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Privacy Policy

Privacy Statement

LAST UPDATE: 12/30/2019

FormFire Security and Privacy Promise for the Individual

 

At FormFire, LLC (“FormFire”, “we”, “our”, and “us”), we place the highest importance on respecting and protecting the privacy of our customers. Our most important asset is our relationship with you. We want you to feel comfortable and confident when using our website. Therefore, we would like to share with you the following principles that govern our information practices and other privacy aspects of our website. This Security and Privacy Promise (the “Policy”) applies solely to personal information collected through the FormFire website, online services, applications, and web pages that post, specifically reference, and incorporate this Policy (all of the foregoing, collectively, the “Site”), whether accessed via computer, mobile device, or other device (collectively, “Device”). Throughout this policy, we refer to information that personally identifies you as: “personal information” or “personal data.”

This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site. Please read this Policy carefully, because by accessing and using this Site you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review our Terms of Use, which governs your use of this Site.

Consent

You hereby agree with and consent to the collection and processing of your personal information as described in this Policy.

Your personal information will be collected, processed, and stored by FormFire or its services providers in the United States.

You have the right, at any time, to withdraw your consent to FormFire’s collection and processing of your personal information. You may withdraw your consent by emailing FormFire at privacy@formfire.com.

Collection and use of Personal Information

As you interact with FormFire, there may be opportunities for you to provide us with your personal information.  When we track activity on this or other FormFire websites, we collect information such as your IP address, browser type and version, and pages you view. We also keep track of how you get to our sites and any links you click on to leave our sites. We do not track URLs that you type into your browser, nor do we track your use of the Internet once you leave our sites.

You may provide us with information about you through a number of sources: FormFire websites, applications, product and related events, surveys, social media platforms, sweepstakes entries, and through our customer contact centers.

The categories of information that FormFire collects about you may include, but are not limited to:

  1. Identifiers/Contact information (such as name, address, city, state and ZIP code, email address, telephone number, unique personal identifier, online identifier, IP address, Social Security number, driver’s license number, passport number, or other similar identifiers);

  2. Demographic information (such as gender, date of birth, marital status, and household composition);

  3. Health Information;

  4. Professional or employment related information (such as current or past job history);

  5. Non-public education information (such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records);

  6. Payment information (such as your credit card number, CVV code, and expiration date);

  7. Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our products, services, apps, and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information;

  8. Marketing profile information;

  9. Relationships you have with FormFire;

  10. Incentive eligibility information;

  11. Investor Information (name, address, phone number, and email address); and

  12. Inferences drawn from other personal information (such as personal preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).

We obtain the categories of personal information listed above from the following categories of sources:

  1. Directly form you as described herein;

  2. Indirectly from you (for example, through information we collect in the course of providing services and products);

  3. Directly and indirectly from activity on this Site; and

  4. From third-parties that interact with us in connection with the services and products we provide.

The information FormFire collects about you and your Devices may be used:

  1. To provide products and services and maintain customer relationships;

  2. To improve the quality, safety, and security of our products and services;

  3. To administer your account(s) and process your payments for products and services;

  4. To operate our websites and applications, including online registration processes;

  5. To autofill data fields on our websites or applications to improve your online experience;

  6. To develop new products and services;

  7. To provide customer support and service;

  8. For warranty administration and validation;

  9. To provide information and product/services updates;

  10. For research, evaluation of use, and troubleshooting purposes;

  11. For marketing and analytics purposes;

  12. To customize and improve communication content; and

  13. To comply with legal, regulatory, or contractual requirements.

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social media, or other electronic messages or via our websites and applications.

Personal Information you Provide

The privacy and security of the personal information that FormFire collects from you is a priority for FormFire. When you visit this Site you may be asked or choose to provide personal information that could reasonably be used to contact your or to identify you personally including, but not limited to: your name, address, telephone number, birth date, and email address. If you choose to purchase any products or use services offered on the Site, FormFire may ask you to provide your name, mailing address, telephone number, and email address, as well as certain financial information (e.g., credit card number) for the purposes of credit checks, payment, and processing of any order.

If you purchase products or services from the Site, we request that you provide your name, email address, billing address, credit card information, and any other information necessary to complete the transaction. FormFire may utilize its third party service providers to process collected financial information to fulfill purchases.

You may choose to receive certain communications from FormFire via your email address upon interaction with the Site. From time to time, FormFire may include surveys, information requests, or other features on the Site that ask you to provide personal information such as your name, telephone number, email address, or mailing address. Any information you may provide will be used by FormFire to allow you to participate in the particular feature being offered. FormFire may also retain any information you provide in order to send you information about FormFire’s products and services that may be of interest to you. FormFire will provide you with the opportunity to opt-out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.

When we ask you for information, we will tell you – or it will be clear – what we need to know to fulfill your request together with how the information you provide to us will be used. By submitting personal information to FormFire at this Site, you hereby consent to FormFire’s collection, use, and disclosure of such personal information.

We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

Passive Information Collection and Use

As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:

  1. Through your browser and Device: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We collect Device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your FormFire account.

  2. Cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on this Site, pages visited, and language preferences. We and our service providers use the information for security purposes, to facility navigation, and display information more effectively. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it.

You can choose to accept or decline Cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browser will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. If you sent your browser to reject cookies, part of the Site may not work for you.

  1. Pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.

  2. IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Address for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

  3. Do Not Track Requests: Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively management the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.

We protect your information

We work to protect your personal information from loss, misuse or unauthorized alteration by using industry-recognized security safeguards. We use both internal and external resources to review our security procedures. Our employees are trained and required to safeguard your information.

How We Use and Disclose Personal Information

We may disclose personal information that we collect or you provide as described in this Policy. The information may be disclosed for a business purpose to the following categories of third parties:

  1. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

  2. To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them; and

  3. To our affiliates for our related business purposes.

We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit payment credit card information, (3) submit your name and e-mail address to receive updates and marketing information, and (4) send e-mail messages or feedback, or transmit other information by e-mail. When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including ZIP code), e-mail address, mobile telephone numbers, and payment information.

We also use and transfer personal information from or about you:

  1. To respond to your inquiries and fulfill your requests, such as to send you document you request or e-mail;

  2. To send you important information regarding our relationship with your or regarding this Site, changes to our terms, conditions, and policies, and/or other administrative information;

  3. For our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our Site;

  4. To our third party service provides who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;

  5. To verify your information, approve your registration as a user of the Site, authenticate payments and process orders, FormFire may disclose certain financial and other information you provide to FormFire to third parties offering products and services for sale on the Site, as well as to third parties that provide credit reporting, payment, or order fulfillment services;

  6. To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business assets or stock (including in connection with any bankruptcy or similar proceedings); and

  7. When we otherwise have your consent.

In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our Terms of Use https://www.formfire.com/interview/termsofuse; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent.

We also use and disclose information we collect passively as described above, under "Passive Information Collection and Use," and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

 

We do not sell or rent your personal information to anyone. In the preceding twelve (12) months, we have not sold any personal information.

We tell you how we use Web technology

Like many websites, we use technology, such as cookies, that allow us to make your visit to our website easier by recognizing you when you return and help to provide you with a customized experience.

For more information see: https://www.hhs.gov/hipaa/index.html

More about how we protect your information

We protect the confidentiality and security of your personal information by using industry-recognized security safeguards such as firewalls, coupled with carefully developed security procedures and Internet security providers to protect your information from loss, misuse, or unauthorized alteration. Our employees are trained and required to safeguard your information and, using physical, electronic and procedural safeguards, we restrict access to personal information to those employees and agents for business purposes only. Additionally, we use internal and external resources to review the adequacy of our security procedures.

Although they may be difficult to identify, you may receive hoax e-mails (e.g.: “information” e-mails) that look authentic and appear to have been sent by a company you recognize. These e-mails ask you to provide or confirm your sensitive personal information by clicking on links. To entice you, they often claim an urgent or threatening condition concerning your account or offer you a prize.

You should not reply or click on any links in the e-mail or provide any personal information without first verifying that the source of the e-mail is legitimate through some other existing communications channel that you already know.

FormFire does not solicit sensitive customer information via e-mail. If you do receive an e-mail message that appears to come from FormFire that requests such information, please forward it immediately to security@formfire.com so that we can respond quickly to mitigate potential damage.

Personal information will be collected, stored, processed, and transmitted in accordance with FormFire’s established policies and applicable federal, state, local, and foreign laws, rules, and regulations.

The principles of FormFire with respect to the processing of personal information are as follows:  (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by FormFire will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by FormFire will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by FormFire will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

If FormFire engages in the processing of personal information for purposes other than those specified in this Policy, FormFire will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.

 

More about our relationships with third parties

Sometimes, we enter into contracts with third parties (e.g., Security Testing, Secure Data Housing, and Secure Data Disposal) who assist us in servicing you. The contracts outline the appropriate use and handling of your information and prohibit third parties from using any of your personal information for purposes unrelated to the service for which they’ve been contracted. Vendors are required to maintain the confidentiality of the information we provide to them. We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required under the law. For example, we may be required to disclose personal information to cooperate with regulators or law enforcement authorities, to comply with a legal process such as a court order, subpoena, search warrant, or a law enforcement request.

Should we sell, merge or transfer any part of our business, part of the sale may include the transfer of your personal information. If so, you will have the opportunity to ask not to receive promotional information following any change of control.

We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site.  For example, we use advertising services providing by third-party ad partners, such as Google, to market our service to you on other websites and online services.  Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity.  To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal.  Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.

We utilize Google Analytics on the Site. Google Analytics is a website analysis service provided by Google, Inc. (“Google”). Google utilizes the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more information on Google’s Privacy Policy go to https://www.google.com/intl/en/policies/privacy/. Users can opt-out of Google Analytics tracking at https://tools/google.com/dlpage/gaoptout/.  Some additional Google Analytics features that FormFire uses are:

  1. Google Analytics Demographics and Interest Reporting – allows FormFire to see the age, gender and interests of website visitors to better understand them and personalize advertising.

  2. Google Display Network Impression Reporting – for banner ads.

  3. Remarketing through Google Analytics for Display Advertising – allows personalization of ads on our ad networks.

  4. User ID Extension for Google Analytics – allows FormFire to connect multiple devices, sessions and engagement data.

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

 

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.

Third parties may offer products and services on the Sites and collect information about you by requesting certain information necessary to provide a particular product or service. FormFire may also obtain certain information about its users from third party customer research groups (e.g., demographic information) which FormFire uses to learn more about its customers. FormFire does not control the policies and practices of third parties in relation to the use and disclosure of any information about users collected by third parties on the Site or in market research programs conducted by such third parties and any use or disclosure of such information by third parties is not governed by this Policy.

Choices and Access

We give you choices regarding our use and disclosure of your personal information. FormFire provides you with the opportunity to receive information by email, regular mail or telephone calls from FormFire, or third parties which may be of interest to you, including information relating to new products and services offered on the Site by FormFire, or other third parties.  If you do not want to receive any information by email, regular mail or telephone calls, you may opt-out of further communications provided by FormFire at any time by: (i) sending FormFire an email at privacy@formfire.com; or (ii) writing to FormFire at 1100 Superior Avenue, Suite 1650, Cleveland, Ohio 44144, Attention: Chief Privacy Officer. Please note that FormFire can only comply with requests relating to email, regular mail or telephone communications provided by FormFire. If you no longer wish to receive further information by email, regular mail or telephone from any third party, you will need to contact such third party directly to opt-out of further communications being provided to you.  We will seek to comply with your request(s) as soon as reasonably practicable. 

If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us.  We will try to comply with your request as soon as reasonably practicable.

Accuracy

It is your responsibility to provide FormFire with accurate personal information.  Except as otherwise set forth in this Policy, FormFire shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you.  To the extent necessary for these purposes, FormFire shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.

Your Rights Over Your Information

By law, you have a number of important rights. In summary, those include the following:

  1. Fair processing of your personal data and transparency over how we use your personal data;

  2. Access to your personal data and to certain other supplementary information that this Policy is already designed to address;

  3. Require us to correct any mistake in the information which we hold;

  4. Require the erasure of personal data concerning you, in certain situations;

  5. Receive the personal data concerning you that you have provided to us, in a structured, commonly used, and machine readable format, and have the right to transmit that data to a third party, in certain situations;

  6. Object at any time to processing of personal data concern you for direct marketing;

  7. Object to decisions being taken by automated means that produce legal effects concerning your or similarly significantly affect you; and

  8. Object in certain other situations to our continued processing of your personal data.

If you would like to exercise any of these rights, please email, call, or write to us with the following: (1) enough information to identify you; (2) proof of your identity and address; and (3) the information to which your request relates.

California Specific Privacy Rights

The California Consumer Privacy Act (the “CCPA”) grants users of our Site that are California residents certain rights in regards to our collection of personal information. These rights include:

  1. The right to request the disclosures of (1) what personal information has been collected; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collection or selling personal information; (4) the categories of third parties with whom the business shares personal information; and (5) the specific pieces of personal information FormFire has collected;

  2. The right to request the deletion of their personal information that has been collected; and

  3. The right to opt-out of the sale of their personal information.

Under the CCPA, a data subject may only make a personal information request twice in a 12-month period. FormFire will respond to such personal information request within 45 days of receiving the personal information request.

Additionally, if you are a California resident, you have the right to request information from FormFire regarding the manner in which FormFire shares certain categories of your personal information with third parties, for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to FormFire at its designated address and receive the following information:

  1. The categories of information FormFire disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and

  2. The names and address of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed

You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. You may make such a request by calling (216) 367-9730.

Other Areas

Data Transfer: We use industry-recognized security safeguards during the transmission of this data.

Electronic Archiving of Information: All relevant information will be stored in both data form and PDF form for a minimum of 1 calendar year. It is held in accordance with applicable laws in order to provide the medical application form filing services that have been requested. We do not use the content of your data or PDF files for any other purpose.

Customer Service and Technical Support: During the Customer Service and Technical Support Process, we can request certain contact information including your name, address, last 4 digits of your social security number, phone numbers, and e-mail address. We use this personal information to contact you to answer your question or resolve your issue. We do not use this information for marketing purposes.

Internet Chat: We offer various Internet Chat services, for example, to contact a FormFire support representative or advisor. Our Internet Chat sessions are encrypted. A transcript of the session is generated and retained and may be used to resolve your current and potential future questions.

Feedback Center: When using our Web site, you can ask us questions and share comments or suggestions with us. Your personal information will only be used in the event we need to respond to your question or comment. If you elect to participate, we may send you information about upcoming FormFire forums and related activities.

Exercising Your Rights

To exercise your rights as described herein, you may submit a verifiable consumer request to us (as described above) by either contacting us via the contact methods provided in the contact section below or by visiting [WEBPAGE LINK/APP LINK TO CONTACT FORMFIRE RE DATA SUBJECT RIGHTS]. FormFire will not discriminate in any way against any users of the Site that exercise their rights provided by law.

Security

FormFire has implemented security measures designed to protect personal information provided by you against unauthorized access and use. FormFire also uses commercially reasonable efforts to establish secure connections with your web browser for any transactions conducted online using a credit card or other financial information you may provide to FormFire. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the contact section below.

Use of the Site by Minors

We do not intentionally collect information from individuals under the age of 13.  The Site is not directed to individuals under the age of 13 and we request that these individuals not provide personal information through this Site.

Compliance with Local Laws

This Policy is meant to guide FormFire with respect to personal information collected from or about you at this Site.  While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to FormFire (“Local Laws”) may require standards which are stricter than this Policy and, in such event, FormFire will comply with applicable Local Laws.  Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. Your personal information will be stored and processed in the United States. We only share your personal data under a ‘need to know’ basis. 

Updates to this Privacy Policy

We may change this Policy.  Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised.  Any changes to this Policy will become effective when we post the revised Policy on this Site.  Your use of this Site following these changes means that you accept the revised Policy.

Compliance

FormFire will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal information has been processed or disclosed in violation of this Policy, FormFire encourages you to raise any concerns using the contact information provided in this Policy.  FormFire will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

Your Right to Complain

If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority, the California Attorney General, any other governmental agency, and/or a judicial body.

A complaint may be submitted directly to FormFire:

  • In writing by sending an email to privacy@formfire.com;

  • In writing by sending a letter to 1100 Superior Avenue, Suite 1650, Cleveland, Ohio 44144; or

  • Orally by directly contacting (216) 367-9730;

You can contact us

If you have privacy-related questions that are not addressed here, please contact or write to us at:

FormFire, LLC
1100 Superior Ave., Suite 1650
Cleveland, OH 44114. USA.

Email: privacy@formfire.com

Phone: (216) 357-7400

If we make material changes to any of our privacy policies or practices regarding personal information we will update our statement and post a notice on our website 30 days before they take effect.