Fiduciary Data Corporation Privacy Notice

The Fiduciary Data Corporation
Privacy Notice
Effective September 23, 2022

The Consent Custody Corporation, a Delaware public benefit corporation d/b/a The Fiduciary Data Corporation (“FDC”, “we”, “us”, or “our”), is developing a service and associated technology platform to provide fiduciary, trust and related services for data and other digital properties to individuals and organizations.

During this development phase, we are providing information, service demonstrations and test-level services in a non-production environment (collectively, the “Services”), as well as an informational website (the “Site”) to our clients, prospective clients and other interested parties, in each case subject to our Terms of Service and this Privacy Notice

This Notice describes the types of information we may collect from you or that you or your organization may provide to us when you browse and interact with the Site, submit an inquiry to us, participate in one of our surveys, use the Services or otherwise interact with us. This Notice also describes how we use and share information about you, as well as certain rights and choices you have regarding your information.

If you have questions or concerns about this Notice or our collection and use of your information, please contact us at the email address listed below, and we will be happy to address them. By using the Site or the Services, you agree to the policies and practices described in this Notice. If you do not agree, please do not use the Site or the Services.

In this Notice, “Personal Information” means information that can be used to identify you (such as your name, email address or other contact information) and other information that is linked to your personal identifiers (such as login information).

This Notice applies only to information that is Personal Information as collected by or provided to us through the Site or the Services. For example, if we create aggregated anonymous data that cannot be used by someone else to identify you, our use of that aggregated anonymous data is not covered by this Notice. This Notice also does not apply to information we may obtain from other sources or to the practices of any third parties.

We may update this Notice from time to time. Whenever we do so, we will include the applicable effective date at the top of the page. Whenever you use the Services or browse the Site or otherwise provide us with information, you are indicating that you agree to the most recent version of this Notice.

Information We Collect
We collect several types of information, including Personal Information, from and about users of the Site and the Services as further described in the following sections.

Information You or Your Organization Provides to Us
We collect Personal Information when you or your organization chooses to provide it to us. For example, if you fill out a request for information on the Site, we collect your contact information, which we use to fulfill your request and to manage - and allow you to manage - your consent for that use. If you establish an FDC account (or one is established for you), we collect your username and password, and you may be asked to verify your identity or your email address.

We use this information to deliver the features of the Site and the Services that you request or that your organization has signed up for, such as to respond to your inquiries, issue digital rights certificates, provide customer support, create and maintain your FDC account or your organization’s FDC account, verify your identity, and communicate with you or your organization about your or its FDC account. We also use this information to evaluate and improve the Site and the Services, customize your user experience, personalize our communications to you, and for other reasons that you request or that we make known to you at the time you choose to provide the information and associated consent.

Information We Collect Automatically
When you use the Site or web-based features of the Services, we may collect information from or about you automatically using standard technologies, such as cookies, Web beacons, and third-party analytics services.

A cookie is a small file that is stored on your device when you visit a website. It allows the website to recognize your device or recall your settings. You can block cookies or delete them by following the instructions for your device or browser, but not all of the features of the Site or the Services may work as intended, or you may be asked to re-enter information, if you block our cookies.

A Web beacon (or a pixel “GIF”) is an invisible digital object on a webpage or email. Web beacons are used to collect information about interactions with the webpage or email, such the number and duration of visits to a webpage.

Analytics services are provided by third parties to measure various uses of an application or webpage, including general geographic location, browsing actions, and similar information for compiling and analyzing statistical data. These third parties may also use automatic technologies like browser cookies and Web beacons. [We use Google Analytics to help us analyze the Site and the Services and how they are used. You can read more about how Google Analytics handles Personal Information here, and you learn how to opt out of Google Analytics here.]

The information we and our third-party service providers may automatically collect includes:

  • IP address and general location (such as region or city);
  • Device, operating system and browser types and versions;
  • Date, time and duration of visits to the Site;
  • Frequency and number of visits to the Site from a particular IP address;
  • Navigation actions in the Site;
  • Referring website, if applicable; and
  • File uploads and downloads through the Site or the Services.

We use automatically-collected information to make the Site and the Services available to you and/or your organization, evaluate and improve the Site and the Services, customize your user experience, and perform market research. We may use this information to present selected content to you or your organization, or to invite you to participate in surveys, product demonstrations, discussion forums or other related matters that we believe may be of interest to you or your organization based on your interests and activities on the Site and using the Services.

Information We Share
We share Personal Information with non-affiliated third parties only as described in this Notice, unless we obtain your specific consent otherwise.

We may share limited Personal Information with our service providers who provide products or services that help us develop, operate, maintain, and improve the Site and the Services. These service providers include email or other communications service providers, and providers of platforms for surveys, customer support, content delivery, database management, hosting, cyber security, customer-relations management, and interactive features of the Site and the Services. Service providers must treat your Personal Information as confidential and use it only to provide the services for which we have engaged them.

We may also use your Personal Information to help protect against fraudulent or unauthorized activities, improve security, comply with applicable law or legal obligations, cooperate with law enforcement or other governmental authorities, investigate complaints, defend against legal claims, protect the rights and safety of our organization and our employees and users, or enforce this Notice and, if applicable, our contract with you or your organization.

If we raise capital, are acquired by or merge with another company or go through a similar major corporate event involving a detailed review of our business and operations by third parties, we may disclose your Personal Information as part of such a review. Any such review will be subject to a confidentiality agreement that will limit the use of your Personal Information to the purpose of the review.

Security and Data Retention
We have implemented commercially reasonable and appropriate measures to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your Personal Information also depends on you. For example, if you have an FDC account or other profile with us, you are responsible for keeping your password or other credentials confidential. Unfortunately, the transmission of information online is not completely secure, and despite the security measures we have implemented, we cannot guarantee the security of your Personal Information transmitted to or through the Site or the Services.

We store Personal Information as long as necessary for the purpose for which we originally collected it, or for other legitimate business purposes, including for backup and archival purposes, to analyze and improve the Site and the Services, and to meet our legal, regulatory, or other compliance obligations.

Your Choices and Rights
You may update, correct, or delete information about you at any time by using the tools and settings available to you through the Site or the Services, by contacting us at the address listed below or, if applicable, by contacting the administrator for your organization. You may elect not to receive promotional communications from us by following the opt-out or unsubscribe instructions included in any such communication or by sending your request to us. If you have an FDC account, however, we may continue to communicate with you about your or your organization’s account, as needed.

We may enable you to invite others to try the Services or participate in a survey or other interaction with us. We may store and use the information you provide (i.e., contact information) in order to extend invitations to those potential users and for no other purpose without their consent. Those other potential users will always have the opportunity to opt-out of receiving further communications from us.

We do not track our users over time and across third-party applications or websites, and therefore we do not recognize or respond to browser-initiated “Do Not Track” signals.

We do not sell Personal Information (including as the term “sell” is defined under the California Consumer Privacy Act), and we do not disclose Personal Information to third parties for their marketing purposes.

You may have additional rights under applicable law. For example, you may have the right to obtain a copy of your Personal Information or to request deletion or transfer of certain Personal Information. We will make reasonable efforts to comply with such requests where applicable, but we may refuse such requests where we are otherwise legally required to retain the information, or where the requests are unreasonably repetitive, require disproportionate technical effort, create privacy risks for others, or are impractical.

Notice to Non-U.S. Residents
We are based in the United States and our data processing activities occur in the United States. Accordingly, except as otherwise expressly agreed by FDC, the information we collect is governed by United States law, which may be different from the laws applicable to Personal Information in your country of residence. Any Personal Information you provide to us will be transferred to (if applicable) and processed and stored in the United States. By providing us your Personal Information or using the Site or the Services, you consent to our collection, transfer, processing, and storage of your Personal Information in the United States in accordance with this Notice and, if applicable, our Terms of Service or other contract with you or your organization, which may include a data processing agreement or addendum if your organization is based or operates outside of the United States.

The Site and the Services are intended for adults and are not directed to minors. We do not knowingly collect any information, including Personal Information, from or about minors. If you become aware that your minor child has provided us with Personal Information, please contact us. If we become aware that a minor has provided us with Personal Information, we will take steps to remove such information.

Contact Information
If you have questions or concerns about the privacy practices described in this Notice, or to communicate with us for any of the reasons described above, please write to us at