The Secured Finance Network (“SFNet”), believes in protecting your privacy and the confidentiality of your Personal Information. This policy discloses the privacy practices for www.sfnet.com and will notify you of the following:

1. What personally identifiable information is collected from you through the website, how it is used and with whom it may be shared.
2. What choices are available to you regarding the use of your data.
3. The security procedures in place to protect the misuse of your information.
4. How you can correct any inaccuracies in the information.
   

Personal information is any combination of information, in the possession of or likely to come into the possession of SFNet, that can be used to identify, contact, or locate a discrete individual and will be treated in accordance with this Privacy Policy. Any information that cannot be used to identify a discrete individual (such as aggregated statistical information) is not Personal Information.

Information Collection, Use, and Sharing

When setting up your member profile, registering for an event, subscribing to one of our publications, or signing up for a webinar or class, SFNet will collect information such as your name, title, company, phone, email and other demographic information that will help us better serve your needs.

We are the sole owners of the information collected on this site. SFNet only has access to/collects information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information, however, there may be events where additional follow-up networking is offered where you may share contact information with other event attendees, or learn about other association events/happenings.

Unless you ask us not to, we may contact you via email, mail, or phone to inform you of additional benefits of membership or other SFNet news.

Cookies 

As you navigate the Site, we may also collect information through commonly used information-gathering tools, such as cookies. A cookie is a piece of data stored on a site visitor's hard drive to help us track and target the interests of our users and enhance the online experience. Usage of a cookie is in no way linked to any personally identifiable information on our site.

There are different kinds of cookies with different functions:

1. Session cookies: a session cookie is only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
2. Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
3. First-party cookies: the function of a first-party cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between SFNet’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
4. Third-party cookies: the function of a third-party cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.

We use cookies for the following purposes:

• Where strictly necessary: These cookies are essential to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining  logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
• Performance: These cookies collect information about how visitors use a Site (e.g., which pages visitors go to most often, if they get error messages from web pages). They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous.
• Functionality: These cookies allow our Site to remember choices you make (e.g., your user name, your role, region you are in) and provide enhanced features. For instance, a Site may be able to remember your login details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font, and other parts of web pages that you can customize. They may also be used to provide services you have requested, such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
• This Site does use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage for SFNet. Google may also transfer this information to third parties when required to do so by law or when such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do so, you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

You can block or delete these cookies by changing the browser settings as explained below.

You can also prevent your data from being collected by Google Analytics on the Websites by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

• Advertising: We use cookies and tracking technologies to help us develop our understanding of your interests and what content and services may be relevant to you.
• The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized,  SFNet’s Site is not compatible with DNT.

Information that may be collected by cookies when you use the Sites may include, without limitation:

• the pages you visit within the Sites;
• the date and time of your visit to the Sites;
• the amount of time you spend using the Sites;
• the Internet Protocol (IP) address used to connect your computer to the Internet; and/or
• your computer and connection information such as your browser type and version, operating system and platform.
  

This information is collected to enhance the site performance and end user experience. You can set your browser to reject cookies or to notify you when you are sent a cookie. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser.  In addition, to find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Once you are logged into our website, cookies will also track your page views and sections of the site you visit most. This is strictly used for internal marketing purposes to help serve the users of the platform with more personalized content. 

Information You Provide to Payment Processors

Any payments made to SFNet are processed by payment processing providers that are PCI/DSS-compliant. All information collected by these third-party providers for purposes of processing your payments is not available to us, unless you have otherwise provided this information to us in connection with your use of the Site or your association membership.

If this data is not processed and transferred, The Secured Finance Network will not be able to execute the contract with you or you will not have access to any or all of the benefits and features associated with your transaction (such as member pricing or access to member-only content). 

Your Access to and Control Over Information

You may opt out of any future communications from us at any time. Contact us at info@sfnet.com for any of the following:

• See what data we have about you, if any.
• Change/correct any data we have about you.
• Have us delete any data we have about you.
• Express any concern you have about our use of your data.

Security

We take precautions to protect your information both online and offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Links

This website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of outside sites not controlled by Secured Finance Network. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Information for California Residents

Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us at info@sfnet.com.

Information for Individuals Located in the European Union

Legal Basis for The Processing of Personal Information from EEA Residents
If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows:

(i) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.

(ii) If the processing of your personal data is necessary for the performance of a contract between you and SFNet or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b).”). If this data is not processed, SFNet will not be able to execute the contract with you.

(iii) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying in the fields of employment law.

(iv) And where the processing is necessary for the purposes of SFNet’s legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.

Transferring Personal Data from the EU to the US:

SFNet has its headquarters in the United States. Information we collect from you may be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR). A finding of “adequacy” in short means that the European Commission has decided that this country outside the EEA ensures an adequate level of data protection. SFNet relies on derogations as set forth in Article 49 of the GDPR as the United States has no “adequacy” decision and no other safeguards under the GDPR are in place (for example binding corporate rules on the transfer outside the EEA). In particular, SFNet collects and transfers to the U.S. personal data only: with your explicit consent; to perform a contract with you; in a manner that does not outweigh your rights and freedoms. If this data is not processed and transferred, SFNet will not be able to execute the contract with you or you will not have access to any or all of the benefits and features associated with your transaction. SFNet endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with SFNet and the practices described in this Privacy Notice. SFNet also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

If you wish to confirm that SFNet is processing your personal data, or to have access to the personal data SFNet may have about you, please contact us at privacy@sfnet.com.

European Union Data Subject Rights

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects (these are persons that can be identified).

This Privacy Notice is intended to provide you with information about what personal data SFNet collects about you and how it is used.

If you wish to confirm that SFNet is processing your personal data, or to have access to the personal data SFNet may have about you, or have other questions, please contact us at privacy@sfnet.com.

You may request information via privacy@sfnet.com about: the purpose of the processing; the categories of personal data concerned; who else outside SFNet may have received the data from SFNet; what the source of the information was (if you did not provide it directly to SFNet); where the personal data is stored and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by SFNet if it is inaccurate. You may request that SFNet erase that data or cease processing it, subject to certain exceptions. You may also ask SFNet for your personal data to be supplemented or updated, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. You may withdraw your consent for the processing of personal data or the further processing of personal data by SFNet at any time.  You may also request that SFNet cease using your data for direct marketing purposes. In many countries (including EEA countries), you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how SFNet processes your personal data. When technically feasible, SFNet will—at your request—provide your personal data to you or transmit it directly to another controller. You have the right to receive your personal information in a structured and standard format.

In addition to the information contained in this Privacy Notice, you may be provided with additional and contextual information concerning particular services or the collection and processing of your personal data upon request.

Reasonable access to your personal data will be provided at no cost to SFNet members, conference attendees and others upon request made to SFNet via info@sfnet.com. If access cannot be provided within a reasonable time frame, SFNet will provide you with a date when the information will be provided. If for some reason access is denied, SFNet will provide an explanation as to why access has been denied.

Security of Your Information

SFNet uses reasonable physical, technical and administrative measures to safeguard personal information you provide through the Sites or in connection with SFNet’s products and services.  Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, SFNet cannot guarantee or warrant the security of any information you transmit on or through the Sites and you do so at your own risk.

Data Storage and Retention

Your personal data is stored by SFNet on its servers, and on the servers of the database management services SFNet engages, located in the United States. SFNet retains data for the duration of the customer’s or member’s business relationship with SFNet and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your personal data are processed. We will retain your personal data as long as you are an SFNet member or require our services so that we can provide these services to you.

If you are located in the European Economic Area, at the moment you cancel your SFNet membership or withdraw your consent for the processing of your personal information, all your personal data received and stored are erased if no longer needed by us. Unless we are required to retain this personal data by law or to comply with our regulatory obligations. In such a case, we will only keep this personal data for as long as necessary. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our data privacy resource at info@sfnet.com.

In certain Sites operated overseas, the Privacy Policy displayed on those Sites, not this Privacy Policy, will govern the collection, use, and sharing of information.

Children

As a professional association, SFNet does not market its services to children. The Child Online Privacy and Protection Act (COPPA) regulates the collection of information from persons under the age of 13. If you are a minor, please do not supply any personally identifiable information through the site. Parents or guardians may contact SFNet at info@sfnet.com if you believe a minor has supplied information that you would like removed.

Questions or concerns

If you have any questions or concerns about this Privacy Policy, please contact us at info@sfnet.com.