Privacy Policy

Flatiron Dragados USA, Inc. and Flatiron Dragados Canada, Inc. and their subsidiaries (collectively referred to as “FlatironDragados,” “we”, “us”, or “our”) are committed to the protection of all personal data processed in the course of its business activities.

Flatiron Dragados USA, Inc. is domiciled at 810 Seventh Avenue, 9th Floor, New York, New York 10019 and telephone (+1) (888) 353-3669.

Flatiron Dragados Canada, Inc. is domiciled at 150 King Street West, Suite 2103 Ontario (Toronto) Canada M5H 1J9, and telephone (+1) (888) 353-3669.

At FlatironDragados, we respect your privacy, and are committed to protecting the personal information we collect. This Privacy Policy (the “Policy”) applies to Personal Information obtained through digital services provided by FlatironDragados, which include FlatironDragados’ website www.FDcorp.com and FD Connect, as well as information we collect offline (collectively, the “Services”). When you submit information to us or through our Services, you consent to the collection and processing of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY, THEN PLEASE DO NOT USE THE SERVICES OR SUBMIT INFORMATION TO US.

The effective date of this Policy is indicated at the end of this Policy. We may modify this Policy from time to time, and will post changes here. Your continued use of the Services following these changes means that you accept the revised Policy.

I. Collection of Data

a. Categories of Data Subjects

FlatironDragados needs to process the personal data of different categories of data subjects and for different purposes. The main groups of people whose personal data are processed are:

Employees.
Own legal representatives.
Suppliers.
Visitors to corporate offices and facilities.
Legal representatives and contact persons of other entities or persons.
Beneficiaries covered by employee insurance policies.
Reporting line users.
Job applicants.

The personal data of each of these groups may be used in different ways and shared with different natural or legal persons, depending on the specific purpose for which they are to be used. Below is the basic information on the processing operations related to these groups of data subjects.

Under no circumstances will FlatironDragados use personal data for automated decision-making.

b. What We Collect

FlatironDragados may collect Personal Information in the course of our normal business activities, as detailed below. FlatironDragados collects, uses, stores and processes Personal Information, which is data that identifies, relates to, describes, or can reasonably be associated with a particular person. This can include:

Identifying information including name, postal or e-mail address, and phone or fax number, social security numbers, social insurance numbers, driver’s license and government identification numbers.
Financial information such as bank account, credit or debit card information, and/or information that may be contained in a consumer report.
Business contact information including as job title, department and name of organization, business address, e-mail address, mobile telephone number.
Usernames and passwords used to access FlatironDragados network resources such as our FlatironDragados login webpage.
Website visitor activity including IP address, the identity of the Internet service provider, the name and version of the operating system, the name and version of the browser, the date and time of the visit, the pages visited. This data may be aggregated such that the individual identities have been removed.
Biometric information: Physiological, behavioral, biological characteristics, activity patterns, fingerprints, face scans eye scans.
Geolocation information: Physical location, movements, and mobile device unique identifier.
Financial information including as financial account information used for payment purposes and/or information that may be contained in a consumer report, bank account information.
Contact information for referrals.
Employment information: Employment history, employee number, performance appraisals, salary and benefits, healthcare and health insurance information, education information, emergency contact information.
Protected class information: Age, race, color, national origin, citizenship, religion or creed, marital status, disability information, sex, genetic information, military or veteran status.

c. Why We Collect Your Personal Information

We collect personal information to conduct our business activities, including:

Executing business activities, including completing our services.
Conducting marketing and promotional activities, including responding to inquiries about FlatironDragados products or services, providing offers and information (as permitted by law) about products, services, or events offered by FlatironDragados.
Improving the functionality, security, and usability of FlatironDragados’ website.
Security, including monitoring log-in portals for access, validating identity, and preventing fraud.
Fulfilling a legal or contractual obligation.
Managing employee relationships, including the administration of benefits.
Processing job applications, including background investigations.
Validating identity for security to allow access to FlatironDragados premises and job sites.
Complying with applicable laws or regulations.

d. How We Collect Information

When you visit our website, we may collect information about your visit.
Directly from clients, contractors, sub-contractors, vendors, employees, and job applicants.
From third parties including contractors, sub-contractors, and government agencies.

II. Data Security

a. Security applied to data processing

In accordance with current applicable laws and regulations, FlatironDragados has implemented appropriate technical and organizational security measures aimed at guaranteeing integrity, availability and confidentiality of personal information, thereby taking into account the nature, scope, context and purposes of each of the processing operations we carry out. We also take into account the probability of a risk occurring and the impact it would have on the persons whose personal data we handle if such risk were to materialize, pursuant to the foregoing.

In general, but not exclusively, the following security measures have been adopted:

Allocation of user permissions based on the functions they are to perform.
Physical and logical access controls.
Back-ups.
Designation of a Data Protection Officer (also known as the Privacy Officer).
Management and control of media containing personal information.
Designation of an Information Security Officer.
Development of data protection policies and protocols.

Encryption of sensitive information and biannual audits to reinforce data processing operations where the level of risk is the highest among all the data processing operations we carry out. In addition, other verification processes are carried out periodically to help assess that the security measures implemented in each of the data processing operations (not only in those with the highest risk) are effective, and to ensure continuous improvement in order to guarantee data processing security, whilst taking into account advances in technology.

b. Cookies and Tracking Technologies

We and our service providers use cookies and other tracking technologies (such as web beacons, tracking pixels, and HTTP referrers) to collect and store information about your interactions with our website, including information about your browsing behavior. Cookies are small files that are transferred to a computer’s hard drive through a web browser that enable the site’s or service provider’s systems to recognize the user’s browser and capture and remember certain information. In general, we and our service providers use cookies and other tracking technologies to optimize the functionality of our website (including by storing your browsing preferences for future visits and identifying repeat visitors), to optimize the various features on our website, to help us understand how our website is used, and to provide users with content or advertising based on their browsing activities.

If you do not want to have cookies placed on your device, you should set your browser to refuse cookies before accessing our website. Please review your browser’s Help menu for instructions,or visit www.allaboutcookies.org for more information on disabling and deleting cookies. Please note that, if you turn cookies off, some features of our website may not function properly.

Emails that we and our marketing service providers send may include similar tracking tools that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email. More information on consenting to receive and how to unsubscribe from our marketing emails is found below.

c. Website Analytics

We use Google Analytics to ensure website functionality and to improve our website. This software may record information such as your IP address, location, age and gender, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter, and other actions you take while visiting us, the pages you view immediately before and after you access our website, how often you use our website, aggregated usage and performance data, application errors, and debugging information. Google Analytics is owned and controlled by Google LLC. Data collected by Google is subject to its privacy policy. You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here https://tools.google.com/dlpage/gaoptout.

d. Managing “Do Not Track” Signals

Some browsers have a Do Not Track (“DNT”) feature that lets your browser automatically send a signal to websites, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies. Our website does not currently have the capability to respond to DNT signals.

e. Security

FlatironDragados has in place security policies that are intended to ensure the security and integrity of Personal Information. FlatironDragados has commercially reasonable and appropriate technical and organizational measures in place to protect against unauthorized or unlawful processing of Personal Information and against accidental loss or destruction of, or damage to, Personal Information held or processed by FlatironDragados. If FlatironDragados forwards Personal Information to any third party, FlatironDragados requires that those third parties have appropriate technical and organizational measures in place to comply with this Privacy Policy and applicable laws.

f. Data Protection Officer/Privacy Officer

For further information, or for any other question regarding the processing of your data, please contact our Privacy Officer as provided below.

III. Consent and Data Rights

a. Consent

Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information.

You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain services if we do not have the necessary personal information.

b. Right to opt–in and opt-out of marketing email communications

You have the right to opt-in and opt-out from marketing communications. We provide an unsubscribe link in all marketing communications. If you opt-out of receiving marketing email communications, we may still send you email messages related to your account or specific transactions with us.

c. Rights of data subjects

You have the right to receive confirmation from FlatironDragados as to whether your personal data is being processed.

Rights of access, to rectification and to erasure of your data
You have the right to access your personal data, as well as to request rectification of data that are inaccurate or, where appropriate, to request erasure of your data when, among other reasons, they are no longer necessary for the purposes for which they were collected.
Right to restriction of processing
In certain circumstances, you may request that the processing of your data be restricted, in which case only the minimum data will be kept for the exercise or defense of claims.
Right to object
Users may request that their data not be processed. This right will be complied with unless there are compelling legitimate reasons or it is necessary for the exercise or defense of possible claims.
Right to data portability
Users have the right to have their data processed by virtue of the consent they have given us or by virtue of a contract entered into, transmitted to them in a structured, commonly used and machine-readable format (interoperable format).
Right to withdraw consent
You are entitled at any time to withdraw your consent to the processing of your data that we carry out pursuant to the consent you have given. Upon withdrawal, the processing will cease, unless there is another cause that legitimizes us to continue the processing. However, said withdrawal will not produce retroactive effects, and therefore the processing carried out up to that time will not be affected.
How to exercise your rights
To exercise any of these rights, you may contact FlatironDragados by mail at:
- Flatiron Dragados USA, Inc.
  ATTN: Privacy Officer
  810 Seventh Avenue,
  9th Floor, New York,
  New York 10019
  Or email: Privacy@FDCorp.com
- Flatiron Dragados Canada, Inc.
  ATTN: Privacy Officer
  150 King Street West,
  Suite 2103Ontario (Toronto)
  Canada M5H 1J9
  Or email: Privacy@FDCorp.com

IV. Data protection of the website and job applicants

a. Purpose

Data processing is limited to one of the following purposes:

To deal with queries from users who contact us at the addresses provided and to send the information requested.
Receive and handle resumes and curricula vitae in the recruitment processes the user participates in.

b. Legitimacy

By providing personal data through the forms provided on the website or by using the e-mail address provided and sending your contact details, the user expressly consents to FlatironDragados being able to process such data under the terms of this Privacy and Data Protection Policy clause and for the purposes expressed.

c. Data retention

Contact data will be kept for as long as the relationship is maintained and erasure thereof has not been requested. In any case, the data retention periods shall be established in accordance with the applicable legal statute of limitations.

Data related to job applications will be kept for a maximum period of 5 years if erasure thereof has not been requested and always in compliance with the applicable legal limitation periods. If you wish to have your application erased, you can request it by email at the appropriate email address below in Section VI.

d. Data recipients

No assignments or transfers of your data are envisaged, other than to companies belonging to FlatironDragados group, pursuant to the purposes specified in this Policy.

V. Data protection and reporting line users

a. Purpose

FlatironDragados uses your data in order to ensure proper management of the reporting line, coordination of Compliance systems and internal legal advice as well as to defend our rights and interests, to detect offences and prevent any criminal liability being brought against FlatironDragados and to prevent any type of conduct contrary to the company's internal or external regulations.

b. Legitimacy

Data processing is based on the public interest consisting of creating and maintaining an information system for internal complaints and investigating possible irregularities or acts contrary to ethics, legality or corporate rules, on the legitimate interest of FlatironDragados in preventing such conduct and in seeking to defend the legitimate rights and interests of FlatironDragados, as well as on the legal obligation to resolve the complaints and queries made, and, where appropriate, for the filing, pursuit or defense of claims.

Processing of the personal data of the complainant, respondent or third parties is strictly necessary to manage the complaint and to comply with the aforementioned purposes and legal obligations. Under no circumstances will FlatironDragados carry out automated decisions based on the data submitted.

c. Data retention

FlatironDragados will keep a record of all complaints received on a confidential basis. Records shall not be kept for longer than necessary and shall be retained for as long as necessary to comply with any applicable legal requirements at any given time.

More specifically, FlatironDragados will keep the personal data of the complainant for the time necessary to decide whether to initiate an investigation into the facts or conduct reported and, once decided, this data will be removed from the reporting line, and may be processed outside the system to investigate the facts for the time necessary to reach a decision. Once the investigation of the report has been completed and any appropriate action has been taken, the data of those reports that have been processed shall be duly blocked in order to comply with the legal obligations that may apply in each case.

Personal data contained within the reporting line will be maintained for the length of the employment of the respondent and archived for a minimum period of four (4) years following the termination of the respondent’s employment. Retention for a longer period may occur if required to comply with a Company legal or corporate obligation.

d. Data recipients

Personal data collected in the context of a complaint made through the channels may be processed or communicated to the following parties where necessary:

The service provider of the platform which manages the channels;
FlatironDragados' Compliance Department;
Authorized representatives of FlatironDragados, where necessary;
External advisor who may provide assistance in assessing the report, investigating the matter or advising FlatironDragados on the issue at hand;
Police or other regulatory or law enforcement authorities.

The data may also be submitted, together with the complaint made, to a division or subsidiary of ACS Group in the event that the facts reported affect them or should be investigated by them.

No international data transfers are envisaged, other than within FlatironDragados.

e. Children

FlatironDragados’ services are not directed to persons under 13 years of age. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that their child has provided us with personal information without the parent’s consent, they should contact us at Privacy@FDCorp.com. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our records.

f. Californian Consumers’ Rights Under the California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act of 2018 provides California consumers (California residents) with specific rights regarding their personal information. If you are a California resident, you have the rights under data protection law which are explained in the CCPA Policy.

g. Visitors outside North America

This Privacy Policy is intended to meet the laws and requirements of the United States and Canada, which may not necessarily be consistent with or as comprehensive as the laws and regulations of other countries. If you are located outside of the United States or Canada, please be advised that any information you provide to us will be transferred to the United States and that by submitting information, you authorize its transfer. Where Personal Information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.

h. For Canadian Residents

Requesting access to their own personal information must be received in writing to the Privacy Officer. You must provide sufficient information to your request to allow us identify the information you are seeking. In addition, you may request a correction of an error or omission in your personal information.

We will respond to your request within 45 calendar days, unless an extension is granted. We will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.