Sherlock AI Privacy Policy
Sherlock AI, a subsidiary of FAIT, LLC (“FAIT,” “we” or “us”), is a provider of integrated financial information and analytical applications to the investment community. To protect your privacy, FAIT wants our customers, suppliers, employees, applicants, and other relevant parties to know how we collect Personal Data, the types of Personal Data we collect, and how we use and share your Personal Data. If information is associated with an identified or identifiable natural person and is protected as Personal Data under applicable data protection law, it is referred to in this Privacy Notice as “Personal Data”. By visiting this Website (the “Site”), or providing your information to us, you are accepting the practices described in this Privacy Policy.
Applicability of this Privacy Policy
This Privacy Policy applies to Personal Data we collect from various sources, including the following:
on our public website;
through our client and supplier-facing applications and tools;
from communications or applications you send us;
when you interact with our advertising or applications on third-party websites and service platforms, if they include links to this notice; and
through your contractual relationship with us, as applicable.
FAIT’s role as a data processor or data controller
Depending on the circumstances, FAIT may process your Personal Data as data controller or as data processor. When FAIT is a processor on another controller’s behalf, FAIT’s processing is governed by terms outlined in a specific data processing agreement with the responsible data controller.
The categories of Personal Data FAIT collects
The Personal Data we process is primarily business contact information, such as username, name and business contact information, from our clients and suppliers and information you and our customers provide when using our products, accessing our websites, and other applications. In some cases, a FAIT client may upload and store its own or another entity's or individual’s Personal Data on a FAIT platform or service. For FAIT products where this is possible, or for any other scenario where FAIT may act as a processor, the collection of and categories of Personal Data will be governed by a specific data processing agreement between FAIT and the client. We also collect and collate information (including some Personal Data) from third-party suppliers and public sources. FAIT does not market to or knowingly collect personal data of Individuals under the age of 18. If you navigate through and interact with our Site and some of our products, we may use automatic data collection technologies to collect certain usage information about your equipment, browsing actions, and patterns. Automatic data collection is carried out through the use of cookies and related technologies. For more information, please see our Cookie Policy.
How FAIT uses your Personal Data
We process Personal Data primarily to provide our services to our clients, to fulfill our contractual obligations, and to improve our products and offerings. Specifically, FAIT uses Personal Data to:
provide client services, such as our SaaS data, analytics, and technology solutions, evaluate and process requests regarding implementation, projects, or change requests; to process payments, technical support, or other similar purposes; and to establish and maintain client accounts;
address your inquiries associated with the information you provide to us;
provide training and after-sales-support on our products and answer to and perform change requests;
To enable users to access and use web applications hosted by us for and behalf of our clients;
To allow users of our provided CRM services to upload Personal Data;
communicate with clients and suppliers, including responding to requests for assistance and to update them about the status of their orders by postal mail, email, telephone, or text message;
investigate, prevent, or act regarding unauthorized use of our services, illegal activities, suspected fraud, or situations involving potential threats;
provide you with underlying tools and applications helping to implement projects and resolve incidents;
provide our content services to our clients and to report and administer clients’ usage of third-party information products (e.g., real-time data from stock exchanges etc.);
to enhance the experience for our users, we use notes relating to support provided to specific employees, advisors, or agents of clients in relation to our products and services for their future use of our services;
to the extent it is lawful to do so, market and promote our products including through email or equivalent electronic means, to send news and newsletters, special offers and promotions, or to otherwise contact clients about products, services, or information;
process, evaluate and complete certain transactions involving the Site, and more generally transactions involving FAIT’s products and services;
operate, evaluate, maintain, improve, and develop the Site (including by monitoring and analyzing trends, tracking user behavior, access to, and, where lawful to do so, use of the Site for advertising and marketing);
facilitate the job application process;
provide users with documentation or communications which they have requested, or which is part of a product;
correspond with users to resolve their queries or complaints;
protect the security of the Site, FAIT confidential and proprietary information (which may include Personal Data), and FAIT employees;
manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
share your Personal Data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case Personal Data held by us about our users may be one of the transferred assets.
Our Legal Basis for processing Personal Data
FAIT relies on different legal bases for processing of Personal Data depending on the business purpose:
the processing is necessary to perform a contract with you or take steps to enter into a contract at your request;
the processing is required to allow you access and to use our services, products, or specific applications;
the processing is necessary for us to comply with a relevant legal obligation;
the processing is in our legitimate interests, which are not overridden by the interests and rights of the relevant individual whose Personal Data is collected; and
you have consented to the processing, e.g. for marketing purposes.
Where we rely on our legitimate interests to process Personal Data, those interests are:
to use supplier, client, and website user data to conduct and develop our business activities and improve our services in order to grow our business and profitability; and
to use third party suppliers and publicly available content (which in some instances includes Personal Data) to provide our content services to customers for their business purposes.
Retention of Personal Data
We keep Personal Data only for as long as required to fulfill the purposes for which it was collected. In general, we retain Personal Data for a period of time corresponding to statutes of limitation, for example to maintain an accurate record of client and supplier dealings. In some circumstances we may retain Personal Data for other periods of time, for instance where we are required to in accordance with legal, tax or accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required in accordance with our document retention policy.
How does FAIT internally transfer and disclose Personal Data?
Transferring Personal Data within FAIT and its affiliates is required in order to provide our services and offerings. FAIT has adopted an Intra-Group Data Transfer Agreement to ensure your Personal Data receives an adequate level of protection wherever it is processed within the FAIT group.
FAIT’s Third Party Service Providers and Partners
We may disclose Personal Data to other companies that we have engaged to assist us in providing you with our products and services, consistent with the legal bases outlined above. This may include the following service providers:
billing services;
transaction managers;
credit verification services;
market researchers;
software and application vendors;
data center providers and cloud services providers; and
other third-party service providers
To the extent that third party service providers and partners process Personal Data on behalf of FAIT, we enter into data processing agreements with them to regulate the processing and to ensure the security of Personal Data. We do not sell or rent Personal Data to third parties for their own use.
Use of Aggregated or De-identified Data for statistical purposes
We may disclose or use aggregated or de-identified information for statistical purposes or analyses in a way that will no longer refer to an individual and that the results of which are not used for decisions affecting a particular person or groups of persons.
Security
FAIT takes reasonable precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Unfortunately, while we work hard to ensure the security of your Personal Data while it is on our systems, no security measures are perfect, and data transmitted over the Internet is not guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any Personal Data you transmit, and you do so at your own risk.
Changes to this Privacy Policy
This Privacy Policy may be amended from time to time. Please review it periodically. Changes will be identified by the date at the top of this page.
Your rights
If you are based in certain geographical locations - such as parts of the U.S., the European Economic Area (EEA), Singapore, India, or the Philippines, and others - you have specific legal rights when it comes to your Personal Data. You may be able to request, see, update, correct, or delete your information. You can also ask us to limit how we use your information, or object to its use altogether. If FAIT previously relied on your consent to process your Personal Data, you may be able to withdraw that consent and stop us from processing your data. If you wish to exercise of these rights, please use the contact information below in the following section. Please note that we will not discriminate against you in any way if you choose to exercise any of the above rights. We may need to request additional information from you in order to respond to your request to exercise any of the above rights. We will respond to your verifiable request and to act on your request within reasonable time without undue delay, subject to your applicable legislation. If we require additional time, or are unable to act on your request, to disclose and or delete your Personal Data as provided under applicable law, we will inform you without undue delay.
Contacting FAIT
Please also feel free to contact FAIT if you have any questions about this Privacy Policy or FAIT’s privacy practices, or if you are seeking to exercise any of your statutory rights.
Data Protection Authority (DPA)
Subject to applicable law, you also have the right to lodge a complaint with your local Data Protection Authority depending on where you reside.
U.S. Data Privacy Notice Supplement
Effective Date: [ Dec 2023] This United States Data Privacy Notice (“U.S. Supplement”) supplements our FAIT Privacy Policy and applies in relation to the processing of personal information of residents of all U.S. States that have passed comprehensive Data Privacy Laws, such as the California Consumer Privacy Act and the Connecticut Data Privacy Act. In case of any inconsistencies between this U.S. Supplement and the rest of this Notice, this U.S. Supplement prevails. For the purposes of this U.S. Supplement, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Categories of Personal Information We Collect and Our Purposes for Collection and Use
You can find a list of the categories of personal information that we collect in the “The categories of personal data FAIT collects” section above.
We collect and use personal information for the business or commercial purposes described in the “How FAIT uses your personal data” section above.
If FAIT decides to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, FAIT will update this U.S. Supplement.
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Directly from You. For example, through your use of our Site or services, or when you apply for employment with us.
Indirectly from You. For example, from observing your activity on our Site or when using our products or services.
Automatically from You. For example, through cookies or other automatic collection techniques that FAIT or our service providers set on your device as You navigate through our Site or use our products or services.
From Service Providers. For example, third-party vendors for payment processing, or other third-party vendors that we use to provide our products and services to you.
For additional details regarding the sources from which we obtain personal information, please see the “Applicability of this Privacy Notice” section above.
Categories of Personal Information Disclosed and Categories of Recipients
We disclose Basic Identifying Information to service providers and third party partners.
We disclose Internet or Other Network Activity to service providers and third party partners.
We disclose Payment Information to service providers who enable the processing of payments.
We disclose Commercial Information to service providers and third party partners.
For additional details regarding the categories of third party disclosures, please see the “FAIT’s Third Party Service Providers and Partners” section above.
Your Privacy Rights
Depending on in which state you reside, you may have certain rights related to your personal information. Specifically,
1. You may have the right to request notice of and access to FAIT’s collection and use of your personal information over the past 12 months, including:
The categories of personal information collected;
The specific pieces of personal information collected;
The categories of sources from which FAIT collected the personal information;
The purposes for which FAIT collects and uses the personal information;
The categories of third parties with whom the business shares the personal information; and
The categories of personal information that FAIT discloses to third parties.
2. You may request that we correct your personal information.
3. You may request that we delete any personal information that we collected from you and retained, subject to certain exceptions which exist in a recruitment or employment context.
For Inquiries and/or to Submit Requests for Information, Deletion or Correction
Please contact: (1) jon@meetsherlock.ai for inquiries about the Company’s Notice or other Privacy practices, or to submit your requests for information, deletion, or correction. As required by applicable laws, we may take steps to verify your identity before acting on your request to exercise your rights.
Agent Authorization
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require you to verify your own identity in response to a request even if you chose to use an agent.
Do Not Sell or Share My Personal Information
FAIT’s website uses cookies, including some that are created by other companies and placed on your browser when you visit our website. We use cookies to keep our site operating as smoothly as possible and to provide web services and functionalities for each visitor. Cookies are used for a variety of purposes. For example, they calculate web statistics, provide online advertising and improve a visitor's experience on our website. Our site may also enable third-party tracking mechanisms to collect data over time and across unaffiliated websites for use in interest-based advertising. For example, third parties may use the fact that you visited the website to send you online ads for FAIT products on third-party websites. In addition, our third-party advertising partners might use information about you to send you targeted advertisements based on your online behavior. Under California and other state laws, our use of those third-party cookies could therefore be considered a “share” or “sale” of your personal information. If you are a resident of California or another jurisdiction with similar laws, that means you have the right to opt out. If you have not done so already, you can click “Do Not Sell or Share My Personal Information” on the Cookie Banner if you’re located in a jurisdiction with this feature, such as California. If you are located in a U.S. state that does not have this feature, please click “Decline” when prompted on our Global Cookie Banner, which will prevent any Third Party or FAIT analytics cookies from being placed on your device. If you originally accepted cookies from our Global Cookie Banner, but then decide to opt out, please clear your browser’s cache and history and click “Decline” when you return the FAIT homepage. To learn more about FAIT’s use of third-party cookies, please see our Cookie Policy.