Privacy Policy

Firefly Partners LLC, on behalf of its affiliates and subsidiaries (collectively, “Firefly Partners,” “us,” “we,” or “our”) has prepared this Privacy Policy (this “Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you”) our practices regarding the personal information that Firefly Partners collects, uses, and shares on behalf of end users (“Users”) of our website available at http://www.fireflypartners.com or other websites operated by Firefly Partners (each, the “Website”).  Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in the Terms of Service, located at https://fireflypartners.com/terms-of-service/.

Firefly Partners reserves the right, at any time, to modify this Privacy Policy.  If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.  Your continued use of the Website following posting of changes constitutes your acceptance of such changes.        

1. COLLECTION OF PERSONAL INFORMATION
   • Personal information you may provide to us through the Website or otherwise includes:

• Contact and profile details, such as your first and last name, preferred pronouns, email and mailing addresses, and phone number.
• Business and employment data, such as such as the company you work for, company description, job title, salary information, LinkedIn profile related information, and other information included in a job application.
• Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
• Cookies and internet activity, such as text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns.
• Marketing data, such as your preferences for receiving communications about our Content, Services, activities, events, and publications, and details about how you engage with our communications.
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed on the Website at the time of collection.
• Deidentified or Aggregate Information – Personal information does not include Deidentified and Aggregate Information. “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which Firefly Partners has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.
• Sources of Personal Information. We obtain personal information from the following categories of sources:
• Personal Information You Provide. Firefly Partners collects personal information when you voluntarily submit it to us, including when you fill out our contact form or submit a job application to us.
• Personal Information that is Automatically Collected. In addition to personal information that we may receive directly from you, Firefly Partners indirectly collects other information from you automatically, such as log information about you, your computer or mobile device, and your activity over time on our Website, and other sites and online services.
• Personal Information Obtained from Third Parties. Firefly Partners may receive personal information about you from other third-party sources, including from business partners or data providers.  We may merge or combine such personal information with the personal information we collect from you directly or automatically.

2. USE OF PERSONAL INFORMATION

Firefly Partners’ primary purpose in collecting personal information is to provide the Services and Content that you request on the Website.  Firefly Partners may also use personal information for various purposes, including without limitation:

• Fulfilling your requests for Services
• Understanding and analyzing the usage trends and preferences of our Users to make our Website better, diagnose technical issues, prevent fraud, and develop new features and functionality.
• To personalize your experience on the Website and to deliver information about offers relevant to your interests.
• To verify your identity or determine your eligibility for offers and promotions.
• To communicate with you, including responding to any of your requests or questions.
• To provide Users with maintenance and support including responding requests for customer support or responding to your Feedback or requests that you make though the Chat Service available on the Website.
• To send you materials, updates, information, special offers, and promotional material from us and from other Users and our business partners using direct marketing or behavioral-based advertising.
• To respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

3. SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, Firefly Partners may share your personal information in the following circumstances:

• Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us).  In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
• Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.
• Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws.  We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.
• Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Website.  Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy.  
• Behavioral-Based Advertising Partners. We participate in behavioral-based advertising.  This means that a third-party advertising company may use technology (e.g., a cookie) to collect information about your use of our Website so that we can provide advertising about Content and Services tailored to your interest.  That advertising may appear either on our Website, or on other websites. 

4. SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure.  While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.  In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

5. YOUR CHOICES

You can make the following choices regarding your personal information:

• Modifications to Your Personal Information. If you wish to update or correct your personal information, please contact us as described below.
• Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Website, as well as targeted offers from third parties.  You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below.  If you decide not to receive promotional e-mails, we may still send you service-related communications in order to fulfill orders for offers you have requested or deliver notifications directly to you through the Website.
• Behavioral-Based Advertising. We participate in behavioral-based advertising.  This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Website so that we can provide advertising about Content and Services tailored to your interest.  That advertising may appear either on our Website, or on other websites.  If you wish to limit third parties’ collection of information about your use of our Website, you can opt-out of receiving behavioral-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp or optout.aboutads.info.  Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.  ADDITIONALLY, PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE WEBSITE.  IT WILL, HOWEVER, EXCLUDE YOU FROM BEHAVIORAL-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
• Do-Not-Track. Some web browsers and devices permit you to broadcast a preference not to be “tracked” online.  We currently do not respond to a “Do Not Track” signal.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

6. NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Firefly Partners are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes.  This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses.  If you are a California resident and would like a copy of this notice, please submit your request to the address listed in the section titled “CONTACTING US” below.

7. OTHER SITES AND SERVICES

The Website may contain links to other websites and online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or online services that are not associated with us.  We do not control third party websites or online services, and we are not responsible for their actions.  Other websites and services follow different rules regarding the collection, use, and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and online services you use. 

8. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Firefly Partners is based in the United States of America.  If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America.  By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms of Service.

9. CONTACTING US

If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at [email protected].

Last Updated: April 23, 2021