Privacy policy

Functional Fluency International is dedicated to developing great tools and services that help our users to be more effective, productive, and successful in their personal and professional lives. We are convinced that a fair relationship with our users is very important. Therefore, we are fully committed to maintaining the security, confidentiality, and privacy of your personal information and to communicate how we collect and process data transparently.
 
This is our Privacy Policy and Cookie Policy. It documents our on-going commitment to you. We update our Privacy Policy and Cookie Policy from time to time so please do review this Policy regularly. This Privacy Policy provides you with details of how we collect and process your personal data through your use of our site www.functionalfluency.com and TIFF© Online.

^{What Personal Data We Hold}

We may collect some, or all, of the following personal data, according to your relationship with us:

• Name, age and gender
• Contact information - email address, address, telephone number
• Employment information – occupation, job title, type of employer, management responsibility
• Responses to the TIFF questionnaire.  (Some of your personal data may have been obtained by a third party, namely from your TIFF Provider, your name, email address and country of residence.)
• Information about your use of our websites, such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.

 
^{Use of Your Information}

In accordance with the General Data Protection Regulation (GDPR) we must always have a lawful basis for using your personal data. This may be because the data is necessary to fulfil a contract with you, because you have consented, or for our legitimate business interests.  We may use your personal data for one, or more, of the following purposes:

• To supply our services and/or products to meet your requests. 
• Communicating with you, to supply you with information to which you have consented, in a way that you have chosen, and/or to respond to requests from you.

In order to fulfil the above purposes, we may transfer your data to one, or more, of the following third parties:

• TIFF Providers, Functional Fluency trainers and Connectors (with whom we have Joint Data Controller contracts)
• Cloud Services, IT professionals and accountants with whom we hold contracts for TIFF Online, email provision and accountancy software.
• In some limited circumstances, we may be legally required to share certain personal data to comply with legal obligations, a court order, or the instructions of a government authority. 

For further information about the TIFF questionnaire in relation to the use of your information please view our Privacy Statement TIFF questionnaire which you can download via the files link below.

^{Retaining Your Personal Data}

This is the length of time that we will continue to process or store your personal data:

• Enquiries that do not lead to further action, or clients who do not complete allocated TIFF questionnaires - 1 year
• Clients who have completed TIFF – 7 years (to enable clients to continue or re-establish contact with a TIFF Provider and make use of their TIFF Profile for further personal development.)

In operating our websites and associated applications the data we collect is stored in locations within the European Union, and in compliance with the relevant international standards.

^{Use of Cookies}

Cookies provide information regarding the computer used by a visitor. A cookie is a small file which asks permission to be placed on your computer’s hard drive. The cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We may use cookies where appropriate to gather information about your computer in order to assist us in improving our website, while giving you the best possible user experience. Using cookies means that you may not have to enter your login details every time you visit secure parts of the website.
You can select “Accept” to consent or select “settings” to review further. You can adjust the settings on your computer to decline any cookies if you wish.  This can be done by activating the reject cookies setting on your computer.

^{Your rights in respect of our processing your personal data:}

• To request a copy of the personal data we hold
• To rectify your personal data that is incorrect
• To request we erase your personal data
• To object to or restrict our processing of your personal data
• To request your personal data be transferred by automated means to another system

To exercise any of these rights, please contact us using the details below

Functional Fluency International
Feijenoordkade 23-a
3071 HM Rotterdam
The Netherlands                                

Email – info@functionalfluency.com

In addition, you also have the right to submit a complaint about our processing of your personal data to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via its website: https://autoriteitpersoonsgegevens.nl/en

July 2021