Effective Date: 4/14/2024
OVERVIEW AND SCOPE
1.1. Overview
Respect for the privacy of personal and other information is fundamental to us. This privacy policy describes our collection of personal information from users of our Web site ("Website" or "Site"), our Platform, as well as all related applications, widgets, software, tools, and other services provided by us and on which a link to this Policy is displayed (collectively, together with the Website, our "Service"). This Policy also describes our use and disclosure of such information. By using our Service, you consent to the collection and use of personal information in accordance with this policy.
1.2. Scope
This policy covers how we treat Personal Information that we gather when you access or use our Services. This policy does not cover the practices of companies we do not own or control or people we do not manage.
1.3. EU-US Data Privacy Framework
Feathery Inc is committed to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and to the rights of EU and UK individuals.
Feathery Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Feathery Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Feathery Inc commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, should first contact Feathery Inc at:
support@feathery.io.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Feathery Inc commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
Feathery Inc is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
For sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), Feathery Inc must obtain affirmative express consent (i.e., opt in) from individuals if such information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. If an individual would like to opt out of their personal information being disclosed to a third party or be used for a purpose that is materially different from the purpose(s) for which it was originally collected, the individual can reach out to support@feathery.io after receiving the notice.
Feathery Inc shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless Feathery Inc proves that it is not responsible for the event giving rise to the damage.
Feathery Inc is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to Feathery Inc and following the procedures and subject to conditions set forth in Annex I of DPF Principles.
PERSONAL INFORMATION
The following subsections detail the categories of Personal Information that we collect and have collected over the past twelve (12) months. "Personal Information," as used in this policy, is information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information”, “personal information” or “personal data” under applicable data privacy laws, rules or regulations. For each category of Personal Information, these subsections also set out the source of the Personal Information, our commercial or business purpose for collecting that Personal Information and the categories of third parties with whom we share that Personal Information. More information regarding those sources and categories are set forth below.
Personal Information does not include "aggregate" or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.
2.1 CATEGORIES OF PERSONAL INFORMATION WE COLLECT
Consumer Contact Data
Examples of Personal Information Collected:
Source:
Third Parties with Whom we Share Data for Business Purposes:
Consumer Demographic Data
Examples of Personal Information Collected:
Source:
Other Identifying Information That You Voluntarily Choose to Provide
Examples of Personal Information Collected:
Source:
Third Parties with Whom we Share Data for Business Purposes:
Device/IP Information
Examples of Personal Information Collected:
Source:
Third Parties with Whom we Share Data for Business Purposes:
Web Analytics
Examples of Personal Information Collected:
Source:
Third Parties with Whom we Share Data for Business Purposes:
2.2 Categories of Sources of Personal Information
You
Third Parties
We may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
We may use service providers to obtain information to generate leads and create user profiles
We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
2.3 Commercial or Business Purposes for Collecting Data
Providing, Customizing, and Improving the Services
Marketing the Services
Corresponding with You
Legal Requirements
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice.
2.4 How We Share Your Personal Information
We will not disclose your personal information to third parties without your consent, other than as described in this policy. We disclose your Personal Information to the categories of services providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Information. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
Business Partners. These parties partner with us in offering various services. They include:
Parties You Authorize, Access or Authenticate
Legal Obligations
We may also disclose personal information if we believe that doing so is legally required or necessary in order to:
Business Transfers
In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets. Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Information
We may create aggregated, de-identified or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
3. Tracking Tools, Advertising and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
4. LINKS
For your convenience, the Site may contain links to other Web sites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.
CHILDREN
Our Site and our Service is not intended for children and children under the age of 13; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Service or send us any Personal Information. We do not knowingly collect personal information from children under the age of 13. If we learn we have collected Personal Information from a child under 13 years of age, we will delete the information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Information to us, please contact us at support@feathery.io.
Access
You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Information to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Information shared with each category of third party recipient. If we have sold your Personal Information over the past 12 months, we will identify the categories of Personal Information sold to each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Information that we have collected about you. To do so, please email support@feathery.io with your account information and request.
If you're a California resident, this right is subject to certain exceptions under the CCPA. For example, we may need to retain your Personal Information to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@feathery.io.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) verifies you own the email for the account for whom we have collected Personal Information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Information Sales Opt-Out and Opt-In
We will not sell your Personal Information, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Information of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.
DATA SECURITY AND RETENTION
Feathery protects the Personal Information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use reasonable security measures that are designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information. You transmit information to us at your own risk.
We retain Personal Information about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
UPDATES TO THIS POLICY
We may occasionally update this Policy. When we do, we will also revise the "last updated" date at the beginning of the policy and will alert you to any such changes by placing a notice on our website, by sending you an email and/or by some other means. Your continued use of this Service after such changes will be subject to the then-current policy. Use of information we collect is subject to the Policy in effect at the time such information is collected. We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose personal information.
10.CONTACTING US
If you have any questions, comments, or concerns about this privacy policy or your personal information, please contact us at support@feathery.io. If you have a complaint that we have breached these privacy principles and attempted in good faith to resolve the complaint through our customer service process, but the complaint was not resolved by us within a reasonable amount of time, then you may enforce these privacy principles against us.
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