Terms & Conditions

On this page you will find Fuel50’s most current Master Services Agreement (MSA) as well as a summarised disclaimer for the use of this website, plus privacy and GDPR information for all users.

Fuel50 Terms & Conditions (MSA)

This Fuel50 Master Services Agreement, including all schedules and policies attached or referenced herein (collectively, “Agreement”) governs all use of products and services provided by Career Engagement Group, including but not limited to Fuel50 CareerDriveÔ, the web-based, interactive career-management application delivering career growth and pathing tools, as well as the Website and certain training career development based programs, workshops, and coaching programs.

This Agreement is entered into between Career Engagement Group or its Affiliate as may be specified in an applicable Order (“Fuel50”) on the one hand, and the individual or entity accepting this Agreement on behalf of itself and its Affiliates (“Client”) on the other hand.  Fuel50 and Client are each a “Party” and collectively, the “Parties.”  This Agreement is deemed accepted and becomes effective upon access to or use of the Website, Services or Products or as specified in a mutually-accepted Order between the Parties.

Read the full Terms & Conditions (PDF) here

Website Disclaimer

By using this website, you accept the following:

  • Cookies are used on this website to anonymously track your experience and ensure we can offer our visitors the best experience possible;
  • Fuel50 does not store any information other than what is submitted via an explicit opt-in;
  • By downloading any of our content and thus submitting this information to us, a member of Fuel50 may directly reach out to you to provide further support relating to that particular piece of content;
  • If you opt-in, you may unsubscribe at any time using the links within the footer of every email;
  • You may also reach out to us at any time to change your subscription details, or to request any / all information we have on file. We will honour any requests to forget you and will completely erase any or all of your personal information upon such requests.

Website Privacy & GDPR

This information is relative to this website (fuel50.com) and its subdomains. For Fuel50’s Security, Trust and Privacy Policies relative to its SaaS platform (“Fuel50”, “Fuel50 CareerDrive”) click here .

Any user continuing to use this website agrees to the following terms, conditions, and privacy policies. If you do not agree with any of the below, please discontinue using this website.

This privacy agreement has been compiled to better serve those who are concerned with how their personally identifiable information (PII) is being used online. PII is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this privacy agreement carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What information do we collect from the people that visit this website?

We do not collect any information from casual visitors to our site other than anonymous tracking data controlled by Google Analytics.

This data could include your browser type (IE, Chrome, Firefox etc), the time you spend on this site, and the country you are viewing this site from. Remember, this data is purely anonymous and is used to better improve our website and brand.

If a visitor decides to interact with our downloadable content this could require the submitting of PII. This information is generally limited to name, email, job title, company, state, country, email address and phone number. You have the freedom to not give us this information, but by submitting this information you agree to certain parts of this privacy policy.

When do we collect (PII) information?

We only collect personally identifiable information from you when you fill out a form on our website.

How do we use your information?

We may use this in the following ways:

  • To send you periodic marketing emails
  • To quickly process event registrations along with relevant communications for these transactions.

How do we protect visitor information?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We also use an SSL certificate.

Cookies

This website uses cookies to track experience usage. These cookies are used to:

  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf (such as Google Analytics);
  • You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies through your browser’s settings.

We never give your information to any third-parties

We do not sell, trade, or otherwise transfer to any untrusted outside parties your personally identifiable information.

Google Advertising

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users (read more here). We have enabled demographics and interests reporting on an occasional basis to improve our advertising efficiency.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA, we agree to the following:

  • Users can visit our site anonymously
  • This policy is viewable from any page on this website (footer)
  • Our Privacy Policy link includes the word ‘Privacy’ and can be easily be found
  • Users will be notified of any privacy policy changes on this page
  • Users are able to change their personal information by contacting us directly

How does our site handle “do not track” signals?

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

We do not allow third-party behavioral tracking outside of anonymous cookies managed by Google Analytics and Adwords.

Opting-in, CANSPAM & Marketing Emails (GDPR-compliance)

We are proud to be GDPR-compliant on a global level as well as a company that highly respects the CAN-SPAM Act. CANSPAM is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address and other clearly labelled information when you choose to interact with our downloadable or exclusively available content on this website.

  • This information is sent as a one-time notification to our marketing team so we know who engaged with our content;
  • The information is also sent by secure API to Hubspot and SalesForce as part of our opt-in process;
  • By submitting this information, a member of our direct team may personally reach out to you regarding that specific piece of content.

We will only add you to our marketing email chain if you check the clearly labelled subscription box at the bottom of a form. When you tick this box, your information is stored in our secure, third-party email platform transferred via a secure API. When you have opted-in:

  • We generally aim to only send marketing emails once a week;
  • Our marketing emails are primarily research-based;
  • You may unsubscribe or opt-out at any time using the links within our marketing emails;
  • You may request any/all information we have on file, as well as requesting complete deletion of any/all information.

To be in accordance with CANSPAM we agree to the following:

  • Not use false, or misleading subjects or email addresses;
  • Identify the message as an advertisement in some reasonable way;
  • Include the physical address of our business or site headquarters;
  • Monitor third-party email marketing services for compliance (if one is used);
  • Honor opt-out/unsubscribe requests within 2 working days;
  • Allow users to unsubscribe by using the link at the bottom of each email;

Contacting us

If there are any questions regarding this privacy policy or any other terms or conditions, you may contact us using the information below:

Fuel50
3-5 Auburn Street
Takapuna, Auckland
New Zealand
Email

See all offices and contact details

Career Engagement Group Fuel50 Privacy Policy

Updated: October 16, 2023

Introduction

This Privacy Policy explains how Career Engagement Group d/b/a Fuel50 (“Fuel50”) processes your personal information, and how you can exercise your privacy rights.

The Policy relates to the personal information we collect when you visit and use https://www.fuel50careerdrive.com and any of their subdomains (the “Site(s)”), as well when you use any of our software, products, mobile versions, or services (including Products or Services as defined in our Terms of Service) that link to this Privacy Policy. For purposes of this Privacy Policy, the Sites and such products, software and services are referred to collectively as the “Fuel50 Services.” This Privacy Policy also applies to information provided to us through other online and offline communications with our personnel.

This Privacy Policy is expressly incorporated into our Terms and Conditions (“Terms”). When you use the Fuel50 Services, you agree to our Terms and to the use of your information as outlined in this Privacy Policy. If you have questions about this Privacy Policy, contact us at privacy@fuel50.com.

1. Who We Are

Fuel50 operates interactive career engagement platforms and services. Fuel50 is the data controller for the personal information that we collect and process through the Fuel50 Services. In some instances, Fuel50 only acts as a “processor” of your information and may not be the “controller” of the information (which may be our Client). This is the case in relation to the information you or your employer might upload about you to a Fuel50 platform or product. You may be required to reach out to the Client directly to remove your information from their databases as well as Fuel50’s.

2. The Information This Policy Applies To

Your “Personal Information” means any data relating to you which identifies you (such as your name, email address, or other similar information) or could indirectly identify you (such as an identification number or an online identifier).

This Policy only reflects how Fuel50 processes Personal Information through the Fuel50 Services. It does not apply to our Clients’ use of data, or the use of your data by any third party (for example, when you visit a third-party website or interact with third-party services, such as social media or a payment processor). You should review those third parties’ privacy policies before you use any of their services (“Third Party Services”).

3. Our Legal Basis for Processing Personal Information

Fuel50’s legal basis for collecting and using the Personal Information described in this section depends on the information we collect and the specific context in which we collect it.

We consider that the legal bases for using your information as set out in this Privacy Policy are as follows:

a) our use of your information is necessary to perform our obligations under any contract with you or for your benefit or to take steps to enter into a contract with you or for your benefit (for example, to provide you with Fuel50 Services or to comply with the terms of use of our Site, which you accept by browsing our Site); or

b) our use of your information is necessary for complying with our legal obligations (for example, if you contact us requesting access to information we hold about you); or

c) where neither (a) nor (b) apply, our use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Site). Our legitimate interests are to:

    1. run, grow and develop our business and improve the Fuel50 Services;
    2. operate our Site;
    3. provide Fuel50 Services to our customers, make and receive payments and provide customer services;
    4. invest in and roll out new products to benefit the communities in which we operate; and
    5. for internal group administrative purposes.

4. What Information We Collect

We handle all Personal Information provided to us with the utmost care and we only collect the information we really need to provide our products and services. You may voluntarily provide us with your information, or we may also receive information about you from your employer (third party). We may also collect information from you using a variety of technologies that automatically and passively collect information when you use our Site.


a. Information You Provide to Us

At touchpoints throughout your use of the Fuel50 Services, we collect Personal Information directly from you, such as:

  • Information that you share via a free text field, or other unstructured format on the Site (please note that we do not collect consumer information via the Site’s Contact Us function unless you provide it);
  • Photos and/or videos that you upload through the Site(s), including audio recordings sent via customer service calls;
  • Information that you share during our product research calls;
  • Other information that could reasonably be used to identify you personally or identify yourhousehold or device.

We may also obtain information from you where you expressly provide us with the information. Examples of sources from which we collect information include telephone calls with you, letters, e-mails or other communications from you, information provided via online chat or support services, web forms or inputs/uploads into our Site, documents you have provided to us, or references and referrals provided to us in connection with your employment application.

You do not have to provide us with the information above, but if you choose not to you may not be able to take advantage of all the features of the Sites or the Fuel50 Services.


b. Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Sites (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Sites. Usage Information may include:

  • Your name, email address, job position, and position within your organization’s company hierarchy
  • Your IP address, MAC address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Sites that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Sites or the Fuel50 Services;
  • Your Device characteristics; and
  • Certain other Device data, including the time of day you visit our Sites or other information used to provide analytics or other usage information.

If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access the Site(s), or certain features, services, content, promotions, or products may be limited or disabled.


i. Cookies and Other Tracking Technologies

We collect certain information through the use of “cookies,” which are small text files that are saved by your browser or device when you access our Sites or the Fuel50 Services. We may use both session cookies and persistent cookies to identify that you have logged into our Site, and to tell us how and when you interact with our Site. We may use cookies to store your preferences and other information on your computer, in order to save you time by eliminating the need to enter the same information repeatedly. We may also use cookies to monitor aggregate usage and web traffic routing on our Site and to customize and improve our Site.

For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy here.


ii. Do Not Track Signals

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. There is no universally agreed-upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.


c. Information from Third Parties

The Sites and Fuel50 Services may include functionality that allows certain kinds of interactions between you and third parties. The use of this functionality may involve the third-party site providing your Personal Information to us or us providing your Personal Information to the third party. Our receipt of this information is always controlled by a written agreement that contains specific provisions about our ability to use your information. For example, your employer may provide certain Personal Information to us in order to create an account for you or we may provide links on the Site(s) to facilitate emails or postings to social media (like a “Share” or “Forward” button for Facebook, Instagram or LinkedIn). These third parties may retain any information used or provided in any such communications or activities and their privacy practices may be subject to different Terms or Privacy Policies. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices.

5. Children’s Privacy

Fuel50 takes children’s privacy seriously. Our Fuel50 Services are not directed to persons under the age of 18, and we do not request, or knowingly collect, Personal Information from any person under 18 years of age. If you are under 18 years of age, please do not submit any Personal Information through our Site. If we learn that we have collected Personal Information from a minor, we will take steps to delete such information from our files as soon as possible.

Please contact us at privacy@fuel50.com to request deletion if you are aware that we may have inadvertently collected Personal Information from a minor.

6. How We Use Your Information

We may use your information for various purposes, including the following:

  • Customizing your experience on the Site(s);
  • Sending Fuel50 Services communications via email;
  • Responding to your requests for information;
  • Providing the products or Services to you;
  • Verifying your identity and for fraud prevention;
  • Providing you with updates and information about products and Services we provide;
  • Sending you email communications such as electronic newsletters about the Fuel50 Services, events and promotions, as well as periodic customer satisfaction, market research or quality assurance surveys that may be of interest to you;
  • Improving the effectiveness of the Fuel50 Services, our marketing endeavors, and our product and service offerings;
  • Helping us address problems with and improve our Site(s) and our products and Services, including testing and creating new products, features, and services;
  • Providing mobile marketing messages and other communications and messages;
  • Protecting the security and integrity of the Sites, including understanding and resolving any technical and security issues reported on our Sites;
  • Engaging in analysis, research, and reports regarding the use of our Sites and the Fuel50 Services;
  • For internal business purposes (including but not limited to internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the safety of company facilities, research and development, business efficiencies);
  • Complying with the law and protecting the safety, rights, property or security of Fuel50, the Services, and the general public; and
  • For other purposes disclosed at the time you provide your information or as otherwise set out in this Privacy Policy.

7. When We Disclose Your Information

We may share your information with the following categories of third parties:

  • Your Employer (if your account is provided by your employer). We may provide certain information about you to your employer’s Human Resources administrator or other representative, including but not limited to your self-rated skills/values/work preferences, your feedback to other employees about their skills, your mentors or mentoring requests, information about your goals and your development actions (e.g., progress percentage, dates of completion and/or statuses), your target job positions, your login events, or your performance ratings. We may also provide your employer with aggregated or anonymized information regarding employees using the Fuel50 Services.
  • Our Service Providers. We may employ third-party companies and individuals to administer and provide Fuel50 Services on our behalf (including, without limitation, maintenance, administration, support, hosting, marketing (including email marketing) and database management services). As permitted by law, we insist that these partners follow the same rules and standards with respect to your information as we do, and we typically have a contractual agreement in place with the other party which prohibits them from disclosing or using the information other than for the business purposes for which it was disclosed.
  • Compliance with Laws and Law Enforcement; Protection of Rights and Safety. Fuel50 cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will use, and disclose any information about you to government or law enforcement officials, state or federal agencies, or private parties as we, in our sole discretion, believe necessary or appropriate to respond to lawful and valid claims and legal process (including but not limited to subpoenas and court orders), to protect the property and rights of Fuel50 or a third party, to enforce our legal agreements (including this Privacy Policy), to protect the safety of the public or any person, or to prevent or stop any activity that we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
  • Business Transfers, Affiliates and Joint Ventures. Fuel50 may transfer your information in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. We may share your information with our parent company, subsidiaries, joint venturers or other companies under a common control that we may have now or in the future, in which case we will require them to honor this Privacy Policy.
  • In other ways we notify you about. We may also share the information we have collected about you in ways other than as described in this Privacy Policy if they are disclosed at or before the time you provide your information.
  • Aggregated and anonymized information. We may aggregate, de-identify, and/or anonymize any information collected through the Sites or the Fuel50 Services such that such information is no longer linked to you personally. We may use and share this aggregated and anonymized information (which is no longer considered Personal Information) for any purpose, including without limitation, for research, marketing and advertising purposes, industry analysis, demographic profiling, and other business purposes (e.g., by reporting on trends in the usage of our Sites or the Fuel50 Services), and may also share such aggregated data with our affiliates and third parties, including advertisers, promotional partners and others.

8. Your Rights and Choices

You have rights and choices when it comes to how we use your information, and we want to ensure you can exercise your rights and make the choices that are best for you.

We prefer to keep your Personal Information accurate and up to date. All Fuel50 users may review their Personal Information in their registration profile, by logging into their account and changing the “user preferences” associated with their account, or you may contact us via email at privacy@fuel50.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).


a. Your rights

Depending on the country you are in, you may have specific privacy rights under the privacy laws that apply. Because we operate and provide services in many countries, we have decided to provide a universal set of privacy rights to all our users, recognizing that transparency and control are important elements in building and maintaining user trust. In addition to the universal rights we list below, some countries also have specific rules we must follow. These are outlined separately where appropriate.

No matter where in the world you are, you have the following rights:

  • The right to know. You have the right to know what information is being collected about you, to confirmation of the existence of the processing, and to know who we share your information with or sell it to.
  • The right to access. You have the right to ask us for a copy of the information we hold about you. Remember, you can access most of this information directly via your registration profile.
  • The right to delete. In some cases, you may have the right to ask us to delete the information we hold about you. Please note that deleting your information may limit our ability to provide the Fuel50 Services to you. If you completely delete all information, your account will be deactivated and you may lose access to the Fuel50 Services.
  • The right of rectification or correction. You have the right to have your information rectified or corrected if you believe the information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your information.
  • The right of restriction. In certain circumstances, you have the right to request that we restrict the processing of your information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your information. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented, unless there is another legal basis for the processing.


b. Making requests about your privacy rights and choices

You may exercise any of your rights by submitting a verifiable data subject request to us using the relevant contact section below, based on your location. You may make a request related to your information, or on behalf of someone for which you have authorization. You must include your full name and email address. We may require you to confirm your identity and/or legal standing for the request. Please note that we may deny your request if we are unable to verify your identity or authority to make the request. We will respond to your request within 15 days or let you know if we need additional time.

  • If you are in the EEA – Our EU data protection representative is Pembroke Privacy Ltd of 4 Upper Pembroke Street, Dublin 2, D02 VN24, Ireland. For all issues related to data processing within the EU please contact info@pembrokeprivacy.com.
  • If you are in California – Email us at privacy@fuel50.com; call us (toll-free) on (833) 844-1103; or write to us at Fuel50, 30025 Alicia Parkway, #20-23, Laguna Niguel, CA 92677. For emails, please include “California Privacy Rights” as the subject line.
  • If you are in any other country – Email us at privacy@fuel50.com.


c. Your additional California privacy rights

This section of the Privacy Policy applies solely to California residents. We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) including as amended by the California Privacy Rights Act of 2020 (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following additional rights:

  • The right to opt out of the sale of Personal Information (as that term is defined by the CCPA) to third parties for any purposes other than to provide the Fuel50 Services you request or as otherwise permitted by law;
  • The right to opt out of the “sharing” of Personal Information (as that term is defined by the CPRA) to third parties for cross-context behavioral advertising;
  • The right to limit the use and disclosure of Sensitive Personal Information for any purposes other than to provide the Fuel50 Services you request or as otherwise permitted by law; and
  • The right not to be discriminated against, even if you exercise your privacy rights.

9. The Personal information we have processed within the last 12 months

Fuel50 collects certain types of Personal Information about you during your relationship with us, as explained above. In particular, our Site and Apps have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category of Personal Information Collected Collected Collected (Yes/No) Sources of Collected Personal Information
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers Yes You
Automatically
Your organization
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)) Yes You
Automatically
Your organization
Characteristics of protected classifications under California or federal law (for instance, gender classification/male or female), religious affiliations, etc. Yes You
Your organization
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies No You
Automatically
Your organization
Biometric information No N/A
Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement Yes Automatically
Third parties
Geolocation data Yes You
Automatically
Your organization
Audio, electronic, visual, thermal, olfactory, or similar information Yes (for customer service calls) Automatically
Your organization
Professional or employment-related information Yes (for job applicants) You
Your organization
Education information (as defined in 20 U.S.C. section 1232g, 43 C.F.R. Part 99) Yes You or your employer (third party)
Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes You
Automatically
Your organization

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

Do not sell my personal information

As a California resident, you have the right, at any time, to tell us not to “sell” your Personal Information (as that term is defined by the CCPA) to third parties for any purposes other than to provide the Fuel50 Services you request or as otherwise permitted by law. As a California resident, you also have the right, at any time, to tell us not to “share” your Personal Information (as that term is defined by the CPRA) for cross-context behavioral advertising – this is called the “right to opt-out” of the sale or sharing of Personal Information. At this time, however, we do not sell our consumers’ Personal Information to third parties other than to our Service Providers (as discussed above) in order to provide the Fuel50 Services you request, to your employer (because as discussed above, your employer, i.e., our Client, is the ultimate controller of Personal Information that you submit via their Fuel50 master account) or as otherwise permitted by law; nor do we “share” our consumers’ Personal Information for cross-context behavioral advertising. If this ever changes, we will notify you as required under this Privacy Policy. We will, however, honor your request to opt out of any marketing emails or correspondence.

Right not to be discriminated against

We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA,, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discountsor other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Any CCPA or CPRA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Third-party marketing

California’s “Shine the Light” law (CA Civil Code Section 1798.83) permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. As stated above, we are usually required to provide your Personal Information to our Clients, as they are the ultimate controllers of the information and to our service providers in order to make it available. We do not currently disclose Personal Information protected under this section to other third parties for their own direct marketing purposes.

10. Security

The security of your information is important to us. We use reasonable organizational, technical and administrative measures and follow generally accepted industry standards for the data and processing that we do, and we take all reasonable steps to protect the Personal Information we collect and hold, both during transmission and once we receive it, including without limitation:

(i) using encryption when collecting or transferring sensitive Personal Information;

(ii) limiting physical access to our premises;

(iii) limiting access to the Personal Information we hold;

(iv) ensuring that we have appropriate security safeguards to keep Personal Information secure; and (v) where required by law, destroying or de-identifying Personal Information.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.

11. Notification of personal data breaches

We have put in place procedures to deal with any suspected personal data breach and will make any legally required disclosures regarding breaches of the security, confidentiality or integrity of Personal Information, consistent with our ability to determine the scope and impact of a breach and our obligations to law enforcement and/or regulating or supervisory entities. The Global Security and Privacy Manager is responsible for maintaining and applying these procedures. If a data breach is confirmed and is likely to result in a high risk to your personal rights, we will communicate the breach to you without undue delay.

12. Retention of Personal Information

Fuel50 will only retain your Personal Information for as long as necessary to fulfill the purposes that we collected it for, including providing the Fuel50 Services, enforcing our agreements, satisfying any legal, accounting or reporting requirements and, where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been resolved. We may retain an archived copy of your information as required by law or for legitimate business purposes. Upon expiration of the applicable retention period and when required, we will securely destroy your information in accordance with applicable laws and regulations

We will also retain Personal Information, including Usage Information, for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

13. Our worldwide practices and international transfers of data

Fuel50 is a global organization, with legal entities, business processes, management structures, and technical systems that cross borders. Therefore, the recipients referred to herein can be located outside the jurisdiction in which you are located (or in which we provide the Fuel50 Services), including third countries outside the European Union (“EU“).

For transfers of Personal Data to the United States of America, Fuel50 has certified itself under the Data Privacy Framework to provide an adequate level of protection for such Personal Data.

For transfers of Personal Data to other jurisdictions that are not regarded as providing an adequate level of protection of Personal Data, we have put in place additional appropriate safeguards (such as contractual commitments) in accordance with applicable laws and regulations to ensure that your Personal Data is adequately protected, on the basis of the relevant sets of Standard Contractual Clauses (SCC’s) approved by the European Commission available for consultation here. For more information on the appropriate safeguards in place, please contact us at the details below.

14. Data Privacy Framework

On July 10, 2023, the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) entered into force. The EU-U.S. DPF Principles entered into effect as of the same date. Fuel50 complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Fuel50 has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU- U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. The Data Privacy Framework list of adhered members may be accessed here. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/

Pursuant to the Data Privacy Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@fuel50.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@fuel50.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Fuel50 commits to resolve complaints about our collection or use of your Personal Data. If you have any questions, complaints and/or other concerns, please first contact us at privacy@fuel50.com

You may also lodge a complaint with your local data protection authority or with the Data Protection Authority in the UK namely the Information Commissioner’s Office ICO.

Fuel50 has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

The Federal Trade Commission has jurisdiction over compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF for Fuel50.

If your complaint cannot be resolved through the above channels, under certain conditions you may invoke binding arbitration for some residual claims regarding DPF compliance not resolved by any of the other DPF redress mechanisms as provided in the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. For additional information, please visit https://www.dataprivacyframework.gov/s/article/ANNEX-I- introduction-dpf?tabset-35584=2.

In the context of an onward transfer of Personal Data, Fuel50 has responsibility for the processing of Personal Data that Fuel50 receives under privacy principles including the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and that Fuel50 subsequently transfers to a third party acting as an agent on its behalf. Fuel50 shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the Fuel50 organization proves that it is not responsible for the event giving rise to the damage.

Because we work with global companies and technologies, when you use the Fuel50 Services, your information may be used, stored, and/or accessed by staff and service providers based in countries outside the EEA, including New Zealand and the United States, or other countries outside of the country in which the information was originally provided. When we transfer information outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect it. As a result, if you are located outside of these countries, we are notifying you that your information may be transferred to the U.S. or outside of the EEA pursuant to the Standard Contractual Clauses or other adequacy mechanisms, or pursuant to exemptions provided under European Union laws. Note that other countries’ data protection laws may not offer the same level of protection as those in the European Union.

Further details on the steps that we take to protect your information in these cases is available from us on request, by contacting us at privacy@fuel50.com.

15. Enforcement and Dispute Resolution

Fuel50 will investigate and attempt to resolve all disputes and complaints regarding our use and disclosure of Personal Data in accordance with this Privacy Policy.

If you are a resident of the European Union or United Kingdom and your concern with Fuel50 has not been addressed satisfactorily, or if you believe we are not processing your Personal Data in accordance with applicable law or in accordance with this Privacy Policy, you have the right to file a complaint with the Data Protection Authority in the member state in which you reside.

16. Links to Other Web Sites and Services

The Fuel50 Services and our Site may contain links to other websites or services. When we link to a third-party website or service, we do not provide an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over any third-party websites or services. Other websites and services follow different rules regarding the use or disclosure of the Personal Information that you submit to them. We encourage you to read the privacy policies or statements of the other websites that you visit and services that you use.

17. Changes to this Privacy Policy

We may update and change this Privacy Policy from time to time, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. If we make any material changes to the Privacy Policy, we will notify you by email or via the Fuel50 Services or other messaging systems, or by posting an updated version of this Privacy Policy on the Site. We encourage you to periodically review this page for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Fuel50 Service. In all of the above cases, your continued use of Fuel50 Services after any notice or posted, modified Privacy Policy indicates that you have read and understood these changes.

18. Contact Us

If you have a concern or complaint about how your Personal Information has been treated by us, you may contact us at privacy@fuel50.com or by writing to us using the information on our Contact Us page.

This page is current as at 14th November 2023