Last updated April 06, 2020
Thank you for choosing to be part of our community at FanAI Inc. (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- WHO WILL YOUR INFORMATION BE SHARED WITH?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DATA BREACH
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Personal Information. We collect first name, maiden name, last name, and nickname; ID; current and former address; phone numbers; email addresses; social media; and other similar data.
Personal Information Provided by You. We collect financial information (invoices); and other similar data.
Information automatically collected
In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Online Identifiers. We collect cookie identifiers, or others such as the ones used for analytics and marketing; device’s geolocation; and other similar data.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third parties.
We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
- Cloud Computing Services
Google Cloud Platform
- Data Backup and Security
Google Drive Backup
- Functionality and Infrastructure Optimization
Cloud Firestore and Firebase Hosting
- Web and Mobile Analytics
- Website Performance Monitoring
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are an EEA resident, you have the right to access, rectify, download, or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:
You can access your personal data by submitting a data subject access request. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You may also request to correct any incomplete or inaccurate personal data that we hold about you. However, we may need to verify the accuracy of the new data you provide to us.
You have the right to ask us to rectify, restrict, limit, or remove the processing of your personal data where (1) there is no good reason for us to continue processing it, (2) we may have processed information inaccurately, unlawfully or (3) we were required to erase for compliance with local law. Note that we may not always be able to comply with your request to erase for specific legal reasons, which will be notified to you at the time of your request.
You may also request the transfer of your personal data to a third party, in which we will provide your personal data in a structured, commonly used and machine-readable format. This right only applies to automated information that you previously consented for us to use and/or used to perform a contract with you.
You may object to the processing of your personal data in certain circumstances when relying on a legitimate interest of yours or of a third party that you feel impedes on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which overrides your rights and freedoms.
You may also withdraw consent to processing your personal data at any time. This does affect the lawfulness of any processing we have done prior to your consent withdrawal, and we may not be able to provide certain products or services to you after your consent withdrawal. We will notify you if this is the case at the time of your consent withdrawal.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any other right). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within thirty (30) days. Occasionally, however, it may take us longer to process your request if it is particularly complex and/or if you have made multiple requests. In this case, we will notify you and keep you updated on the status of your request(s).
Your Right to File a Complaint
If you are based in the European Union, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO)—the UK supervisory authority for data protection issues ICO UK. We would, however, appreciate the chance to address your concerns before you approach the ICO so, please contact us in the first instance.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Contact us using the contact information provided.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
■ Contact us using the contact information provided.
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when FanAI Inc. believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that FanAI Inc. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information FanAI Inc. will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
CCPA (California Consumer Protections Act) Disclosures
The CCPA requires businesses that are subject to this law to provide consumers who reside in California with certain rights with respect to their personal information.
As a California resident and within 45 days, FanAI will respond to your right to:
Request a copy of the specific personal information collected about you during the 12 months before your request (a “personal information request”);
- Have such information deleted (with exceptions);
- Request that your personal information not be sold to third parties, if applicable; and
- Not to be discriminated against because you have exercised any of these rights.
Should you choose to exercise any of your rights above, CCPA allows consumers to make a personal information request no more than twice in a 12-month period and that business will need to collect information from the requesting party so that It can verify a Consumer’s identity.
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Karim Varela, by email at firstname.lastname@example.org, or by post to:
1411 5th St #202, Santa Monica, CA 90401
Santa Monica, CA 90401
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to email@example.com. We will respond to your request within 30 days.
Applicable Laws means laws, rules, directives, regulations issued or enacted by any government entity (including any domestic or foreign, supra-national, state, county, municipal, local, territorial or other government, which includes to the extent applicable, Directive 95/46/EC, Directive 2002/58/EC, European Commission decisions and guidance) each as transposed into domestic legislation of each Member State or other country and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR, and any industry self-regulatory principles that are applicable in the location or region where the Services are provided or received, related to the Processing of Personal Data or the interception, recording or monitoring of communications.
CCPA means Assembly Bill 375 of the California House of Representatives, an act to add Title 1.81.5 (commencing with Section 1798.100) to Part 4 of Division 3 of the Civil Code, relating to privacy and approved by the California Governor on June 28, 2018 (California Consumer Protection Act, “CCPA”).
EU Model Clauses means the standard contractual clauses approved by European Commission on standard contractual clauses for the transfer of Personal Data to Processors or Controllers established in third countries (but which shall exclude any contractual clauses designated by the European Commission as optional in that decision), as amended or replaced from time to time by the European Commission.
GDPR (General Data Protection Regulation) means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC; The terms, “Controller”, “Processor” “Data Subject”, “Member State”, “Personal Data” or “Data”, “Personal Data Breach”, and “Processing”, and “Supervisory Authorities” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.