Effective date: January 2020

SFAI | Santa Fe Associates International (“SFAI | Santa Fe Associates International” or “we”) is a national professional services firm which provides assurance, tax, financial advisory, and consulting services to private and publicly-traded businesses, as well as to individuals (the “Services”). This Privacy Statement outlines our general policy and practices for protecting the personal information that we collect through our Web site at www.sfai.com.kw and other Web sites (each, a “Site”) that we operate and in connection with the provision of the Services. This Privacy Statement explains the types of information we gather through our Sites and in connection with our Services, how we use that information, and the choices individuals may exercise regarding our use of, and their ability to correct, that information. By submitting personal information to us, you are consenting to use of your personal information (including any disclosures, processing, and transfers of your information to third parties by SFAI | Santa Fe Associates International) in accordance with this Privacy Statement. Any consent you provide is entirely voluntary. If you do not accept this Privacy Statement, then you should not submit any personal information to SFAI | Santa Fe Associates International through this Site or in connection with any Services.

In order to use this Site, you do not need to send us any personal information. You may voluntarily provide us directly or via our service providers with personal information, such as your name and contact information, by submitting your resume or work history information, subscribing to publications, joining our mailing lists, participation in online surveys or self-assessment tools, registering on the “Log In” page, registering for events (e.g., webcasts, seminars, or conferences), requesting access to specific content, responding to a survey, submitting requests to meet with SFAI | Santa Fe Associates International representatives or by submitting requests through our “Contact Us” or “Submit RFP” mailboxes. In some instances, we or our service providers using online identification technologies, such as cookies and beacons, may automatically collect certain types of information when you visit our Sites or through the emails we exchange. We may use the personal information you submit through the Site to respond to your requests, send you information about SFAI | Santa Fe Associates International’s services or events, send you administrative information or notices, send you information about our services, advertise our services to you on other sites or social media platforms, provide a more personalized experience, improve our Site, and for our internal business purposes. If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using the contact information listed below.

We do not seek sensitive personal information on this Site except where we are required to do so as part of the recruitment process. If you choose to apply for a job through our Site, we may collect information such as your name, address and other contact information, work and educational experience, licenses and certifications, and other personal information. Your decision to submit such information is entirely voluntary. We may use this information to process and evaluate your application for employment and to communicate with you about employment opportunities. We may also retain and use this information to identify, and communicate with you about, future potential employment opportunities with us. If we elect to make an offer of employment, this information may become part of the employee file and may be used for other employment and work-related purposes.

In connection with providing Services, SFAI | Santa Fe Associates International enters into contracts with its clients that describe the purpose for which information (including personal information) is collected and used. Companies that engage SFAI | Santa Fe Associates International are responsible for obtaining, as required pursuant to law or regulation, consents from parties that provided the company with their personal information, which will be transferred to and used by SFAI | Santa Fe Associates International to perform the Services requested. Individuals that engage SFAI | Santa Fe Associates International will be asked to consent to provide their personal information to us to perform the Services requested.

Our legal basis for processing any personal information provided to us is either that (i) you have expressly consented to the practices described in this Privacy Statement by voluntarily providing your personal information to SFAI | Santa Fe Associates International; (ii) such processing is necessary for the performance of a contract where SFAI | Santa Fe Associates International has been engaged to provide Services; (iii) to meet legal, regulatory or professional standards obligations; or (iv) to perform activities in furtherance of our lawful and legitimate interests. Examples of such lawful and legitimate interests for use of data in our possession or control include: conducting internal administrative activities, marketing our services and analyzing our marketing efforts, and enhancing and personalizing a visitor’s experience on our Sites.

We do not use profiling or make any decisions based solely on the automated processing of your personal information. We retain personal information for only so long as necessary for the intended purpose for which it was collected unless a longer retention period is required or permitted by law or our document retention policies based on professional standards and best practices. We may also store your name, email address, and other contact information such as company, title and industry in a customer relationship management tool and use it to manage our relationship with you and/or your company.

As is the case with many commercial Web sites, SFAI | Santa Fe Associates International automatically logs certain information about visitor access to a Site, which may include a visitor’s internet protocol address, browser type, language, internet service provider, pages and content viewed, referring/exit pages, and/or operating system, as well as date and time stamps. A visitor’s IP address may be used for IT security and systems diagnostic purposes. It may also be used in aggregate form to understand Site usage trends and performance analysis.

We use “cookies” which are small data files stored on a visitor’s computer or internet-enabled device that serve a number of purposes such as enhancing your online experience when visiting our Sites by remembering elections made, content accessed or downloaded, and responses to forms and surveys. The use of “cookies” is common practice for most Web sites; however, most Web browsers include settings that allow users to decline cookies. If you do not accept our cookies, you may not be able to fully experience some of our Site’s functionality. After you finish browsing our Sites, it is possible for you to delete cookies from your system if you choose to do so.
Further information about managing cookies can be found in your browser’s help file or through sites such
as www.allaboutcookies.org or www.cookiecentral.com.

BY NAVIGATING ON OUR SITES, YOU AGREE THAT WE CAN PLACE THESE COOKIES AS EXPLAINED ABOVE ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

We use the services of Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This analytical tool uses cookies and other similar technologies to help analyze how visitors use the Sites. For more information about the collection and use of data through Google Analytics, please refer to www.google.com/policies/privacy/partners. Google offers the ability to opt-out from tracking through Google Analytics cookies. For more information, visit http://tools.google.com/dlpage/gaoptout. Google has developed the Google Analytics Opt-out Browser Add-on to provide Web site visitors with more choice on how their data is collected by Google Analytics. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the Web site visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the Web site itself or to other Web analytics services.

We or our digital media service providers also use Web beacons; a small transparent image also referred to as a tracking pixel to help us better understand the effectiveness of our content and advertisement, the interests of our visitors, and to improve the visitor experience on the Sites. These beacons allow us to determine which visitors have come to this Site after viewing an advertisement we have served on third-party Web sites. We also work with such third parties to collect data so that we can determine the effectiveness of our ads and serve ads targeted to your interests. The use of Web beacons does not provide us with any personal information and we do not use this technology to access your personal information. It is used only to compile aggregated data about visitors to this Site.

Web beacons do not place information on your device but may work in conjunction with cookies to monitor activity. You have the option to render some Web beacons unusable by rejecting their associated cookies. The Web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

In some of our newsletters and other email communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge visitor interest and to enhance future visitor experiences.

If you do not wish us to confirm whether you have opened, clicked on or forwarded our communications, you will need to unsubscribe, as it is not possible for us to send these emails without tracking enabled. Registered subscribers can update their communication preferences at any time by following the instructions in the individual email communications you receive from us.

Some Web browsers incorporate a “do-not-track” or similar feature that signals to Web sites with which the browser communicates that a visitor does not want to have his or her online activity tracked. As of the effective date of this Privacy Statement, not all browsers offer a “do-not-track” option, and “do-not-track” signals are not yet uniform. For this reason, SFAI | Santa Fe Associates International does not currently respond to “do-not-track” signals.

We at times use Web services from third-parties on this Site to present content within the pages of this Site, e.g. to display videos and social content, to conduct surveys, etc. We cannot prevent these Web services from collecting information on your usage of this embedded content and recommend that you review their respective terms of use and privacy policies for further information.

We provide visitors the capability to share links to our content via social media and email. This capability connects the visitor directly with their third-party social media sites and email service provider. No personal information, IDs or passwords are made available to or stored by SFAI | Santa Fe Associates International in connection with this activity. After the content sharing is initiated, all interactions are directly between the user and their respective social media platform or email provider. We recommend reviewing the respective terms of use and privacy policies of your social media sites and email service provider for further information.

We provide visitors the convenience of auto-filling Web Site forms with their contact information from LinkedIn. Auto filling forms is voluntary and only provides SFAI | Santa Fe Associates International with the basic contact information requested in the form. No other personal information, IDs or passwords are made available to or stored by SFAI | Santa Fe Associates International in connection with this activity. We recommend reviewing the LinkedIn privacy policy for further information
at www.linkedin.com/legal/privacy-policy.

SFAI | Santa Fe Associates International will not disclose an individual’s personal information to third parties, except as set forth in this Privacy Statement, when we have permission to make the disclosure, to advertise our services to you on other sites or social media platforms, or as necessary to fulfill the purpose for which the information was submitted. We also may use or disclose personal information as we believe to be necessary or appropriate (i) under applicable law (including to meet a national security or law enforcement requirement); (ii) to comply with legal process or professional standards; (iii) to protect our rights, privacy, safety or property and/or those of our affiliates or clients; or (iv) in a merger, acquisition or asset sale. We will not transfer the personal information you provide to any third parties for their own direct marketing use. Our service providers will disclose an individual’s personal information to us when the service provider collects the information on our behalf.

SFAI | Santa Fe Associates International may use third-party service providers to provide administrative, marketing, or operational services to SFAI | Santa Fe Associates International. Such entities may be located within or outside the United States and, depending upon the services, they may have access to personal information in connection with their services. We require all such service providers to protect the information we entrust to them and to use such information only as necessary to provide services to us.

This Privacy Statement does not address, and we are not responsible for, the privacy, information, or other practices of any third party, including any third party operating any Web site or service to which the Site links. The inclusion of a link on our Site does not imply endorsement of the linked site or service by us or by our affiliates.

The security of your personal information is important to us. We seek to use reasonable physical (e.g. key card office entry, locking doors), technical (e.g. password protection, network firewalls, laptop encryption, authentication mechanisms), and administrative safeguards (e.g. confidentiality agreements, training, procedures that limit access to and use of data) to protect the information we process. However, no method of transferring data over the Internet or storing electronic data is completely secure. Therefore, while we strive to use reasonable and appropriate means to protect your personal information, we cannot guarantee absolute security.

We process personal information only in ways compatible with the purpose for which it was collected, as subsequently authorized by the individual, or as otherwise permitted by applicable law. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.

If an individual becomes aware that information, we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. We may limit or deny access to personal information where providing such access would be unreasonably burdensome or inappropriate under the circumstances. All requests to access or change personal information will be handled in accordance with applicable legal requirements.

We will investigate and attempt to resolve complaints and disputes regarding our use and disclosure of personal information in accordance with this Privacy Statement. We encourage interested persons to raise any concerns with us using the contact information below. Any employee who we determine is in violation of our privacy policies will be subject to disciplinary process.

In the event SFAI | Santa Fe Associates International goes through a business transition, such as a merger, or the acquisition or sale of all or a portion of its assets, your personal information may be among the assets transferred.

SFAI | Santa Fe Associates International reserves the right to amend or modify this Privacy Statement from time to time. We will post any revised Privacy Statement on this Site, or a similar Web site that replaces this Site. By continuing to use any of our Sites, you agree that the terms of this Privacy Statement as of the effective date will apply to information previously collected or collected in the future as permitted by law.

This Site is not designed for or directed at persons 18 years of age or younger, and we do not intentionally collect information from anyone under the age of 18 through this Site.