PRIVACY POLICY 

This Privacy Policy (“Privacy Policy”) explains how FYI.FYI (“FYI.FYI” or “we” ) collects, uses, and shares your information when you use our various services (“Services”). Using and accessing any of our Services is subject to the terms of this Privacy Policy, and by doing so you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service.

FYI.FYI is a messaging and collaboration platform that gives you the power to share your ideas and communicate with the world. We give you tools to communicate with others one-on-one (“messaging”), in collaborative circles (“groups”), and to the public at large (“posting”). We also give you tools to store and share access to files you create. That’s a lot of information you’re trusting us with – here’s how we handle and use it.

We only store the data that FYI.FYI needs to function as a secure and feature-rich messaging and collaboration tool, and keeping your data private and secure is of utmost importance to us. Most of the data collection and uses described in this Privacy Policy are necessary in order for us to be able to provide you the Services. We do collect and use data in some ways not strictly necessary for us to provide the Services, but they are related to the Services and our basis for the collection and processing are legitimate interests we have, such as to analyze and improve the Services.

INFORMATION WE COLLECT 

As we provide you the Services, we collect information in these four general categories, which we further describe below.

· Information you provide us when using our Services;

· Information we collect automatically;

· Information we get from third parties, and offline sources;

· Any other information you choose to provide to us.
 

Information You Provide Us When Using Our Services

Account Information. As part of you signing up to become a FYI.FYI user, we collect personal information you choose to provide us. That may include your name, address, email, and phone number, and other information about your interests and preferences, as well as other demographic information such as age and gender. All of this information that may identify, relate to, describe, reference, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device is called “Personal Information.”

User Content. As part of providing our messaging, group, and posting Services, as well as our file storage and collaboration services, we collect content, communications, files, and other information you provide when you use our Services (collectively, “User Content”). User content information is subject to the controls you place upon it, for example one-to-one messages are generally available to the intended recipient, but User Content, even when access is limited to you only, is accessible and may be reviewed by us for the purpose of enforcing our community standards, to comply with legal requirements, or for the purpose of improving our Services.

For more information, please see our Terms of Service. For public posts, post contents and replies are public and are publicly displayed. For group posts, all others with access to the group may read, display, and reply to any information you make available to the group. It is possible for a group member to download or otherwise copy information you share and then further share it in other forums.

We also collect information you choose to upload, sync, or import from a device (such as a contacts list or location), which we use for things like helping you and others find people you may know.
 

Information We Collect Automatically When Using Our Services

Location Information. In some cases, some functionality of our Services uses location information. If you consent to the collection of location information by permitting your mobile device to send us your latitude and longitude, or similar functions, depending on the permissions you grant us, we may collect and use this information both while you are directly using the Services and in the “background” (i.e. at times when you are not directly using the Services). Even where specific location information is not available from your device, either because of the permissions you’ve granted or for other reasons, we may use your IP address or other information collected while using the Services to infer an approximate geographic location for your device.

Usage Information. We collect pages viewed, access times, user, and content interactions and other information about your interactions with our Services.

Device Information. We collect information from and about the devices and browsers you use that integrate with our Services, including device type, operating system and version, browser type, language, IP address, plugins, battery and signal strength, available storage space, unique device identifiers and mobile network information, cookies, web beacons, or other technologies that may uniquely identify your device or browser. We may correlate information across devices you use.

Information Collected by Cookies and Other Tracking Technologies. Like most websites and applications, we and our service providers use cookies, web beacons and other technologies to collect information. Cookies are small data files stored on your hard drive or in device memory that help us and our service providers to, among other things, improve our Services and your experience by seeing which areas and features of our Services are popular. Most web browsers are set to accept cookies by default. For more information about cookies and how to disable them, please see “YOUR CHOICES” below. Keep in mind that removing or rejecting cookies could affect the availability and functionality of some Services.
 
 

Any Other Information You Choose To Provide To Us.

You may provide other information directly to us in other ways and for other purposes besides the Services. For example, we may collect information when you fill out a survey, participate in a sweepstakes or promotion, request customer support, apply for a job with us, communicate with us via third-party social media sites, or otherwise communicate with us.
 
 

HOW WE USE YOUR INFORMATION

We use your information to:

Provide our Services. Our Services allow you to communicate and collaborate with others, and we use your personal information in providing those services. We also use information you provide or we collect from you to personalize the Services to you. We also may use location information to personalize our Services.

Enhancing our Services. We use information you provide or we collect to understand how people use our Services, and to develop, and test new services and features. We also may use information to conduct troubleshooting activities, and to evaluate and improve our Services.

Secure our Services and Enhance Safety. We use and monitor personal information to verify accounts and account activity, detect and prevent account takeover and malicious activity, detect and prevent spam, maintain the integrity of our Services, promote safety and security, combat illegal or harmful conduct, and comply with legal requirements, including valid requests from regulatory authorities or law enforcement.

Communicate with you. We use your information to communicate with you within our Services, and through other means such as by email, text, call, or mail. We may respond to your inquiries and let you know about our Services or products or services from others we believe may be of interest to you.

Analyze trends. We aggregate and parse information to analyze usage of our Services, including to determine trends.   

HOW WE SHARE INFORMATION

We may share the information we have about you in the following ways:

In Providing the Service. Our Services communicate information to others, and all information you post to our Services is made available to others, as directed by you. For messages, information is shared with the party messaged. For groups, the information is shared with the group. For public posts, any information included is public and can be seen by anyone. Information available includes both the information posted as well as your username and other information about the post, such as the time it was posted and your location when it was posted.

Public content may be accessed, downloaded, or shared through or by APIs, search engines, apps, websites, and by other third party services that integrate with our Services.


With our Vendors and Other Third Parties. We may share information with vendors and other service providers who need access to such information to help us provide, protect, or maintain the Services. We may share information with law enforcement, government agencies, or in response to legal requests if we have a good faith belief that disclosing the information is necessary to comply with law, regulation, legal process, or governmental request. These requests may include requests from agencies outside your home jurisdiction where we have an obligation to comply.

We may also disclose information in connection with, or during negotiations of, a merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

With Third Party Social Media. Where our Services offer features to share information on other social media platforms, your use of such features posts information to the selected platforms, and those posts are subject to the policies, including privacy policies, of those platforms.   

HOW LONG WE KEEP YOUR INFORMATION

How long we keep your information depends on the type of information, the purpose for which it is used, how sensitive it is, and other similar factors. We keep information like your name, phone number, email address and the content you post until you ask us to delete it. Note that information that you have made public with our Services made be retained by others who had access to that information through our Services even if we delete the information. We will also retain information for the length of time reasonably needed to provide you with our Services and to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. In particular, we will retain information for as long as necessary to investigate and resolve disputes and/or enforce our rights and agreements, including if your account is disabled for violation of our policies. We may also retain aggregated, anonymized, and de-identified information indefinitely.

In instances where we delete information at your request, copies of that information may still exist in our backup and disaster recovery systems for the period such information is retained for disaster recovery purposes. 

SECURING YOUR INFORMATION 

The security of your personal information is of utmost importance, and we take a number of steps to safeguard it. We have implemented technical and organizational security measures that are designed to help protect your information from unauthorized access, disclosure, use, and modification. We have also deployed monitoring to detect unauthorized access or use of information. We also regularly review security procedures to evaluate new potential threats and appropriate new technologies and methods. However we cannot warrant or guarantee that the information you transmit will not be accessed, disclosed, altered, destroyed or used in an unauthorized manner.  

YOUR CHOICES

We want you to be in control of your information. In most cases, these controls are included directly in the Services themselves. For example every message and post has the option to delete, and files uploaded to our Service can be redownloaded or deleted at any time.
However, if there are additional choices you wish to exercise, we are happy to help. You may exercise the following choices by sending an email to [email protected] Of course, each option may be subject to applicable legal limitations. Additionally, in some cases we may ask you to verify your identity/request or provide additional information fulfilling your request. We may also reject your request for several reasons, such as if we are unable to verify your identity or relationship to the information, if the request risks the privacy of other persons, or is unlawful.

Data Access. You can request a copy of the information we have about you.

Data Correction. You can request to correct or modify the information we have about you.

Object to Processing. You can object to our processing of the information we have about you.

Deletion. You can directly delete most information we have about you through your account. You can also request to delete information we have about you. Please note that we may not be able to identify all information related to you that we may have if that information has not been linked to your identity. For example, some information collected by cookies may not be associated with an account, and can only be deleted by deleting the cookie on your browser. For more information about cookies, and how to delete them, please see below.

Marketing and Communication Preferences. Control of our communication with you depend on the mechanism of communication.
Email. If you wish to unsubscribe to promotion email communications we send to you, simply select “unsubscribe” in the emails.
Text/SMS. If you wish to unsubscribe to any text messages we send to you, text “STOP” in reply to any text message you receive from us.
Calls and postal mail. If you wish to unsubscribe or change/update any other communication preferences with us including calls or mail, contact us by email at [email protected]

Cookies and other Tracking Technologies.
Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. We may use different types of cookies on our Services, including performance cookies, functional cookies and targeting cookies. You may opt out of cookies by following the instructions from your browser settings.

Please note that your opt-out only applies to the browser you use to submit your opt-out, so if you use multiple browsers or devices, you must opt-out on each browser, on each device. Your opt-out is enabled using cookies so once you opt-out, if you delete your browser’s saved cookies on a device, you will need to opt-out again on that browser on that device.

Opting out of cookies and other tracking technologies may not preclude advertising networks from which you have not opted out from displaying customized advertising, and opting out will not prevent any advertising network from displaying advertising, only that the advertising will not be customized to you.   

Do Not Track. Some web browsers may transmit “do not track” signals (go here to learn more). Web browsers may incorporate or activate these features differently, making it unclear if users have consciously activated them. As a result, we do not take steps to respond to such signals.

CHILDREN’S INFORMATION

We do not knowingly collect or solicit personally identifiable information from children under 16.

If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under the required minimum age, we will delete that information as quickly as possible. If you believe that a child under the required minimum age may have provided us personal information, please contact us using our contact form.  

PRIVACY RIGHTS FOR SPECIFIC JURISDICTIONS 

We recognize that privacy is a universal right and attempt to apply the same protections and rights to everyone, certain jurisdictions require specific forms of notification in a privacy policy. The disclosures below each apply to users who reside in each identified state or country. If you are a resident of California, Nevada, the United Kingdom, Switzerland, or the one of the countries of the European Economic Area (EEA), please review the applicable sections below to learn more about your privacy rights and how to exercise them.


CALIFORNIA

If you are a California resident, this section applies to you. This section describes how we collect, use, and share your personal information in our capacity as a “business” under the California Consumer Privacy Act of 2018 (“CCPA”), and the rights that you have with respect to your personal information. For purposes of this section, “personal information” has the meaning given in the CCPA, but does not include information excluded from the CCPA’s scope.

Personal information we collect, use, and disclose.

The chart below summarizes the personal information we collect by reference to the categories of personal information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in posts, may contain other categories of personal information not described below.   

Statutory category of personal information (PI)
(Cal. Civ. Code § 1798.140)
PI we collect in this category (See Personal information we collect above for description) Source of PI Business/
commercial purpose for collection
Categories of third parties to whom we “disclose” PI for a business purpose
Identifiers (other than online identifiers) ● Contact details
● Posts
● You ● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Public
● Verification partners
● Legal and safety-related third parties ● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
California Customer Records (as defined in California Civil Code section 1798.80) ● Contact details
● Posts
● You ● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Public
● Verification partners
● Legal and safety-related third parties ● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Commercial Information ● Contact details
● Posts
● Survey data
● Contests, sweepstakes, and prize drawings data
● Messages and email data
● Online activity data
● You
● Your browser and device
● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Verification partners
● Legal and safety-related third parties ● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Financial Information ● None ● N/A ● N/A ● N/A
Online Identifiers ● Messages and email data
● Contact lists
● Geolocation
● Device data
● Online activity data
● You
● Your browser and device
● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Verification partners
● Legal and safety-related third parties ● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Internet or Network Information ● Messages and email data
● Device data
● Online activity data
● You
● Your browser and device
● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Legal and safety-related third parties
● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Geolocation Data ● Geolocation
● Device data
● You
● Your browser and device
● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Legal and safety-related third parties
● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Inferences May be derived from your:
● Contact details
● Network details
● Posts, interests, location, and recommendations
● Survey data
● Contests, sweepstakes, and prize drawings data
● Messages and email data
● Geolocation
● Device data
● Online activity data
● Information from third parties and public sources
N/A ● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development
● Legal and safety-related third parties
● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Professional or Employment Information ● Business information ● You ● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development 
● Legal and safety-related third parties
● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors
Sensory Information ● Photos, videos, audio  ● You ● Setting you up on FYI.FYI
● Provide and improve the Services
● Create and maintain a trusted environment ● Research and development  
● Public
● Legal and safety-related third parties
● Third party partners
● FYI.FYI corporate family
● Business transferees
● Professional advisors

Access Categories of Information.
You may request the following information about how we have collected and used your personal information during the past 12 months:

● the categories of personal information we have collected about you;

● the categories of sources from which we collected the personal information;

● the business or commercial purpose for collecting or selling the personal information;

● the categories of third parties with whom we share the personal information;

● the specific information related to you that we collected or processed;

● the categories of personal information that we disclosed for a business purpose; and

● the categories of third parties to whom the personal information was disclosed for a business purpose.


You may exercise any of these choices by sending an email to [email protected] Please note that most of your personal information can be accessed directly through your user account.

Deletion.

You can directly delete most information we have about you through your account. You can also request to delete information we have about you by sending an email to [email protected]

Sale of Information

We do not sell your information.

Requests by authorized agents.

Your authorized agent may make a request for information, access, and deletion on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. Authorized agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.

Verifying requests for information, access, and deletion.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Shine the Light Law

Under California’s Shine the Light law (California Civil Code Section 1798.83), California users of our Services may ask us to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to FYI.FYI, Inc. 10960 Wilshire Blvd., 5th Floor, Los Angeles, CA 90024. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information. 

NEVADA RESIDENTS 

Subject to certain exceptions, some of our data sharing practices may be considered a “sale” of your personal information under Nevada Revised Statutes 603A. Nevada residents may opt-out of the “sale” of personal information covered under the statute, by exercising your cookie consent options as detailed in the Cookies and Other Technologies section of this privacy policy.  

RESIDENTS OUTSIDE THE UNITED STATES 

FYI.FYI is located in the United States and provides its Services in the United States. Data collected from you will be stored in the United States. The data protection and other laws of the United States might not be as comprehensive as those in your country.

By using our Services, you acknowledge and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

To the extent the laws of another jurisdiction apply to your data or use of our Services, we will comply with such laws.

EU and UK Residents

If you are an EU citizen or UK citizen, you may have additional rights under the EU General Data Protection Regulation or the UK-GDPR (collectively, the “GDPR”) with respect to your Personal Data, as outlined below. For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” means information that can be used to individually identify a person, and “processing” covers actions that can be performed in connection with data such as collection, use, storage and disclosure. We are the controller of your Personal Data processed in connection with the Services.

The legal bases for which we collect and use Personal Data above depends on what the information is and why we collected it. The four bases upon which we rely include:

Contract. This means we need the information to perform our contracted Services with you. When we process data by contractual necessity, the Services that require that data will not work if you fail or refuse to provide such Personal Data.

Legal Obligation. We use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.

Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy.

Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose. If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

In addition to other rights detailed in the policy (such as requesting deletion, correction or updating of your personal information), EU and UK citizens have certain rights regarding your personal information, including:

Right to Object or Restrict Processing. You have the right to object to or restrict our use of your personal information for direct marketing purposes or under certain circumstances when the legal bases for using your information is based upon our legitimate interest. If you wish to object to our use of your information, you can send us a request to [email protected]
Right to Access and Portability. You also have the right to access the Personal Data we have collected about you, and receive information you have provided to us in a portable format. You can send us a request to access your information by sending an email to [email protected]

Right to Erasure. You have the right to have your personal data erased and no longer processed. Upon receiving the request, we will make a reasonable effort to delete your personal information from the Service and from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations. We may also retain depersonalized information after deletion. You can send us a request to delete your account or access your information by sending an email to [email protected]

Withdrawal of Consent. If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. You can exercise your right to withdraw consent by sending an email to [email protected]

File a Complaint. You have the right to complain to the data protection authority located in your Member State.  

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this Privacy Policy, we will post a notice to our Services and will update the notice’s effective date. Your continued use of the Services following notice of the changes constitutes your acceptance of the changes, so we encourage you to review the Privacy Policy regularly. If you do not agree to the updated Privacy Policy, you may delete your account(s).

CONTACT INFORMATION 

If you have any questions or comments about this Privacy Policy, please contact us at [email protected]