This Privacy Policy ("Policy") constitutes a binding agreement between Fenurion Inc. ("Fenurion," "we," "us," or "our") and any individual or entity ("User," "you," or "your") accessing or utilizing our website, digital platforms, services, or products (collectively, the "Services"). This Policy delineates our practices concerning the collection, processing, storage, disclosure, and protection of Personal Data and establishes the juridical framework governing data subject rights.
By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. Your continued use of the Services following any modifications to this Policy shall constitute acceptance of such modifications.
This Policy is drafted in accordance with and operates under the following legal authorities:
For purposes of this Policy, the following terms shall have the meanings ascribed herein:
"Personal Data" or "Personal Information" means any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, IP addresses, device identifiers, biometric data, geolocation data, and online identifiers that can be used alone or in combination with other information to identify, contact, or locate a specific individual.
"Processing" encompasses any operation performed on Personal Data, whether automated or manual, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
"Data Controller" means Fenurion Inc., the entity determining the purposes and means of Processing Personal Data.
"Data Processor" means any natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Data Controller.
"Data Subject" means the identified or identifiable natural person to whom Personal Data relates.
"Sensitive Personal Information" includes racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, sexual orientation, Social Security numbers, financial account credentials, and precise geolocation data.
We collect information that you voluntarily provide when you:
Such information may include: full name, postal address, email address, telephone number, date of birth, payment information, account credentials, profile photographs, and any other information you choose to provide.
Pursuant to ECPA § 2510 et seq. and applicable wiretap statutes
When you access our Services, we automatically collect certain technical information through cookies, web beacons, log files, and similar tracking technologies, including:
We may receive Personal Data from:
Subject to ePrivacy Directive 2002/58/EC Article 5(3)
We employ the following types of cookies:
You may control cookie preferences through your browser settings. However, disabling certain cookies may limit functionality of the Services.
GDPR Articles 6 and 9
We Process Personal Data only where we have a lawful basis, including:
Processing necessary for performance of our contract with you, including:
Processing necessary for our legitimate business interests, subject to balancing against your rights:
Processing required to comply with legal obligations, including:
Where required, we obtain your explicit consent for:
You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
We engage third-party service providers who Process Personal Data on our behalf under strict contractual obligations, including:
All Processors are bound by data processing agreements requiring compliance with applicable data protection laws and implementing appropriate technical and organizational measures.
In connection with any merger, acquisition, asset sale, reorganization, or bankruptcy proceeding, Personal Data may be transferred to successor entities. You will be notified via email and/or prominent notice on our website of any such change in ownership or control.
ECPA § 2702 and CFAA § 1030
We may disclose Personal Data when required by law or in good faith belief that such disclosure is necessary to:
We will assess the validity and scope of any legal demand before disclosure and will provide notice to affected users unless legally prohibited.
We may share aggregate statistical data and de-identified information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, and other purposes.
GDPR Chapter V (Articles 44-50)
Fenurion operates globally and may transfer Personal Data to countries outside your jurisdiction. Where we transfer Personal Data from the European Economic Area (EEA) to third countries, we ensure adequate protection through:
We conduct transfer impact assessments and implement supplementary measures where necessary to ensure data protection equivalent to that required within the EEA.
We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Retention periods are determined based on:
Upon expiration of applicable retention periods, we will securely delete or anonymize Personal Data in accordance with our data retention schedule and applicable legal requirements.
GDPR Article 32 and CCPA § 1798.150
Fenurion implements industry-standard technical and organizational measures to protect Personal Data against unauthorized access, alteration, disclosure, or destruction, including:
While we employ commercially reasonable security measures, no electronic transmission or storage system is completely secure. We cannot guarantee absolute security of your Personal Data. You are responsible for maintaining the confidentiality of your account credentials and for all activities under your account.
GDPR Articles 15-22; CCPA §§ 1798.100-1798.120
Depending on your jurisdiction, you may have the following rights regarding your Personal Data:
You have the right to obtain confirmation whether we Process your Personal Data and to receive a copy of such data along with supplementary information about the Processing.
You may request correction of inaccurate Personal Data and completion of incomplete Personal Data.
You may request deletion of your Personal Data where:
You may request limitation of Processing where accuracy is contested, Processing is unlawful, or you have objected to Processing pending verification of legitimate grounds.
You have the right to receive Personal Data you provided in a structured, commonly used, machine-readable format and to transmit such data to another controller.
You may object to Processing based on legitimate interests or for direct marketing purposes, including profiling. We will cease Processing unless we demonstrate compelling legitimate grounds that override your interests.
California residents have additional rights including:
To exercise any of these rights, please submit a verifiable request through:
We will respond to verified requests within the timeframes required by applicable law (generally 30 days for GDPR requests, 45 days for CCPA requests, with possible extensions).
You have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of alleged infringement.
COPPA 15 U.S.C. §§ 6501–6506; GDPR Article 8
Our Services are not directed to children under the age of 13 (or 16 in the EEA), and we do not knowingly collect Personal Data from children. If we learn that we have collected Personal Data from a child without valid parental consent, we will delete such information promptly.
If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@fenurion.com with details, and we will take appropriate remedial measures.
Parents and guardians have the right to review, request deletion of, and refuse further collection of their child's Personal Information by contacting us using the information provided in this Policy.
Certain web browsers and devices permit you to broadcast a preference that you not be "tracked" online. At present, no uniform technological standard for recognizing and implementing Do Not Track (DNT) signals has been finalized. Accordingly, our Services do not currently respond to DNT browser signals or similar mechanisms.
We will update this Policy if and when a uniform DNT standard is established and adopted by Fenurion.
Our Services may contain links to third-party websites, applications, or services not operated or controlled by Fenurion. This Policy does not apply to such third-party properties. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before providing any Personal Data.
The inclusion of any link does not imply endorsement by Fenurion of the linked site, its operator, or its content.
GDPR Article 22
We may use automated processing, including profiling, to:
You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you. Where such processing occurs, you have the right to obtain human intervention, express your point of view, and contest the decision.
GDPR Article 33-34; State Breach Notification Laws
In the event of a data breach likely to result in a risk to your rights and freedoms, we will:
We maintain an incident response plan and conduct regular security drills to ensure preparedness for potential security incidents.
We reserve the right to modify this Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through:
The "Last Updated" date at the top of this Policy indicates when it was last revised. Your continued use of the Services after the effective date of changes constitutes acceptance of the modified Policy. If you do not agree to the changes, you must discontinue use of the Services.
We encourage you to review this Policy periodically to stay informed about how we protect your Personal Data.
If you apply for employment with Fenurion, we collect Personal Data including resumes, cover letters, references, background check information, and interview notes. This information is used solely for recruitment purposes and is retained in accordance with employment law requirements.
You may opt out of marketing emails by:
Please note that even after opting out of marketing communications, we may still send transactional or service-related messages.
If we collect biometric information (such as facial recognition data), we will:
Fenurion maintains compliance with applicable data protection and privacy frameworks, including:
We conduct annual third-party audits to verify compliance with these standards. Certification documentation is available upon request to qualified parties.
Severability: If any provision of this Policy is found by a court of competent jurisdiction to be invalid, illegal, or unenforceable, such provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its intent. If such modification is not possible, the provision shall be severed from this Policy, and the remaining provisions shall continue in full force and effect.
Entire Agreement: This Policy, together with our Terms of Service and any other legal notices published by Fenurion, constitutes the entire agreement between you and Fenurion concerning the subject matter hereof and supersedes all prior or contemporaneous communications and proposals, whether electronic, oral, or written.
Governing Law: This Policy shall be governed by and construed in accordance with the laws of [Jurisdiction], without regard to its conflict of law provisions. However, data protection rights are governed by the applicable laws of your jurisdiction as outlined in this Policy.
Dispute Resolution: Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts of [Jurisdiction], except where mandatory consumer protection laws require otherwise.
BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO BE BOUND BY ITS TERMS. YOU FURTHER ACKNOWLEDGE THAT YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME WHERE PROCESSING IS BASED ON CONSENT, WITHOUT AFFECTING THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, YOU MUST NOT USE OUR SERVICES.
This Privacy Policy represents our commitment to transparency, accountability, and respect for your privacy rights under applicable international, federal, and state laws governing data protection and electronic communications.
Document Version: 4.2
Effective Date: November 14, 2025
Last Reviewed: November 14, 2025
This document has been prepared in accordance with international data protection standards
and reviewed by qualified legal counsel specializing in privacy and technology law.
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