Freeh Sporking & Sullivan, LLP
Freeh Group International Solutions graphic

Privacy Policy

Last Updated: September 27, 2011

This Privacy Policy (the Privacy Policy) describes the information that Freeh Sporkin & Sullivan, LLP and its affiliates ("FSS") collect through FSS website located at ("the Site") and how we use that information.  A list of our affiliates can be found below.  Please note that the Privacy Policy applies solely to FSSS online information-gathering and dissemination practices in connection with the Site, and does not apply to any of FSS practices conducted offline.  If you have any questions or comments about the Privacy Policy or FSS privacy practices, please contact us at [email protected] .

Please read the Privacy Policy before you visit the Site and/or provide information on the Site.  Your use of the Site signifies that you agree with all the terms of the Privacy Policy, so please do not use the Site if you disagree with any part of this Policy.  Where you provide information about others (e.g., for colleagues) you must ensure that you are entitled to provide this information to us.

The Internet and the benefits it offers are evolving rapidly, as are the ways in which people use the Internet and the laws surrounding such use.  FSS therefore reserves the right to update and revise the Privacy Policy at any time, without prior notice to you.  You can determine if the Privacy Policy has been revised since your last visit by referring to the "Last Updated" legend at the top of this page.  Your use of FSS Site following such revision constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us, and you should therefore review the Privacy Policy regularly to ensure that you are aware of its terms.  Please print, save, and retain a copy of the Privacy Policy (and of any revised version) for your records.

The Information That We Collect
FSS gathers "Personally Identifiable Information" (or "PII"), "Site Usage Data," and "IP Addresses" through the Site.  Personally Identifiable Information is information that identifies a person as an individual, such as your name, company, and title, postal address, telephone number, or email address.  Site Usage Data is aggregated information, demographic information, and any other information that does not reveal a person's specific identity.  An IP Address is the Internet Protocol address of the computer that you are using. Site Usage Data, IP Addresses and any other information that does not reveal your specific identity or does not directly relate to an individual shall be referred to in this Privacy Policy collectively as "Other Information."

  1. Personally Identifiable Information.  You do not have to provide us with your PII to use this Site. However, certain services to which you may subscribe through this Site (e.g.,FSS event announcements) may require you to provide PII.  We collect PII from you only when you voluntarily provide it to us. Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site. Aggregated Personal Information does not personally identify you or any other user of the Site, (for example, we may use aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code.  
  2. Site Usage Data.  When you visit and interact with the Site, FSS and third parties with whom FSS has contracted to provide services to FSS may collect Site Usage Data (for example, a catalog of the Site pages you visit).  Such non-PII may include your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version. We use this information, which is collected by most browsers, to ensure that our Site functions properly. Site Usage Data may also include demographic data, such as your location.  To enhance your Internet experience on the Site, FSS and FSS service providers may use cookies on the Site.  Cookies are data that a web server transfers to an individual's computer for recordkeeping and other purposes.  We use cookies and other technologies to facilitate user's ongoing access to and use of FSS Site.  Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while visiting the Site, as well as for online tracking purposes. We can recognize your computer to assist your use of the Site. We also gather statistical information about the usage of the Site in order to continually improve the design and functionality, understand how customers use the Site and to assist us with resolving questions regarding the Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular web site.  If cookies are disabled, however, not all features of the Site may operate as intended.  Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider's web site.  FSS and FSS service providers may also use various Internet technologies such as 'pixel tags, 'action tags,' 'web bugs,' '.gif tags,' 'JavaScript' or similar technologies (together, "Tracking Tools") in connection with Site pages and HTML-formatted email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates.  Tracking Tools allow us to count users who have visited certain pages of the Sites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns.  When used in email messages in certain formats, Tracking Tools can tell the sender whether and when the email has been opened.  FSS uses these technologies to customize and enhance the Internet experience of individual users.  When you revisit the Site, we may recognize you by a Tracking Tool and customize your experience accordingly.  For example, once you have completed the registration process, a Tracking Tool or cookie will be used to avoid having you register again.
  3. IP Addresses.  When you visit and interact with the Site, FSS and third parties with whom FSS has contracted to provide services to FSS may collect Internet Protocol ("IP") addresses.  Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider.  This number is identified and logged automatically whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

How We Use the Information We Collect

  1. Personally Identifiable Information.  FSS may use PII in the following ways:
    1. Fulfillment of Requests.  We process PII to comply with your requests, respond to your inquiries, and send you newsletters or publications that you request, to provide services, including the provision of seminars and other events, or to register you for events.   If you contact us by email through the Site, we may keep a record of your contact information and correspondence, and use it to respond to you.  We will further use PII to fulfill any other purposes for which it was provided, and as disclosed at the time the data are collected.
    2. Administrative Communications.  We may send you important administrative or transactional information regarding the Site.  Because this information may be important to you, you may not opt out of receiving these communications.
    3. Other Communications.  We may use PII about you to send you FSS mailings relating to FSS that we think may be of interest to you, in accordance with applicable law.  If you decide at any time that you no longer wish to receive mailings from us, please refer to the paragraph below, headed Opting Out. Please note that some of these mailings may be provided by FSS affiliates.  If you are a Californian user of the Site, and would like more information regarding FSS provision of your PII to these other legal entities of FSS, please refer to the paragraph below headed Special Notification for FSS California Users."
    4. Internal Business Purposes.  We may also use PII about you for FSS internal business purposes, such as data analysis, audits, and other similar purposes.
  2. Site Usage Data.  Because Site Usage Data does not personally identify you, we may use such information for any purpose.  In addition, we reserve the right to share such Site Usage Data, which does not personally identify you, with third parties, for any purpose.  As an example, we may use aggregated Site Usage Data to help us improve FSS Site and the services that we provide through FSS Site.  Please note that to the extent any Site Usage Data is linked with PII, such linked information will be treated as PII as long as it is linked. 

How Is Personally Identifiable Information Disclosed?

  1. Disclosures to Affiliates.  As mentioned above, we may share PII provided to us with FSS affiliates, consistent with FSS goal of providing the highest level of global service.  Subject to local requirements, this information may be used to provide services offered by FSS affiliates and for all the purposes outlined in this policy.  FSS remains responsible for jointly used PII. 
  2. Emails to Friends.  Subject to local requirements, we may provide functionality to permit you to send messages regarding Site-related content to a friend through the Site.  If you wish to use this feature, you may be required to provide us with, and we may use, your friend's email address so that we can facilitate your sending of such message to your friend. By using this functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address.  Please note that any PII you provide in connection with sending messages regarding Site related content to anyone through the Site, such as your name and your email address, will, of course, be disclosed to that party. 
  3. Third-Party Service Providers.  We may provide PII about you to FSS contractors, agents, and designees to the extent necessary to enable them to perform certain Site related services (e.g., providing web hosting, improving Site related services and features, or providing maintenance services) on FSS behalf.
  4. Business Transfers.  FSS may transfer any and all PII to third parties (whether affiliated or unaffiliated with FSS), in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).  
  5. Law Enforcement; Compliance.  We also may use and/or disclose PII to any third party if we believe that we are required to do so for any or all of the following reasons: (i) by law, including laws outside your country of residence; (ii)  to comply with legal process or respond to requests from governmental or public authorities including public and government authorities outside your country of residence; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or FSS network; (iv) to enforce FSS Terms of Use Agreement; (v) to protect the rights, privacy, property, business, or safety of FSS and its affiliates, their partners and employees, the users of the Site, or the public, and or (vi) to protect our operations or those of any of our affiliates and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

By using the Site, you acknowledge and consent to the fact that PII provided by you or collected by us through your use of the Site may be stored and processed by us in the United States, which may provide a different level of data protection than that provided by your country of residence.  You also acknowledge and consent to the fact that we may, at FSS discretion, store and process such data in other countries and will endeavor to protect the PII under FSS control wherever it is processed or stored.

How We Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as PII under applicable law, then, in addition to the uses listed in the "The Information That We Collect" Section above, we may use and disclose Other Information for all the purposes for which we use and disclose PII.

In some instances, we may combine Other Information with PII (such as combining your name with your geographical location). If we combine any Other Information with PII, the combined information will be treated by us as PII as long as it is combined.

Information Collected by Third Parties

Third-Party Sites.  The Site may contain links to third party web sites.  These linked sites are not under FSS's control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site.  We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by FSS.  If you provide any PII through any such third-party web site, your transaction will occur on such third party's web site (not the Site) and the PII you provide will be collected by, and controlled by, the privacy policy of, that third party.  We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.  PLEASE NOTE THAT THE PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

Your Choices :

  1. Opting Out.  We may from time to time send you mailings relating to FSS that we think may be of interest to you.  If you would prefer not to receive marketing mailings from us, you may unsubscribe from these marketing mailings by following the unsubscribe instructions in any such message or by contacting us by email at [email protected]
  2. Reviewing, Changing, or Suppressing PII.  To the extent permitted by the laws of your country, you may request to review, correct, update, suppress, or otherwise modify any PII that you have previously provided through the Site, or object to the use of such PII by FSS.  You may exercise these rights by logging on to your subscriptions account on the FSS Site at or by contacting us at [email protected].
    Additionally, you may also oppose the processing or transferring of PII to the extent the laws of your country require if you have a legitimate reason to do so.

    In your request, please make clear what information you would like to have changed, whether you would like to have your PII suppressed from our database or otherwise let us know what limitations you would like to put on our use of your PII.

For your protection, we will only implement requests with respect to the PII associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will endeavor to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within FSS databases and other records, which will not be removed therefrom.  We may, from time to time, re-contact former users of the Site.  Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared PII about you.

Special Notification for Individual California Users  

As noted above, we may disclose PII to affiliates of FSS, which may use this information for all purposes outlined in this Privacy Policy.  Because separate legal entities are considered "third parties" for purposes of California Civil Code Section 1798.83, and certain communications from FSS affiliates might be viewed as promoting their services, we are providing the following information for California residents who have provided us with PII about themselves during the creation of or during the course of an established relationship that is primarily for personal, family, or household purposes ("Individual California Users").  Individual California Users may request information about FSS disclosures of certain categories of PII to third parties (i.e., other affiliated legal entities of FSS) for such third parties direct marketing purposes.  Such requests must be submitted to us either by email at [email protected]  or by mail at the following address:

Freeh Sporkin & Sullivan, LLP
3711 Kennett Pike, Suite 130
Wilmington, DE 19807

Within thirty (30) days of receiving such a request, we will provide a list of the categories of PII disclosed to third parties (i.e., other affiliated legal entities of FSS) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.  This request may be made no more than once per calendar year.  We reserve FSS right not to respond to requests submitted other than to the email or mailing addresses specified in this section.


  1. Security. FSS seeks to adopt commercially reasonable security measures consistent with industry practice to assist in protecting against the loss, misuse, and alteration of PII that is under FSS control.  Unfortunately, no data storage system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure.  As a result, we cannot guarantee the security of FSS servers, the means by which PII is transmitted between your computer and FSS servers, or any PII provided to us or to any third party through or in connection with the Site.  If you believe your connection to FSS site is no longer secure, please notify us as soon as possible.
  2. Use of the Site by Children.  The Site is not directed to children under the age of thirteen (13), and FSS does not knowingly collect PII from children.  If you are younger than thirteen (13) years old, please do not provide any PII while using the Site.
  3. Retention Period .  We will retain PII about you for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required by law and/or regulations. 
  4. Jurisdictional Issues.  FSS does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction.  Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations.  We may limit the Site's availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time, without prior notice to you, and in FSS sole discretion.  By using the Site and submitting any PII, you consent to the transfer of PII to other countries outside of your country of residence, including the United States, which may provide a different level of data security and data protection rules than that provided in your country of residence. 
  5. Contacting Us.  If you have any questions regarding the Privacy Policy, please contact us by email at [email protected] or write to us at the following address:
    Freeh Sporkin & Sullivan, LLP
    3711 Kennett Pike, Suite 130
    Wilmington, DE 19807
    Please note that email communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us. 
  6. Sensitive Information We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise to us.

 © 2011 Freeh Sporkin & Sullivan, LLP

Affiliates For purposes of the FSS Privacy Policy, the following entities are considered to be affiliates of Freeh Sporkin & Sullivan, LLP: