Approved List or in Switzerland or the EEA, we will require such processor (and will require the processor to require each of its applicable subprocessors) to do so.

(i) FDE will require such processor (and will require the processor to require each of its applicable subprocessors) to be bound by the model clauses promulgated by the European Commission as provided here (or any updated link which the European Commission may supply from time to time) (for this Addendum, the “Model Clauses”). When relying on the Model Clauses, FDE shall (a) monitor the laws and regulations of Third Countries for the adequate protections of Swiss, or EEA Data Subjects as required by the GDPR or other local laws and regulations; and (b) terminate the storage, transfer, processing , or control of Personal Data by a processor (or a subprocessor where the process has informed FDE of the country in which such subprocessor is processing your Personal Data) when (i) such laws and regulations of Third Countries are incompatible with the GDPR or other local laws and regulations, or (ii) access to Personal Data is requested by the public authorities of Third Countries and such access is lawful under the laws of the Third Countries but is prohibited under the GDPR or other local laws and regulations. If the events described in III(I)(b)(i)(b)(i) or (ii) occur, FDE will confer with the appropriate supervisory authority regarding appropriate actions to safeguard your Personal Data.

If processor (or its applicable subprocessors) can store, transfer, process, or control the Personal Data solely within Switzerland, EEA, or a country on the Approved List, then FDE shall contractually require the processors (and require processor to require its subprocessors to) do so.
If processor (or its applicable subprocessors) must store, transfer, process, or control the Personal Data in a Third Country, then FDE shall require its processors (and require processor to require its subprocessors to) to be bound by the Model Clauses. When relying on the Model Clauses, FDE shall contractually require such processors (and shall also require processors to require their subprocessors) to agree to (a) monitor the laws and regulations of Third Countries for the adequate protections of Swiss or EEA Data Subjects as required by the GDPR or other local laws and regulations; and (b) terminate the transfer, processing, or control of Personal Data when (i) such laws and regulations of Third Countries are incompatible with the GDPR or other local laws and regulations, or (ii) access to Personal Data is requested by the public authorities of Third Countries and such access is lawful under the laws of the Third Countries but is prohibited under the GDPR or other local laws and regulations. If the events described in III(I)(c)(2)(b)(i) or (ii) occur with respect to your Personal Data (and if FDE has formal notice that the events described in III(I)(c)(2)(b)(i) or (ii) have occurred), FDE will confer with the appropriate supervisory authority regarding appropriate actions to safeguard your Personal Data.

J. How long will FDE store my Personal Data for?

We are required by law to store your Personal Data for as long as is necessary to comply with our legal, regulatory and contractual obligations.

With respect to GDPR (and similar laws), we will store and process your Personal Data that we obtain via: (i) your consent, until the earlier of (a) the purpose for which we obtained such information has been fully accomplished or (b) you inform us that you have withdrawn your consent; (ii) our legitimate interest until the earlier of (a) your Personal data is no longer necessary for the purpose for which it is being processed, or (b) FDE concludes that your rights and freedoms outweigh our right to process your Personal Data; and (iii) our necessity for the performance of a contract, until the termination or expiration of the contract including the termination or expiration of FDE’s and your employer’s or company’s duties or obligations that survive any such termination or expiration.

K. What Protections do I have if FDE transfers my Personal Data to the U.S.?

If FDE transferred any of your data to the U.S. you have the protections of the contractual clauses (as defined below) and the Model Clauses (as defined above). FDE US, LLC, a Delaware limited liability company, is FDE’s primary affiliate and operating company in the United States (“FDE US Parent”). FDE US Parent has a subsidiary, FDEco, LLC, also a Delaware limited liability company (“FDE US Sub,” collectively with FDE US Parent, “FDE US”).

FDE US and FDE US Sub participates in contractual clauses as defined below regarding the collection, use, and retention of personal information transferred from the European Union, EEA, and/or Switzerland, as applicable to the United States. If there is any conflict between the terms in this Privacy Notice and the contractual clauses (as defined below), the contractual clauses (as defined below) shall govern.

This Privacy Notice only applies to Personal Data within the scope of the FDE US’s contractual clauses (as defined below) participation. FDE US’s contractual clauses for its clients are in the United States of America Addendum below.

FDE US’s contractual clauses participation covers Personal Data regarding:

(1) current, former, and prospective employees in connection with the employment relationship which is covered by a separate, employee only, privacy policy that has been made available to FDE US employees;

Our certifications do not cover any disclosure of an individual’s Personal Data to a third party who processes the Personal Data for its own purposes when the disclosure is made at the request of the individual.

FDE US disclose Personal Data to third party service providers in connection with the operation of their respective businesses, including their provision of services to clients, learners, program participants, consultants, contractors and deployed personnel. FDE US ascertain that these third party service providers provide at least the same level of privacy protection as is required by the contractual clauses (as defined below). FDE US may be liable if both (a) third parties fail to meet these obligations and (b) FDE US is responsible for the event giving rise to the damage.

FDE US are subject to the investigatory and enforcement powers of the United States Federal Trade Commission. FDE US may be required to disclose Personal Data to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.

Any questions or complaints concerning FDE US’s contractual clauses (as defined below) participation, or requests to access, correct, amend, delete, or limit the use or disclosure of Personal Data (opt out) may be directed to privacy@fdeco.com. If FDE US has not been able to satisfactorily resolve the issue, then you may raise it free of charge with your data protection authority (see paragraph immediately below).

In compliance with the contractual clauses (as defined below), FDE US commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (“SAs”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved complaints concerning our handling of personal data received in reliance on the contractual clauses.

L. EEA residents.

Should your complaint relate to FDE US’s failure to comply with its contractual clauses (as defined below) commitments and remains unresolved and you reside in the EEA, then you should contact the SAs who act as an independent recourse mechanism to settle all such disputes. Such complaints can be directed either to the EEA SAs panel secretariat or individual EEA SAs.

Currently, the contact information relevant to the submission of the standard complaint form is as follows: Commission Européenne, Directorate General Justice, Directorate C (Fundamental Rights and Union Citizenship) of the European Commission, Data Protection Panel, B-1049 Brussels, Belgium, Telephone: (32-2) 299 11 11, Fax: (32-2) 298.80.94, email: ec-dppanel-secr@ec.europa.eu.

You can find the standard compliant form at https://edps.europa.eu/data-protection/our-role-supervisor/complaints/edps-complaint-form_en.

The contact information for individual EU SAs can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm.

M. Swiss residents.

Should your complaint relate to FDE US’s failing to comply with our contractual clauses (as defined below) commitments and remains unresolved and you reside in Switzerland, then you should contact the FDPIC with whom FDE US has agreed to cooperate regarding such disputes.

The contact information for the FDPIC can be found at: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.

Under the contractual clauses (as defined below), the following independent dispute resolution bodies designated to address complaints will provide appropriate recourse free of charge to the individual: the panel established by SAs.

Also, under the contractual clauses (as defined below), the following independent dispute resolution bodies designated to address complaints will provide appropriate recourse free of charge to the individual: the Swiss Federal Data Protection and Information Commissioner (“FDPIC”).

We have appointed Frank Recruitment Group Netherlands BV. to act as our EU representative and Frank Recruitment Group Sàrl as our Switzerland representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or applicable Swiss data protection law, including the Federal Act on Data Protection (FADP), or if you have any queries in relation to your rights or general privacy matters under EU GDPR, or applicable Swiss data protection law, please email one of the following representatives.

However, please do not use the below email address for any data protection queries relating to UK policies or claims, queries relating to UK data protection matters should be referred to us at privacy@fdeco.com and not to our EU or Swiss representative.

EU Representative

Frank Recruitment Group Netherlands BV
Vijzelstraat 68-78

1017 ES Amsterdam

The Netherlands
Email: representative@fdeco.com

Swiss Representative

Frank Recruitment Group Sàrl
Suite 311

Spaces Quai de l’Ile:

Quai de l’Ile 13

1204 Geneva

Switzerland
Email: representative@fdeco.com

United States of America Addendum

If you would like a copy of FDE’s US comprehensive information security program, please email FDE’s Information Security Manager at privacy@fdeco.com.

If FDE receives a “Do Not Track” signal or request from a web browser, FDE will not honor such request or signal. FDE has taken this position in part to provide you with a personalized and efficient experience on the Websites.

As discussed in this Privacy Notice, there are third parties who conduct tracking on the Websites.

Information about web beacons used by FDE and third parties with whom it contracts can be found in Section XII.F of the Privacy Notice above.

II. For information on FDE US’s transferring of personal data from the United Kingdom, European Economic Area, and Switzerland, see the section titled “What Protections do I have if FDE transfers my Personal Data to the U.S.?” in the United Kingdom Addendum and the European Economic Area and Switzerland Addendum above.

FDE US requires certain contracts to contain the rights, obligations and requirements set forth in Sections II(A) through II(C) inclusive below (collectively, the “contractual clauses”)[1]. Accordingly, the following contractual clauses, to which FDE reserves the right to revise from time to time without notice, shall be incorporated by reference where these contractual clauses are required in client contracts:

(A). In the event FDE US transfers to client or any of its affiliates, or provides client or any of its affiliates with access to any Personal Data (as defined for this Section II below) of European Union or Switzerland residents, including employees of FDE or its affiliates and actual or prospective FDE client contacts, learners, program participants, consultants, contractors or deployed personnel, and client maintains, receives, has access to, stores, uses or processes such Personal Data in the United States, client shall comply with data protection, data security and confidentiality requirements at least as strong as those set forth in the Principles issued by the U.S. Department of Commerce, as revised from time to time (collectively, the “Principles”) During the term of such contracts and while client creates, receives, maintains, stores, uses, processes or disseminates any Personal Data, client shall:

use the Personal Data only for the specific and limited purposes intended in the client contract including for the delivery of relevant FDE services;
provide immediate written notice to either FDE US Parent or FDE US Sub as applicable if (a) client determines that it can no longer meet its obligation to provide the same level of protection of the Personal Data as is required by the Principles, and in such case client shall cease processing the Personal Data or (b) client becomes aware of any accidental or unlawful destruction of, or accidental loss or alternation of or unauthorized disclosure or access to, any Personal Data (a “Breach”) which notice shall include a description of the quantity of Personal Data subject to the Breach, the approximate length and duration of the Breach, the data subjects whose Personal Data was subject to the Breach and a Breach remediation plan;

[1] FDE US does not currently have any framework certifications regarding the Principles and if it does certify either FDE US Parent or FDE US Sub, FDE will update this Privacy Notice.
at its cost, employ its best efforts to stop, limit and remediate the Breach, perform a “root cause” analysis of the Breach, employ its best efforts to prevent the same or a similar Breach from reoccurring and keep FDE up to date on all its efforts under this subsection II(A)(3);
implement appropriate technical and organizational measures to protect Personal Data against a Breach;
not transfer any Personal Data to third parties without the data subject’s prior written or email consent (which either FDE US Parent or FDE US Sub as applicable shall attempt to obtain after receiving notice from client of its need to transfer Personal Data to a third party);
assist FDE US in responding to data subjects exercising their rights under the Principles;
act only on instructions from FDE US; and
either have in place an independent recourse mechanism to handle data subject complaints that complies with the requirements of the Principles or make available an equivalent mechanism.

(B) Upon the termination or expiration of the applicable client contract, client shall, at FDE US’s option, return all Personal Data to either FDE US Parent or FDE US Sub as applicable or permanently destroy all Personal Data (and all copies and derivative works thereof) in its care, custody or control except for any Personal Data that applicable law, if any, requires client to maintain (“Archival Personal Data”). With respect to any Archival Personal Data, client’s obligations and requirements under this Section II shall remain in full force and effect for as long as such Archival Personal Data remains in client’s care, custody or control.

(C) If client forwards or gives access to any of the Personal Data to any third party at any time, including any subprocessor or controller of client, client shall ensure that its written contract with such third party contains the Data Privacy Framework Terms.

(D) For purposes of this Section II, the term “Personal Data” shall have the same meaning ascribed to that term as in the Principles which can be found at the Principles as revised from time to time.

Generally, FDE voluntarily extends the same protections for residents of US states that have comprehensive data privacy laws (including without limitation California, Colorado, Connecticut, Iowa, Utah, and Virginia) to those residents in US states without such laws. To the extent you reside in either, the following disclosures may apply to you:

US State Data Privacy Laws

Our goal is to enable individuals and organizations to comply as easily as possible with the US state privacy laws (including to the extent such laws are applicable, without limitation, the California Consumer Privacy Act (CCPA) of 2018 as amended by California Privacy Rights Act (CPRA) of 2020; Virginia Consumer Data Protection Act (CDPA); Colorado Privacy Act (CPA); Connecticut Act Concerning Personal Data Privacy and Online Monitoring (CTDPA); Utah Consumer Privacy Act (UCPA); Texas Data Privacy and Security Act (TDPSA); Florida Digital Bill of Rights (FDBR); Oregon Consumer Privacy Act (OCPA); Montana Consumer Data Privacy Act (MCDPA); Iowa Consumer Data Protection Act (ICDPA); Delaware Personal Data Privacy Act (DPDPA); Nebraska Data Privacy Act (NEDPA); New Hampshire An Act relative to the expectation of privacy (NHCDPA); New Jersey An Act concerning commercial Internet websites, online services, consumers, and personally identifiable information (NJDPA); Tennessee Information Protection Act (TIPA); Minnesota Consumer Data Privacy Act (MCDPA); Maryland Online Data Privacy Act (MODPA); Indiana Consumer Data Protection Act (ICDPA); Kentucky Consumer Data Protection Act (KCDPA); Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA) (collectively, the CCPA, CPRA, CDPA, CPA, CTDPA, UCPA, TDPSA, FDBR, OCPA, MCDPA, ICDPA, DPDPA, NEDPA, NJDPA, TIPA, MCDPA, MODPA, ICDPA, KCDPA, RIDTPPA, are the “US State Data Privacy Laws”) requirement to protect the privacy and data of consumers. As a provider of AI consultancy, workforce transformation, talent development, training and deployment services, we respect and protect your privacy and security and are committed to following best practices.

We – meaning FDEco, which is a trademark and brand owned by FDE US, LLC and its subsidiaries, including without limitation, (Collectively “we,” “us,” “our,” or “FDE”) – prepared this Privacy Addendum to help you understand our practices regarding the collection, use, and disclosure of information we collect from you through FDE’s web applications, our websites that link to this Privacy Addendum, and any other services we provide to our customers (collectively, “Services”).

By accessing or using the Services, you agree to this Privacy Addendum, our Do Not Sell or Share My Personal Information Notice, our Privacy Notice, and our Terms of Use.

I. Information from Children

FDE only works with adults (people who are at least 18 years old or people who have reached the age of majority in the jurisdiction where they reside, if older). FDE therefore is not directed to children under the age of 13 and we do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have collected personally identifiable information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable.

Please contact us at privacy@fdeco.com, fill the webform here, or give us a call at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 2521 if you believe we have any information from or about a child under the age of 13.

II. US State Data Privacy Law Disclosures

The US State Data Privacy Laws, require businesses subject to this law to provide consumers residing in California, Colorado, Connecticut, Iowa, Utah, and Virginia (“US State Data Privacy Law Consumer”) with certain rights regarding their personal information and sensitive personal information.

At this time, we may sell or share your personal information, and depending on the circumstances, your sensitive personal information, so the opt-out or opt-in choices may apply. For more information, visit https://www.fdeco.com/legal/do-not-sell-or-share-personal-info-or-sensitive-personal-info/.

Here’s a summary of rights for US State Data Privacy Law Consumers under the US State Data Privacy Laws:

A. Your Right to Opt Out. You have the right to tell businesses that do sell or share your personal information or sensitive personal information to third parties (i.e. us) not to sell or share it at any time. Businesses that sell or share your personal information or sensitive personal information to third parties must also ensure that the third parties do not resell or reshare it unless the business notified you explicitly and provided you with a chance to opt out of resales. These opt-out rights apply to businesses that do not know your age, or know you are older than 16. Additionally, we must also respect opt outs made by your authorized agent if such authorized agent provides signed written permission from you to do so.

B. Your Right to Opt In. If a business has actual knowledge that you are between ages 13 and 16 (e.g., based information the business collects), businesses cannot sell or share or allow resales or reshares of your personal information or sensitive personal information without your affirmative authorization. If a business has actual knowledge that you are younger than 13, it may not sell or share, or allow resales or reshares of your personal information or sensitive personal information without your parent or guardian’s affirmative authorization. This is your right to opt in.

C. Your Right to Disclosures. You have the right to know:

1. A link to FDE’s “Do Not Sell or Share My Personal Information and Limit the Use and Disclosure of Sensitive Personal Information” notice.
a) Please visit https://www.fdeco.com/legal/do-not-sell-or-share-personal-info-or-sensitive-personal-info/

2. A description of a consumer’s rights pursuant to US State Data Privacy Laws, including CCPA Section 1798.120:

(a) Your Right to Opt Out. If you’re a US State Data Privacy Law Consumer and we sell or share your information to third parties, you can tell us at any time not to sell or share your personal information or sensitive personal information. This right to opt-out applies if we do not know your age or if we know you are older than age 16. Additionally, we must also respect opt outs made by your authorized agent if such authorized agent provides signed written permission from you to do so.

(b) Your Right to Opt In. If we have actual knowledge that you are between ages 13 and 16 (e.g., based information we collect, or because someone informed us), we will never sell or share your personal information or sensitive personal information without your affirmative authorization. If we have actual knowledge that you are younger than 13, we will never sell or share your personal information or sensitive personal information without your parent or guardian’s affirmative authorization. This is your right to opt in.

(c) Do We Sell or Share Your Personal Information? At this time, we may sell or share your personal information or sensitive personal information and you can opt out at any time. If you opt out, or for children 16 and younger, if you have not opted in, we will not sell or share your personal information or sensitive personal information to third parties unless you expressly authorize us to do so.

3. A description of a consumer’s rights pursuant to US State Data Privacy Laws, including CCPA Section 1798.110: US State Data Privacy Law Consumers have the right to request that we disclose to you:

(a) The categories of personal information it has collected about you.

(b) “Personal information” is information that identifies or relates to a particular consumer or household including name, postal address, email address, IP address, social security number, personal property records, purchasing histories, biometric information, internet activity such as browsing or search history, geolocation data, employment information, sensitive personal information, education information and inferences drawn from this information, in so far as it is not publicly available information. In addition to the above types of personal information that we may collect, FDE may collect personal information such as:

(i) Name;

(ii) Contact details e.g. street address, email address, telephone number;

(iii) Work Experience;

(iv) Job Title;

(v) Professional Certifications;

(vi) Education & Qualifications;

(vii) Skills;

(viii) Career History;

(ix) Salary Range;

(x) Right to work status/citizenship;

(xi) Other information relevant to help us provide technology talent creation services;

(xii) References from past employers; and

(xiii) IP address.

(c) “Sensitive personal information” means: nonpublic personal information that reveals:

(i) A consumer’s social security, driver’s license, state identification card, or passport number;

(ii) A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;

(iii) A consumer’s precise geolocation;

(iv) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;

(v) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication;

(vi) A consumer’s genetic data;

(vii) The processing of biometric information for the purpose of uniquely identifying a consumer; and

(viii) Personal information collected and analyzed concerning a consumer’s health; and

(ix) Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

4. The categories of third parties with whom the business shares personal information and/or sensitive personal information.

(a) All users of the websites and/or our services

(i) To third parties where we have retained them to provide services that we or you have requested or that FDE clients have requested including references, qualifications and background reference checking services and to verify the details you have provided from third party sources.

(ii) To third parties to provide data storage, CV/resume parsing, data cleansing and marketing services to FDE where such third parties have agreed to maintain the confidentiality of, and to protect, your personal information and/or sensitive personal information in accordance with applicable law.

(iii) To third parties to assist with credit control and payment management.

(iv) To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, in connection with legal proceedings or other similar cause or circumstance.

(v) To FDE affiliates, whose locations can be found at https://www.fdeco.com/contact. These entities will process your personal information and/or sensitive personal information in accordance with the Privacy Addendum.

(vi) In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets, or a controlling interest in the equity, of FDE (or any of its group companies) provided that such counterparty(ies) to any such transaction agrees to adhere to the terms of the Privacy Addendum (or a similar document) and applicable law.

(b) Actual or Prospective FDE Clients

(i) To FDE clients in order for them to determine if you are or may be suitable for a program, consultancy engagement, deployment, customer project or related service.

(ii) To third parties that you authorize us to send your personal information and/or sensitive personal information to such as your CV

(iii) To third parties to determine if an FDE client or other entity (or their respective affiliates) to whom FDE presented you has (a) employed you or (b) retained you or any entity (i) that employed you or (ii) that retained you or (iii) in which you have an financial interest.

(c) Individuals who work for FDE clients (i.e. a client contact)

(i) To Contacts in the course of providing your company or employer with FDE services and to support service delivery.

(ii) To third parties where we have retained them to provide services that you have requested including Freelancer skill tests and other testing.

(iii) To third parties to determine if an FDE client or other entity (or their respective affiliates) to whom FDE introduced a learner, program participant, consultant, contractor or deployed personnel has (a) engaged the individual or (b) retained the individual or any entity (i) that engaged the individual or (ii) that retained the individual or (iii) in which the individual has a financial interest.

5. The categories of sources from which the personal information and/or sensitive personal information is collected.

(i) We collect personal information and/or sensitive personal information from you actively when you enter it into our services (e.g., your name, your CV/resume, etc.).

(ii) We collect personal information and/or sensitive personal information passively when you access our services, to the extent your web browser provides this information to our servers (e.g., your operating system) and also based on your service usage (e.g., when and from what IP address you log on to our services, which may reveal your precise geolocation).

(iii) We collect personal information and/or sensitive personal information when it is provided to us by either yourself or a third party (for example, LinkedIn, professional networks, learning platforms and relevant databases, etc.).

6. The business or commercial purpose for collecting, selling, or sharing personal information and/or sensitive personal information.

(a) Why do we process your personal information and/or sensitive personal information?

(i) Generally, we use your personal information and/or sensitive personal information for our business and activities, and in our efforts to expand and improve our business. Examples include:

All users of the Websites and/or our services

(a) To provide our technology talent creation services to you, your employer or your company;

(b) To facilitate service delivery, including but not limited to:

(i) Qualifying and submitting learners, program participants, consultants, contractors and deployed personnel;

(ii) For clients, negotiating FDE terms of business;

(iii) Arranging assessments or discussions and obtaining feedback;

(iv) Agreeing engagement or service terms; and

(v) Providing post-engagement follow-up.

(c) Where permitted by applicable law and unless you tell us otherwise, we (or a third party to whom we have provided your Personal Data under part VI below of this Privacy Notice) may send you emails, SMS messages, or text messages (standard SMS or text message rates may apply);

(d) To assess data about you against programs, consultancy engagements, deployments, customer projects or related services which we judge may be suitable for you;

(e) To third party vendors to assist us in hosting, managing and operating our websites;

(f) To third party vendors who provide data analysis and data updating services to us;

(g) To third party vendors who provide email and other communications related services to us

(h) To enable you to submit your CV/resume to FDE, apply online (including through the Websites) for programs or services or subscribe to alerts about opportunities we think may be of interest to you;

(i) To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;

(j) To improve our customer service and to make our services more valuable to you (including tailoring the Websites when you log on to enrich your personal online experience);

(k) To send you electronically or by post surveys, reports, FDE event details, promotions, offers, networking and client events and general information about relevant industry sectors which we think might be of interest to you, where you have consented to being contacted for such purposes (and we will provide you with an opportunity to opt out);

(l) To identify you, and respond to and process your requests for information and provide you with a product or service;

(m) To amend records to remove personal information and/or sensitive personal information;

(n) To use your information on an anonymized basis to monitor compliance with our equal opportunities policy, other FDE policies and any legal or compliance requirements;

(o) To use your information on an anonymized basis to create marketing materials such as a salary survey; and

(p) To carry out our obligations arising from any contracts entered into between you and us, and for other everyday business purposes that involve use of personal information and/or sensitive personal information.

Actual or Prospective Learners, Program Participants, Consultants, Contractors and Deployed Personnels

(a) To help identify a suitable program, consultancy engagement, deployment, customer project or related service for you;

(b) To contact you about programs, consultancy engagements, deployments, customer projects or related services that FDE is delivering or may deliver for FDE clients;

(d) To communicate with you (individual participants), your employer or your company (consultants, contractors or deployed personnel) after you or it has started a program, engagement, deployment or project to make sure all is going well or to remedy, or attempt to remedy, any problems;

(e) To answer any questions you have about a program, engagement, deployment, project or relevant market opportunity;

(f) To fulfill any aspect of your Employment Agreement or Contract of Employment with FDE;

(i) To third party vendors who provide customer relationship management database services to us;

(ii) To third party vendors who provide data analysis and data updating services to us

(iii) To third party vendors who provide document execution, transmission and storage services to us

(iv) To third party vendors who provide email and other communications related services to us

(g) To collect any money due, or allegedly due, to FDE or any FDE client (or FDE’s client’s client);

(h) To obtain or inquire about any property (including computers and confidential business information) owned, or allegedly owned, by FDE or any FDE client (or FDE’s client’s client);

(i) To determine if an FDE client or other entity (or their respective affiliates) to whom FDE presented you has (a) employed you or (b) retained you or any entity (i) that employed you or (ii) that retained you or (iii) in which you have an financial interest;

(j) To establish, exercise or defend any legal claims; and\

(k) To assist you (individual participants), your employer or your company (consultants, contractors or deployed personnel) if you are dissatisfied with the program, engagement, deployment or project, or any aspect of it.

Individuals who work for FDE clients (i.e. a “client contact”)

(a) To meet a service requirement of your company or employer;

(b) To contact you about learners, program participants, consultants, contractors or deployed personnel with whom FDE has a relationship;

(i) To third party vendors who provide customer relationship management database services to us;

(ii) To third party vendors who provide data analysis and data updating services to us;

(iii) To third party vendors who provide document execution, transmission and storage services to us;

(iv) To third party vendors who provide email and other communications related services to us;

(d) To communicate with you after your company or employer has hired/retained an FDE learner, program participant, consultant, contractor or deployed personnel to make sure all is going well and to remedy, or attempt to remedy, any problems;

(e) To negotiate and fulfil any aspect of your company’s or employer’s contract with FDE Group;

(f) To answer any questions you have about a program, engagement, deployment, project or individual or your company’s or employer’s contract with FDE;

(g) To resolve any issue with the issuance, payment, collection or enforcement of an FDE invoice;

(h) To collect any property owned by FDE or any FDE learner, program participant, consultant, contractor or deployed personnel;

(i) To third parties to determine if a FDE client or other entity (or their respective affiliates) to whom FDE introduced a learner, program participant, consultant, contractor or deployed personnel has (a) engaged the individual or (b) retained the individual or any entity (i) that engaged the individual or (ii) that retained the individual or (iii) in which the individual has a financial interest; and

(J) To establish, exercise or defend any legal claims.

7.The specific pieces of personal information and/or sensitive personal information it has collected about that consumer.

(a) Please email us at privacy@fdeco.com, fill out the webform here, or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 2521 to request this information. Before we can respond to your request, we’ll need to verify your identity.

8. A description of a consumer’s rights pursuant to US State Data Privacy Laws, including CCPA Section 1798.115:

(a) If we sell or share your personal information and/or sensitive personal information or disclose it for a business purpose, you have the right to know:

(i) The categories of personal information and/or sensitive personal information that the business collected about the consumer.

(aa) See Section 3 4) above (e.g., web log data, registration data, resume/CV data, etc.).

(ii) The categories of personal information and/or sensitive personal information that the business sold about the consumer and the categories of third parties to whom the personal information and/or sensitive personal information was sold, by category or categories of personal information and/or sensitive personal information for each third party to whom the personal information and/or sensitive personal information was sold or shared.

(aa) See Sections 3 4), 3 5) and 3 6) above.

(iii) The categories of personal information and/or sensitive personal information that the business disclosed about the consumer for a business purpose.

(aa) See Section 3 6) above.

(b) If we sell or share your personal information and/or sensitive personal information or disclose it for a business purpose, you have the right to request that we disclose to you (1) the categories of personal information and/or sensitive personal information that we collected about you, (2) the categories of personal information and/or sensitive personal information we sold or shared about you and the categories of third parties to whom we sold or shared it, by category of personal information and/or sensitive personal information for each third party to whom we sold or shared your personal information and/or sensitive personal information and (3) the categories of personal information and/or sensitive personal information that the business disclosed about the consumer for a business purpose. We are required to verify your identity before providing you with this information if the information would constitute your personal information and/or sensitive personal information.

To exercise these important rights, please: mail us at privacy@fdeco.com or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 2521 to request this information. Before we can respond to your request, we’ll need to verify your identity.

(c) If we sell or share your personal information and/or sensitive personal information to a third party or disclose it for a business purpose, we are required to disclose:

(i) The category or categories of consumers’ personal information and/or sensitive personal information we sold or shared, or if we have not sold or shared your personal information and/or sensitive personal information, we shall disclose that fact.

(aa) If we sell or share your personal information and/or sensitive personal information, it will be in the form of your CV/resume, anonymized or pseudonymized.

(ii) The category or categories of consumers’ personal information and/or sensitive personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information and/or sensitive personal information for a business purpose, it shall disclose that fact.

(aa) We rely on vendors to operate our infrastructure, and accordingly for each category of personal information and/or sensitive personal information that we disclosed above as a category that we collect, we disclose it to one of our third-party vendors for a business purpose (i.e. to develop, market, provide and support our business services). Those categories are: web log data, registration data, payment data, service usage data, customer content, consumer content and marketing data.

(d) If we sell or share your personal information and/or sensitive personal information to a third party, it is not allowed to resell or reshare it unless we notified you explicitly and provided you with a chance to opt out.

(aa) We do not allow third parties to whom we sell or share your personal information and/or sensitive personal information to resell or reshare the personal information and/or sensitive personal information, so no opt-out choices apply. See https://www.fdeco.com/privacy-notice/#ccpa for details.

9. A description of a consumer’s rights pursuant to US State Data Privacy Laws, including CCPA Section 1798.125:

(a) Businesses, including us, may not discriminate against you because you exercised any of your consumer privacy rights such as by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including via discounts or other benefits or penalties; (3) providing you a different level or quality of goods or services or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Businesses may however discriminate where any difference is reasonably related to the value provided to you by your data.

(b) Businesses, including us, may offer you financial incentives, including payments as compensation, for the collection, sale or deletion of your personal information and/or sensitive personal information. If we offer any incentives we will (1) notify you about them in our privacy policy and in any California-specific descriptions of consumer privacy rights we post and (2) only enroll you in them with you opt-in consent after disclosing all material incentive program terms to you. Incentive programs may never be unjust, unreasonable, coercive, or usurious.

(i) We do not currently offer any financial incentives.

10. A description of a consumer’s rights pursuant to US State Data Privacy Laws, including CCPA Section 1798.105:

(a) You have the right to request that we delete any personal information and/or sensitive personal information about you that we have collected. Before we delete any information, we’ll need to verify your identity. If we delete your information, we’ll also instruct our vendors (aka service providers) to delete it. The US State Data Privacy Laws do not obligate us to delete information under all circumstances, including where we need the information to provide our services to you, to detect security incidents, to identify errors in our services, or to comply with legal obligations. If you request that we delete information, we’ll let you know if we are deleting it or if we are not deleting it based on exemptions provided by the applicable US State Data Privacy Laws.

11. One or more designated methods for submitting requests (at minimum, a toll-free telephone number):

(a) You may submit any consumer privacy requests by emailing us at privacy@fdeco.com, fill out the webform below, or by calling us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and entering Service Code 2521. Before we can respond to your request, we’ll need to verify your identity.

III. Your Right to Data Deletion. You have the right to request that we delete any personal information and/or sensitive personal information about you that we have collected. Before we delete any information, we’ll need to verify your identity. If we delete your information, we’ll also instruct our vendors (aka service providers) to delete it. The US State Data Privacy Laws do not obligate us to delete information under all circumstances, including where we need the information to provide our services to you, to detect security incidents, to identify errors in our services, or to comply with legal obligations. If you request that we delete information, we’ll let you know if we are deleting it or if we are not deleting it based on exemptions provided by the US State Data Privacy Laws. You may also delete personal information and/or sensitive personal information by using our services dashboard as described above.

IV. Your Anti-Discrimination Rights. Businesses may not discriminate against you exercising any of your consumer privacy rights such as by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including via discounts or other benefits or penalties; (3) providing you a different level or quality of goods or services or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Businesses may however discriminate where any difference is reasonably related to the value provided to you by your data. We will not discriminate against you in any way for exercising your privacy rights.

V. Your Rights Regarding Financial Incentives. Businesses may offer you financial incentives, including payments as compensation for the collection, sale or deletion of your personal information and/or sensitive personal information. In this case a business must: (1) notify you about the incentives in its Privacy Addendum and in any US State Data Privacy Law-specific descriptions of consumer privacy rights it posts and (2) only enroll you in them only with your opt-in consent after disclosing all material incentive program terms. Incentive programs may never be unjust, unreasonable, coercive, or usurious. We do not currently offer any financial incentives.

VI. Designated methods for submitting requests. We offer three ways to express your privacy preferences: the following interactive web form, our email at privacy@fdeco.com, and the toll free phone number below.

CCPA Toll Free webform: Do Not Sell My Personal Information

VII. Changes to Privacy Addendum

Any information that we collect is subject to the Privacy Addendum in effect at the time such information is collected. We may, however, revise the Privacy Addendum from time to time. If a revision is material, as determined solely by us, we will notify you, for example via email. The current version will always be posted to our Privacy Addendum.

If you have any questions about this Privacy Addendum, or wish to exercise any of your privacy rights, please contact us at privacy@fdeco.com or at any of the methods described above.

FDE Privacy Notice

Table of Contents

I. Introduction

II. Who are we?

III. Who does this Privacy Notice protect?

IV. What information will we collect?

V. Why do we process your Personal Data?

VI. Who do we send your Personal Data to?

VII. What will FDE do if my Personal Data is breached?

VIII. Will my Personal Data be transferred to another country?

IX. How long will FDE store my Personal Data for?

X. Sending FDE Personal Data over the internet

XI. How we collect and aggregate information about visitors to our Websites

XII. Technology and Tools

XIII. Links to other websites

XIV. Changes to our Privacy Notice

United Kingdom Addendum

ICO regional offices

European Economic Area & Swiss Addendum

United States of America Addendum

US State Data Privacy Laws