Foghorn Labs LLC Privacy Policy for EU Residents

Effective Date: 2020-09-24
Last Updated on: 2020-09-24


This Privacy Policy for EU Residents supplements the information contained in Foghorn’s GENERAL PRIVACY POLICY and applies solely to all visitors, users, and others who reside in the European Union (“EU Residents” or “you”). Capitalized terms used in this Privacy Policy for EU Residents which are not defined will have the same meaning as used in Foghorn’s Privacy Policy linked above.


Legal Basis for Processing Personal Information under GDPR


We may process Personal Information under the following conditions:

  • Consent: You have given your consent for processing Personal Information for one or more specific purposes.
  • Performance of a contract: Provision of Personal Information is necessary for the performance of an agreement with you or for any pre-contractual obligations with you.
  • Legal obligations: Processing Personal Information is necessary for compliance with a legal obligation to which Foghorn is subject.
  • Vital interests: Processing Personal Information is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Information is related to a task that is carried out in the public interest or in the exercise of official authority vested in Foghorn.
  • Legitimate interests: Processing Personal Information is necessary for the purposes of the legitimate interests pursued by Foghorn.

In any case, Foghorn will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


Your Rights under the GDPR

Foghorn undertakes to respect the confidentiality of your Personal Information and to guarantee you can exercise your rights.


You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your Personal Information. The right to access, update, or delete the Personal Information Foghorn has about you. Whenever made possible, you can access, update, or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact Foghorn to assist you. This also enables you to receive a copy of the Personal Information Foghorn holds about you.
  • Request correction of the Personal Information that Foghorn has about you. You have the right to have any incomplete or inaccurate Personal Information Foghorn holds about you corrected.
  • Object to processing of your Personal Information. This right exists where Foghorn is relying on a legitimate interest as the legal basis for its processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Information on this ground. You also have the right to object where Foghorn is processing your Personal Information for direct marketing purposes.
  • Request erasure of your Personal Information. You have the right to ask Foghorn to delete or remove Personal Information when there is no good reason for Foghorn to continue processing it.
  • Request the transfer of your Personal Information. We will provide to you, or to a third-party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for Foghorn to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Information. If you withdraw your consent, Foghorn may not be able to provide you with access to certain specific functionalities of the Foghorn Website.

Exercising of Your GDPR Data Protection Rights


You may exercise your rights of access, rectification, cancellation and opposition by contacting Foghorn. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, Foghorn will try its best to respond to you as soon as possible.


You have the right to complain to a Data Protection Authority about Foghorn’s collection and use of your Personal Information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.


Tracking Technologies and Cookies


“Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.


We use Cookies and similar tracking technologies to track the activity on our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the Website.


You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Website.


Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.


We use both session and persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
    Type: Session Cookies
    Administered by: Foghorn Labs
    Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and Foghorn only uses these Cookies to provide you with those services.
  • Cookies Policy / Notice Acceptance Cookies
    Type: Persistent Cookies
    Administered by: Foghorn Labs
    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies
    Type: Persistent Cookies
    Administered by: Foghorn Labs
    Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
  • Tracking and Performance Cookies
    Type: Persistent Cookies
    Administered by: Third-Parties
    Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
  • Targeting and Advertising Cookies
    Type: Persistent Cookies
    Administered by: Third-Parties
    Purpose: These Cookies track your browsing habits to enable Foghorn to show advertising which is more likely to be of interest to you. These Cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with Foghorn’s permission, third party advertisers can place Cookies to enable them to show advertisements which Foghorn thinks will be relevant to your interests while you are on third party websites.


Facebook Fan Page


Data Controller for the Facebook Fan Page


Foghorn is the Data Controller of Your Personal Data collected while using the Service. A Data Controller is the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Information. As operator of the Facebook Fan Page, Foghorn and the operator of the social network Facebook are joint Data Controllers.


Foghorn has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service:


Visit the Facebook Privacy Policy for more information about how Facebook manages Personal Information or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.


Facebook Insights


Foghorn uses the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Foghorn’s users.


For this purpose, Facebook places a Cookie on the device of the user visiting Foghorn’s Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.


Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.


For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here:


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