Introduction

ManchesterCF (collectively “we”, “us”, “our”) values its visitors’ privacy. This privacy policy delineates what information we might collect from a registered user or other visitor (“you”), and what we will and will not do with it.

Please note that this privacy policy does not govern the transmission, collection and use of information by companies that ManchesterCF does not control, nor by individuals not employed or managed by ManchesterCF. If you visit a website that we mention or link to, be sure to review its privacy policy before sharing any information with that site.

What is personally identifiable information

“Personally identifiable information” means information that can be used to identify you as an individual, for example:

• your name, company, email address, phone number, billing address and shipping address;
• your ManchesterCF, FIU Connect or FINTEL Online user ID and password;
• payment information for transaction processing;
• any account-preference information you provide us;
• course progress and other learning data;
• your computer’s domain name and IP address, indicating where your computer is located on the internet;
• session data for your login session, so that our systems can “talk” to yours while you are logged in.

What we do with your personally identifiable information

It is always up to you whether to disclose personally identifiable information to us, although some information is required in order for us to provide online courses, for example registration for FIU Connect and payment information for FINTEL Online requires your email address and purchase of FINTEL Online modules requires credit card information.

If you do provide personally identifiable information to us, we will:

• not sell or rent it to a third party without your permission;
• use your contact details to provide you with information we believe you need to know or may find useful, such as news about our services and products and modifications to the privacy policy;
• take reasonable precautions to protect the information from loss, misuse and unauthorised access, disclosure, alteration and destruction;
• not use or disclose the information except:
  • as necessary to provide services or products you have ordered;
  • in other ways described in this privacy policy or to which you have otherwise explicitly consented;
  • in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, analytics and reporting);
  • as required by law, for example, in response to a subpoena or search warrant;
  • to external auditors who are contracted to keep the information confidential;
  • as necessary to protect the rights, safety, or property of ManchesterCF, its users, or others; this may include (for example) exchanging information with other organisations for fraud protection and/or risk reduction;
  • to allow you access to review, update, request transfer or deletion of or request ManchesterCF to stop processing your personal information;
  • to automatically delete all personal information that is not required for business purposes;
  • notify you and the appropriate privacy authority for your region within the required timeframe if we learn of a breach that compromises your personal information.

Other information we collect

We may collect other information that cannot be readily used to identify you, such as (for example) the domain name and IP address of your computer. We may use this information, individually or in the aggregate, for technical administration of our website(s), research and development, customer and account administration, and to help us focus our marketing efforts more precisely.

Cookies

ManchesterCF uses “cookies” to store personal data on your computer. If you set up your web browser so that cookies are not allowed, you might not be able to use some or all of the features of our website(s). You will be asked to provide your explicit consent before you access any areas of our site that use cookies.

External data storage and processing sites

We may store your data on servers provided by third party hosting suppliers with whom we have contracted. We have vetted the availability, information security and privacy policies of these vendors based on our information security, personal information protection and supplier governance policies developed in compliance with established information security and privacy standards and procedures. ManchesterCF only contracts with vendors that are compliant with the relevant and applicable information security requirements.

Payment processing for purchasing FINTEL Online modules is conducted through Square Inc. Square complies with all Payment Card Industry (PCI)data security standards and the European Union (EU) General Data Protection Regulation (GDPR).

You can request more information on our information security, personal information protection and supplier governance policies, as well as the relevant policies of our vendors or partners by emailing us at privacy(at)manchestercf.com.

Your privacy responsibilities

While we have developed and implemented the required policies, procedures and best practices to gain compliance with international information security standards, including the GDPR, we also need your help to protect your privacy. Please observe the following best practices to ensure the security of your personal information:

• do not share your FIU Connect or FINTEL Online user ID or password with anyone else;
• log off the FIU Connect or FINTEL Online website or lock your screen with a password when you leave your computer unattended;
• take customary precautions to guard against “malware” (viruses, Trojan horses, bots, etc), for example by installing and updating suitable anti-virus software.

Notice to European Union users

ManchesterCF‘s operations are located primarily in Canada and data centres for hosting our courses are distributed internationally. ManchesterCF has conducted the required due diligence to gain assurance that our primary hosting partners, Amazon Web Services (AWS) and Blackboard are GDPR-compliant. By providing personal information to us, you are consenting to its storage in GDPR-compliant data centres distributed internationally. Data transfers occur using an EU approved data transfer mechanism such as the EU-US Privacy Shield or the EU-approved model clauses (data transfer agreements). These mechanisms ensure that personal information is adequately protected even when leaving the EU or European Economic Area (EEA), as required by the GDPR.

Information collected from children

You must be at least 13 years old to use ManchesterCF‘s website(s) and service(s). ManchesterCF does not knowingly collect information from children under 13.

Changes to this privacy policy

We reserve the right to change this privacy policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. If you have provided us with an email address, we will notify you, by email, of any material change to how we use personally identifiable information.

Questions or comments?

If you have questions or comments about ManchesterCF’s privacy policy, send an email to privacy(at)manchestercf.com, or contact us via any of the ways described in the Contact Us page at www.manchestercf.com.