Anfluss LLC understands that privacy is important to you as a company and to your own clients. Therefore, we are committed to safeguarding the confidentiality and privacy of personal and proprietary information entrusted to us.
We encourage clients to work with us to ensure and enhance their data privacy. We prioritize the protection and stewardship of client personal privacy and proprietary information.
This Privacy Policy describes how Anfluss LLC handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business-technical-scientific advisory services in various fields (“Services”), as shall be explained in more detail.
Notice at Collection
Anfluss LLC collects the personal information described below for the purposes and for the period described below. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”). We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide Anfluss LLC with personal information about others, you are responsible for providing this notice to them.
Scope of this policy
This policy covers personal information collected or used by Anfluss LLC as a data controller, as defined by the EU GDPR and similar laws (e.g., Brazil’s LGPD, DIFC Data Protection Law 2020). California residents should review the section on their rights. Details on when personal information is collected are found under “When do we collect personal information” below.
When we provide services to clients, we sometimes handle personal information as a processor, such as hosting client data on our e-discovery platforms. This means we only process the information based on our clients’ instructions, and they retain control. If our use of your personal information is not covered by this policy, you may need to contact the client (controller) for details on the processing.
In these Privacy Practices, “Personal information” refers to information related to an identifiable individual or reasonably linked to a particular individual or household.
Anfluss LLC collects personal information from and on behalf of its clients (e.g., about their employees and customers) to provide business advisory services and manage client relationships. It also collects personal information from website visitors, job applicants, and event attendees. Anfluss LLC uses personal information to deliver services to clients, improve service delivery, contact client representatives or prospects, market its services, and manage recruitment and events.
You may have important rights regarding your personal information, depending on how and why Anfluss LLC uses it. For questions about your personal information, contact support@anfluss.com
By continuing to use this and other websites affiliated with Anfluss LLC, you acknowledge and agree to the practices described in this Privacy Policy and elsewhere on the websites, including any updates.
When do we collect personal information?
We collect information about you if:
- you use this website (or other websites and webapps affiliated with Anfluss);
- you enquire about, or engage Anfluss LLC to provide, our Services (either as an individual or as a representative for your employer or client);
- the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
- you apply for a position with Anfluss LLC;
- you attend an event or webinar hosted or sponsored by Anfluss LLC;
- you visit a exhibit booth by Anfluss LLC at a conference or industry event;
- you contact us with any other enquiry, complaint or notice.
- we acquire a company or employer, or assets of a company or employer that has your information
Types of personal information and purposes
We collect the following types of personal information for the purposes as described below.
Website Users
Anfluss LLC collects your name, address, email, phone number, and any other personal information you provide as comments when you submit an inquiry through the “Contact Us” tool. We also gather background information for career-related inquiries submitted through our website.
We may automatically collect personal information through cookies or similar technologies, such as your IP address, device identifier, browsing patterns, and clickstream data. This helps ensure the effective operation of our website and tailor our services to your needs, like showing you a local version of our site. This tracking information is stored anonymously and is used to understand trends, administer the website, and analyze user behavior.
For more details on our use of cookies, please refer to our Cookie Policy.
In certain cases, Anfluss LLC may use IP addresses to identify you if necessary to enforce this Privacy Policy, protect our services, websites, systems, and individuals, or when required by law.
Anfluss LLC’s Former, Current, and Prospective Clients
If you submit an inquiry to Anfluss LLC about our services (via the website, email, phone, or in person), we will process your name, job title, and contact information to respond to your inquiry.
When you attend an Anfluss LLC event or webinar, or interact with our colleagues at an industry event or conference, we may collect basic personal information, such as contact details, that you voluntarily provide (e.g., by filling in a form or handing over a business card) to facilitate your participation and manage our relationship with you.
If you or your organization becomes an Anfluss LLC client, we may process your personal information to:
- Conduct “Know Your Client” checks and screenings before starting a new engagement, including compliance-related information such as proof of identity, professional background, directorship history, and, in some cases, criminal convictions or adverse media coverage.
- Perform background checks to comply with anti-money laundering and terrorist financing laws.
- Handle client communication, service, billing, and administration.
- Address client complaints and administer claims.
Following applicable marketing laws, we also process personal information about our clients (former, current, and prospective) to:
- Send newsletters, promotional material, and other marketing communications.
- Invite clients to events and manage those events.
Performing Services for Our Clients
As mentioned, many of our services involve processing personal information. Typically, this information is provided to us in strict confidence, with restrictive undertakings on its use and disclosure. We encourage our clients to only share with us non-identifiable data for processing and analytics purposes. We work with clients throughout the data sharing process to minimize identification, leakage risk, and other risks to privacy.
Other Uses
If you apply for a position with Anfluss LLC, we will collect personal information to evaluate your application and during any interview and assessment phases.
If you inquire about or decide to invest in Anfluss LLC, we will collect basic personal information from you or your representative party to register you as an investor or lender.
If we hire you as a vendor, supplier, or contractor, we will collect personal information to complete transactions and, where applicable, conduct appropriate screenings.
Finally, if you contact us for any other reason, we will collect your basic contact details and any other relevant personal information to address your inquiry.
Legal Basis
Certain laws, including the GDPR, state laws in the United States, and other regional/municipal laws, require us to establish a ‘lawful basis’ for processing your personal information. In most cases, processing will be justified because:
- It is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract (e.g., when you request certain services as an individual client, or when we advise your employer or service provider on fulfilling a contractual obligation to you).
- It is necessary for us to comply with a legal obligation (e.g., collecting certain client information for tax or accounting purposes, or making disclosures to courts or regulators).
- It is necessary for the performance of a task carried out in the public interest (e.g., background checks for anti-money laundering and terrorist financing purposes).
- It is in our legitimate interests, provided these are not overridden by your interests and fundamental rights (this is the basis for most of our processing related to providing services and for client onboarding, administration, and relationship management).
In limited circumstances, we will use your consent as the basis for processing your personal information, such as when required by law to obtain your prior consent for sending marketing communications.
Before collecting or using any special categories of data (as defined by the GDPR or similar privacy laws) or criminal record data, we will establish a lawful exemption, typically:
- Your explicit consent.
- The establishment, exercise, or defense of legal claims by us or third parties.
- Other uses permitted by applicable law, including context-specific exemptions under local laws within the United States, EU Member States, and other countries with GDPR-like privacy laws, such as for preventing or detecting fraud in relation to potential client instructions.
Disclosure of Personal Information to Third Parties
Anfluss LLC will not disclose your personal information to third parties except as described in this Privacy Policy, unless we have your permission or are required or permitted by law. We may share your information with our affiliates to carry out the purposes for which the information was supplied or collected. Third-party contractors, consultants, and vendors engaged by Anfluss LLC to provide services may also have access to your personal information. These third parties will adhere to data protection requirements that provide the same or greater level of security as Anfluss LLC and will typically have entered into a written agreement with us regarding the protection of your personal information.
Anfluss LLC may also disclose your personal information to:
- Respond to requests from law enforcement agencies, regulators, courts, subpoenas, search warrants, or other legal requests.
- Prevent and/or detect crime.
- Establish legal rights or investigate or pursue legal claims.
- Facilitate a merger, acquisition, or corporate restructuring involving Anfluss LLC.
- Prevent risk of harm to an individual.
International Hosting and Transfer of Information
Anfluss LLC does not currently engage in international business and does not intend to transfer data internationally. If the need arises for collaboration with an international partner, we will take appropriate steps to ensure the transfer of personal information is in compliance with applicable laws and is carefully managed to protect your privacy rights. Transfers will only occur to countries recognized as providing adequate legal protection or where alternative arrangements are in place to protect your privacy.
Information Security
Anfluss LLC employs reasonable technical safeguards, security policies, and procedures to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures include confidentiality requirements for staff and service providers, limiting access to personal information on a “need-to-know” basis, and providing relevant training to personnel. We also have comprehensive policies for data incident response and regularly audit our IT Security Program. Despite our best efforts, absolute security against all threats cannot be guaranteed.
Retention of Your Personal Information
Anfluss LLC retains your personal information for as long as necessary to fulfill the purposes for which it was collected, any compatible purposes established later, new purposes you consent to, or to comply with legal and regulatory requirements. Typically, this retention period aligns with the duration of your relationship or contract with us, plus the time during which legal claims may be made after the termination of such relationship or contract. Some information, such as call recordings and tax records, may need to be retained longer to meet compliance needs. Personal information may be kept for a shorter or longer period if required by law, an Anfluss LLC policy, if subject to a legal hold, or if identified as appropriate through a data protection impact assessment.
Your Rights under GDPR and Similar Laws
Your Rights:
If your data is processed by Anfluss LLC in jurisdictions with GDPR-like laws, you have specific rights regarding your personal information.
Identity Confirmation:
We may ask for additional information to confirm your identity before disclosing any personal information.
Request Processing:
Contact us to exercise your rights. We will strive to fulfill your request promptly, subject to legal constraints.
Limitations:
We may not fully address your request if it affects confidentiality obligations or if we are legally entitled to handle it differently.
Right to Access: You can access personal information Anfluss LLC holds about you and understand how and why it is processed.
Right to Rectification: You can request corrections to your personal information if it is inaccurate or outdated.
Right to Erasure: You can request the deletion of your personal information under certain circumstances, such as when it is no longer needed for its original purpose.
Right to Restrict Processing: You can restrict the processing of your information if its accuracy is contested, if the processing is unlawful but you do not want it erased, if it is no longer needed but you still require it for legal claims, or if you have objected to the processing and verification is pending.
Right to Data Portability: You can request your data in a machine-readable format for transfer to another controller, applicable if the processing is based on consent or a contract.
Right to Object: You can object to processing based on legitimate interests. We may continue processing if we demonstrate compelling legitimate grounds.
Contact:
For concerns or to exercise your rights, contact us at support@anfluss.com.
Anfluss LLC will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. In addition, under applicable local law you may have the legal right to lodge a complaint with the relevant supervisory authority or local data protection authority.
Additional Information for California Residents
This section addresses California residents’ rights under the California Consumer Privacy Act (CCPA). The CCPA requires businesses to inform California consumers about how their personal information is used. This document fulfills that requirement but does not apply when we function as a “service provider” to our clients.
Job Applicants:
Please review the Notice at Collection and Privacy Policy for California Job Applicants.
Personal Information:
Under the CCPA, “personal information” includes any data that identifies or could be linked to a specific California resident or household.
Categories of Personal Information Collected and Disclosed:
| Category | Do We Collect? |
|---|---|
| Name, Contact Information, and Identifiers | Yes |
| Customer Records | Yes |
| Protected Classifications | No |
| Purchase History and Tendencies | Yes |
| Biometric Information | No |
| Usage Data | Yes |
| Geolocation Data | No |
| Audio/Visual | Yes |
| Employment History | Yes |
| Education Information | No |
| Profiles and Inferences | Yes |
Disclosures for Business Purposes
Anfluss LLC does not disclose personal information for business purposes. However, in certain circumstances we may disclose various categories of personal information for business purposes, as defined by the CCPA:
Service Providers:
To perform services on our behalf, including the specific purposes detailed in our privacy policy.
Auditors, Lawyers, Consultants, and Accountants:
To audit compliance with policies and laws and to perform services on our behalf.
Affiliated Companies:
Among companies affiliated with and departments within Anfluss LLC for purposes such as auditing compliance, ensuring security, debugging, short-term transient use, performing services, internal research, and improving the quality or safety of a service or device.
No Sales or Sharing
We do not sell or share your personal information for cross-context behavioral advertising. We have not sold or shared personal information, including that of children under 16, in the last 12 months.
Sensitive Personal Information:
We only use sensitive personal information to perform services, ensure security, or for other permitted purposes, without inferring characteristics from it.
Categories of Sources from Which We Collect Personal Information
You: When you provide information directly.
Service Providers: For analytics, IT, and system administration services.
Affiliated Companies: To assist affiliated companies, operations, or departments within Anfluss LLC.
Automated Technologies: Browsing activity collected on our website.
Third Parties: Lawyers, bankers, auditors, and insurers.
Public Sources: Public databases.
Marketing/Advertising Companies: From social media platforms and analytics companies.
Surveillance/Recording Technologies: Video surveillance and audio recording with consent.
Government or Administrative Agencies: Law enforcement and public health officials.
Acquired Entities: Personal information from entities we acquire.
Aggregated and Deidentified Information
We may aggregate or deidentify information for internal use and disclosure to third parties. This information is not personal information.
Aggregated Information:
Group statistics without identifiable details, e.g., 20 people used our contact form on a given day.
Deidentified Information:
Data stripped of identifiable details, e.g., an anonymous visitor accessed our main web page. We maintain it in a deidentified form and do not attempt to reidentify it, except for ensuring our deidentification processes work correctly. We encourage and sometimes require clients to deidentify datasets before sharing with us, where applicable and technically possible.
California Residents’ Rights
Notice at Collection:
We notify California residents about the categories of personal information we collect and its purposes at or before the point of collection.
Right of Deletion:
California residents can request the deletion of their personal information, with some exemptions.
Right to Correct:
Residents can request the correction of inaccurate personal information we hold.
Right to Know – Specific Pieces:
Twice a year, residents can request specific pieces of their personal information in a portable format.
Right to Know – General Information:
Residents can request information about how we handle their personal information, including categories collected, sources, purposes, and third parties to whom it was disclosed.
Submitting Requests:
Submit requests to exercise these rights at support@anfluss.com or call 833-708-0303.
How We Verify Your Request:
We match personal information provided with what we have on file. The more sensitive the request, the more information we may ask for verification.
Right to Non-Discrimination and Incentives:
We do not discriminate against residents for exercising their CCPA rights and comply with requirements for any financial incentives related to personal information.
Authorized Agents:
You may designate an authorized agent to exercise your rights. The agent must provide authorization and follow our verification process. Contact us at support@anfluss.com for the “Authorized Agent Designation” form or provide a compliant power of attorney.
Marketing
Anfluss LLC may send you information about our services, products, and events that we think might interest you, via post or email. To stop receiving these communications, you can unsubscribe using the link in our marketing emails or contact us to opt out of all marketing communications.
Children
Anfluss LLC’s websites are not designed for children under 16. We do not knowingly collect information about anyone under 16, except when providing professional services.
Links
Anfluss LLC’s websites may link to other sites, including those of our affiliates, which have their own privacy policies. We are not responsible for the content or privacy practices of third-party websites. Review the privacy policies of any sites you visit before providing personal information.
Changes to this Policy
By using Anfluss LLC’s websites, you consent to our collection, use, and storage of personal information as described. We may update this Privacy Policy and will notify you by posting changes on our website.
Contact Us
For questions or concerns about this policy or our data processing practices, please contact us at support@anfluss.com.
Cookie Policy
This policy applies to Anfluss LLC and its affiliated entities (collectively “Anfluss”).
Anfluss is committed to safeguarding your privacy and being transparent about the technologies we use. This Cookie Policy explains how and why we use cookies and similar technologies to enhance your user experience on our websites. Please read this policy alongside our Privacy Policy.
What are Cookies and Other Tracking Technologies?
A cookie is a small text file that a website places on your computer or mobile device when you visit. It allows the website to recognize your device and store some information about your preferences or past actions. For more information about cookies, you can visit allaboutcookies.org and youronlinechoices.eu.
How Do We Use Cookies and Other Tracking Technologies?
We use cookies to authenticate and identify your session on our website, enabling us to display the correct information. This helps us distinguish you from other users and provide a good user experience. Most web browsers allow you to erase cookies, block them, receive a warning before they are stored, or disable them altogether. By selecting “Use necessary cookies only” on our website’s cookie notice, you agree to our use of only the essential cookies. Selecting “Allow all cookies” allows us to use all cookies as described in this policy.
Logging: We record and store details of the pages you visit to generate usage statistics. We do not sell or share this information with other companies, except as outlined in our Privacy Policy.
Cookie Retention: Our website uses both persistent and session-based cookies. Session-based cookies last only for the duration of your visit, while persistent cookies remain in your browser’s subfolders until you delete them manually or your browser deletes them.
Types of Cookies We Use
First Party Cookies
- First Party Cookies: These are set by the Anfluss website you are visiting and can only be read by Anfluss.
Session Cookies
- Session Cookies: These cookies store information about your page activities so you can easily pick up where you left off. They are temporary and erased when you close your browser. When you revisit the site, it won’t recognize you, and you will need to log back in or select your preferences again. A new session cookie will be generated each time you visit and will remain active until you leave the site and close your browser.
Persistent Cookies
- Persistent Cookies: These cookies store user preferences and remain in your browser’s subfolders until you delete them manually or your browser deletes them based on the duration specified in the cookie’s file.
Third Party Cookies
- Third Party Cookies: These are set by organizations other than Anfluss. For example, we might use a third-party analytics company, such as Google Analytics, which will set its own cookies to perform this service.
Categories of Cookies We Use
- Necessary: These cookies enable basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
- Preference: These cookies remember information that changes how the website behaves or looks, such as your preferred language or region.
- Statistics: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously.
- Marketing: These cookies track visitors across websites to display relevant and engaging ads for the user, making them more valuable for publishers and third-party advertisers.
- Unclassified: These are cookies that we are still in the process of classifying, along with their individual providers.
Use of Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics helps us understand how users interact with our site, such as which pages are most frequently visited. The information generated by the Google Analytics cookie (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google uses this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website and internet usage. Google may also share this information with third parties if required by law or if those third parties process the information on Google’s behalf. Google does not associate your IP address with any other data held by Google. By using this website, you consent to Google’s data processing as described above.
Changes to Cookie Usage
If we make significant changes to how we use cookies (e.g., adding new cookies with different functionalities), we will inform you from the login page. This information will always be accessible from the navigation links at the bottom of all pages.
Managing Cookies
If you do not want cookies to be used, you can manage your cookie preferences:
- By clicking the “I Accept” button on the cookies notice, you agree to our use of all cookies described in our cookie policy.
- If you do not accept cookies, only essential cookies will be placed, which may affect some site functionality.
- To remove existing cookies, use your browser options.
- To block future cookies, change your browser settings. Blocking all cookies may impact certain website functionalities or degrade your browsing experience.
Contact Us
If you have any questions or concerns about this policy or our data processing practices, please contact us at support@anfluss.com.
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