Privacy Policy

Privacy Policy


Last Updated: June 5, 2017

1. Purpose. Thank you for visiting the Fuel Cycle website and reviewing our privacy policy. Your privacy is important to us. We are committed to respecting your privacy and recognize your need for appropriate safeguarding of any Personal Information (as defined in Section 6(a) below) that you share with us.  We have prepared this Privacy Policy to explain how FUEL CYCLE, Inc. (“FUEL CYCLE”, “we,” or “us”) collects, uses, and shares Personal Information we obtain from you when you use the FUEL CYCLE websites or services, and/or otherwise participate in an online community that FUEL CYCLE conducts on behalf of its corporate clients (each a “FUEL CYCLE Client”) through a FUEL CYCLE-hosted website, mobile or other application (each, a “Site” and collectively, the “Sites”) or otherwise provide to us in any way. Your use of any Site may be subject to FUEL CYCLE’s Terms of Service (which can be found at: and/or the FUEL CYCLE Client’s Terms and Conditions of Use, among other policies including their privacy policies. Because the Internet is global, Personal Information may be transferred to, obtained from, and processed or stored in countries (including the United States of America) other than the one in which you reside. By using any Site, you explicitly consent to such use of your Personal Information and agree to the terms of this Privacy Policy.

2. FUEL CYCLE Client Privacy Policy. Please note that this Privacy Policy only governs FUEL CYCLE’s use of your Personal Information. The FUEL CYCLE Client’s use of your Personal Information is governed by the FUEL CYCLE Client’s own privacy practices and you should review the FUEL CYCLE Client’s applicable Privacy Policy to understand its privacy practices.  We are not responsible for the FUEL CYCLE Client’s privacy practices, and/or for any materials or information contained on any non-FUEL CYCLE site (including without limitation any FUEL CYCLE Client’s website) that may be accessed from a Site. This policy was last updated as of the date first set forth above.

3. Non-Personally Identifiable Information. We automatically collect certain information from you when you visit a Site to help us understand how you use the Site (which we will refer to in this Privacy Policy as “Non-Personally Identifiable Information”). For example, each time you visit a Site we may automatically collect your IP address, browser and computer type, Internet service provider (ISP), access date and time, the clickstream data, the web page from which you came, and the web page(s) that you accessed during your visit. Additionally, when you access a site from a mobile device, we may automatically collect information on the type of device you use, operating system version, and the device identifier. We (and potentially our marketing partners, clients, affiliates, and service providers) may also use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive), beacons, tags, scripts, and/or mobile analytics to keep track of your use of the Sites, to validate your identity, to remember your username, password and preferences, to analyze trends, to track users’ movements, to gather demographic data, to provide targeted advertising, to tailor the Sites to meet your personal interests, and to improve the quality of the Sites, among other things. We may receive reports based on the use of these technologies on an individual as well as aggregated basis. We do not link the information we store in cookies to any Personally Identifiable Information (as defined in Section 4, below) that you provide to us through the Sites.  Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie from us or any third party, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain areas of the Sites may not function properly or as effectively as possible.

4. Personally Identifiable Information. You may have to register with FUEL CYCLE to use the Sites. As part of the registration process, you will be asked to provide certain information by which (either alone or in combination with other information provided by you) someone could personally identify you (which we will refer to in this Privacy Policy as “Personally Identifiable Information”), including for example, your first and last name, your home address, your email address, your date of birth, etc. Each FUEL CYCLE Client identifies the Personal Information that it wishes FUEL CYCLE to obtain from you on its behalf in its own policies and/or notifications to you from time to time. We collect your Personally Identifiable Information for the purposes of providing services, managing and monitoring your account(s) with us, and passing such Personally Identifiable Information to the relevant FUEL CYCLE Client on whose behalf we have collected it in the first instance. Each FUEL CYCLE Client’s use of your Personally Identifiable Information will be governed by their Privacy Policy and we shall not be liable in any way for their use or misuse of any such information at any time.

5. Sensitive Personal Information. If we ask you to provide sensitive Personally Identifiable Information (i.e. information specifying medical or health conditions, personal financial information, geo-locational information, social security number, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information regarding your sex life, among similar such information) (referred to herein as “Sensitive Personal Information,” and included as part of the Personally Identifiable Information, as applicable), we will require that you first affirmatively agree (i.e., opt-in) to provide such information before we collect it from you. The information we request is not designed for any discriminatory purpose and you are not required to provide any such Sensitive Personal Information if you do not wish to do so, although your use of any Site may be affected thereby.

6. Our Information Use and Sharing Practices.
(a)           Generally. Except as otherwise permitted herein or required by applicable law, rule or regulation, we will never share your: (i) Non-Personally Identifiable information; (ii) Personally Identifiable Information; and/or (iii) Sensitive Personal Information (collectively, your Personal Information”), with any third party without your permission.

(b)           FUEL CYCLE Client.  Notwithstanding the foregoing, we provide some or all of your Personal Information to the particular FUEL CYCLE Client on whose behalf we have collected your Personal Information through any of the Sites, and such FUEL CYCLE Client may contact you regarding goods or services in which you may be interested, among other reasons. We will not share your Personal Information with any other FUEL CYCLE Client without your prior express permission other than as set forth herein or as required by law.

(c)           Aggregated Data.  We collect and use aggregated Personal Information of some or all users who use the Sites for the purpose of enhancing users’ experiences using FUEL CYCLE’s service, and providing feedback to FUEL CYCLE Clients.  From time to time, we may share aggregated Personal Information with third parties without having to obtain your permission. However, we will not share any aggregated Personal Information in any manner that would enable the recipient to personally identify you without your express permission other than as set forth herein or required by law.

(d)           Service Providers.  Notwithstanding anything set forth herein to the contrary, from time to time, we may enter into relationships with third parties who provide services to us (e.g., we outsource a portion of our electronic mailing to a third party). In those circumstances, we only disclose Personal Information that is necessary for such service providers to perform those services on our behalf, and we require that they maintain the confidentiality of such Personal Information. Such provision shall not be deemed a breach of the terms hereof, and we shall not be liable for their misuse or unauthorized dissemination of any Personal Information unless such activity is the direct result of our gross negligence or willful misconduct.

(e)           Site Access/Improvement. We may view, store and use Personal Information: (i) to provide access to and use of the Sites and related services, (ii) to communicate with you concerning your account and customer service issues, (iii) to personalize, customize, and improve the Sites and related services (including without limitation the provision of marketing and advertising communications from us and third parties), (iv) to ensure the technical functioning of the Sites and related services, (v) to develop new services, and (vi) to protect the copyright and other intellectual property-protected content of our Sites and related services.

(f)            Other Disclosure Scenarios.  Notwithstanding anything in this Privacy Policy to the contrary, we reserve the right, and you hereby expressly authorize us, to share or use any Personal Information: (i) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims; (ii) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (iii) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of any Site’s infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things); (iv) to our parent company, subsidiaries, affiliates, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (v) if we are acquired by or merge with another entity. We may also be required to disclose a user’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We will provide an individual opt-out or opt-in choice before we share Sensitive Personal Information with third parties other than as expressly permitted here under, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your Personal Information, please submit a written request to and we will comply with your request subject to the terms hereof. FUEL CYCLE’s accountability for Personal Information that it receives from a participating European Union member of the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles which can be found online at: In particular, FUEL CYCLE remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process Personal Information on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless, and subject to the Privacy Shield Principles, FUEL CYCLE proves that it is not responsible for the event giving rise to the damage. Please see Section 12 for more information on this subject matter.

7. Public Information. If you identify any Personal Information as public, you are authorizing us to share such information publicly in any manner we elect at any time. Also, there may be areas of the Sites (e.g., message boards, discussion rooms, and other online forums) in which you are able to post information that will be available to all other users of the Sites.  By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas and as such, immediately upon posting, the materials or information you post shall be considered public information (and no longer Personal Information subject to privacy restrictions).

8. Accessing, Modifying, and Deleting Your Personal Information. If you would like to modify or delete from our database any Personal Information stored in your profile, or if you would like to delete your profile completely, you can do so as follows: log into the FUEL CYCLE Client online community and proceed to the “My Account” section where you have the ability to edit your information or close your account. We will use all reasonable efforts to implement these changes within ten (10) calendar days. Please note that any Personal Information that we have copied may remain in back-up storage for some period of time after your request. We will also be unable to recover any Personal Information from any FUEL CYCLE Client once it has been transferred to such client. Also, please note that we will maintain all Personal Information in our database whenever we are required to do so by law, and/or if and as necessary in order to resolve disputes and enforce our agreements.  We retain your Personal Information during the term of the particular project that we are conducting on behalf of the relevant FUEL CYCLE Client, and for a period of sixty (60) calendar days after the termination of such project, but in no event longer than allowed by applicable law. FUEL CYCLE acknowledges that certain EU individuals have certain rights to access the Personal Information that we maintain about them, subject to the terms of the Privacy Shield Principles.  An individual who seeks access to, or who seeks to correct, amend, or delete inaccurate data, should direct their query to  If requested to remove data, we will respond within a reasonable time frame.

9. Security. We implement reasonable industry-standard security technologies and procedures measures to help protect your Personal Information from loss, misuse, unauthorized access, alteration, destruction, seizure, theft or disclosure.  Unfortunately, however, no data transmission over the Internet can be guaranteed to be one hundred percent secure.  As a result, while we strive to protect your Personal Information, we cannot guarantee its security and as such, the inadvertent dissemination of such information shall not be deemed a breach hereof by FUEL CYCLE unless and to the extent caused by our negligence or misconduct. In addition, FUEL CYCLE is unable to control how other users will utilize the information you share with them. FUEL CYCLE disclaims any responsibility or liability of any kind or nature with respect to the sale, misuse, or dissemination of any information you share with other users or third parties, including without limitation your Personal Information. To that end, we ask that you not share any Sensitive Personal Information about yourself or other contacts through the Sites or related services at any time. Unauthorized attempts to upload information or change or misuse information on any Site are strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.

10. Children’s Privacy. We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests.  The Sites are not intended for and may not be used by children under the age of 13.  We do not knowingly collect information from children under the age of 13 and we do not direct the Sites to, or encourage use of the Sites by, children under the age of 13.

11. Changes. We may update this Privacy Policy from time to time in our sole discretion.  If pursuant to any such update we make any material change in the way we treat your Personal Information, we will inform you by posting a notice on relevant areas of the Sites.  Any updated version of this Privacy Policy will be effective as of the date set forth therein. We encourage you to periodically check our website for the latest information on our privacy practices. Additionally, if FUEL CYCLE is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership, and, notwithstanding anything set forth herein to the contrary, we shall be permitted to transfer all of your Personal Information as an acquired asset to any such party without being in breach of the terms hereof.

12. Privacy Shield. FUEL CYCLE is a participating member of and complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  FUEL CYCLE has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit

13. Non-Solicited Communications. Except to the extent otherwise required to comply with the Privacy Shield Principles, this Privacy Policy does not govern our use of any information you provide to us when you call us, write to us, or communicate with us in any manner other than through the Sites as an active client.

14. Links. FUEL CYCLE may display links to third party websites. Please note that we cannot control and cannot be held responsible for the privacy policies (or other practices) of any such websites. You should always read the privacy policy of a website to find out more about how personal information is collected and processed.

15. Questions. In compliance with the EU-US Privacy Shield Principles, FUEL CYCLE commits to resolve complaints about your privacy and our collection and/or use of your Personal Information.  European Union individuals with inquiries or complaints regarding this Privacy Policy should first contact FUEL CYCLE at:

12100 Wilshire Boulevard, Suite 1950
Los Angeles, CA 90025
Tel: (323) 556-5400


FUEL CYCLE has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information about how to file a complaint, provided that you first contact us to resolve this issue. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield panel.

FUEL CYCLE is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).