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Privacy Notice

This Privacy Notice outlines how information about you, which directly identifies you or could potentially identify you (“personal information”), is collected, used, and shared by FeatureFold (“FeatureFold,” “we,” “our,” or “us”). This applies to our Featurefold platform (the “Platform”), our website www.featurefold.com (the “Site”), and other online tools and services linked to this Privacy Notice (collectively, the “Service”).

GLOBAL APPLICABILITY AND REGION-SPECIFIC DISCLOSURES

This Privacy Notice applies to visitors of our Site and users of our Services. In certain jurisdictions, we may provide additional disclosures to comply with regional laws regarding the handling of personal information. Please refer to the relevant sections below for information that may apply to you:

1. INFORMATION WE COLLECT AND HOW WE USE IT

We gather personal information about you as part of your interaction with our Service. This includes information you provide directly when using the Service, data obtained from third-party sources, and information automatically collected through tools like cookies and similar technologies.

Information You Provide

We collect personal information directly from you in connection with your use of our Service. The types of information we collect include:

You may choose whether or not to provide certain personal information. However, some information (e.g., your name, address, or payment details) may be required to deliver specific services. If incomplete or inaccurate information is provided, we may be unable to fulfill your request or provide the relevant service.

Automatic Data Collection

Like many digital platforms, we, along with our third-party providers and partners, automatically gather certain personal information when you visit or interact with our website and other online services. This includes:

For details about how we and our partners use cookies and similar technologies to collect information automatically, and the options available to you for managing these practices, please refer to the How We Use Cookies and Other Tracking Technologies section below.

Information from Third-Party Sources

We may receive personal information about you from our business partners, service providers, and other external sources, which we may combine with data collected directly from you. These third parties may include website and service operators, payment processors, and marketing affiliates. The information we receive can include contact details, demographic data, and insights about your communications and related activities. We use this information to manage and enhance our services, facilitate your subscriptions, and support marketing initiatives.

Other Uses of Personal Information

In addition to the uses detailed above, we may collect and utilize personal information for the following purposes:

2. HOW WE SHARE PERSONAL INFORMATION

We may share, disclose, or grant access to your personal information with third parties in the following ways:

3. CONTROL OVER YOUR INFORMATION

4. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES TO COLLECT INFORMATION

We, along with our third-party partners, automatically collect certain types of usage information when you visit our Site, interact with our emails, or engage with our services. This data is typically collected using various tracking technologies, including cookies, web beacons, embedded scripts, location-based technologies, file information, and similar tools (collectively, “tracking technologies”).

Through these tracking technologies, we and our partners gather usage and device information, including:

How We Use Tracking Technologies

The data collected through tracking technologies is used to:
(a) Remember your preferences so you don’t need to re-enter information during your visit or subsequent visits;
(b) Deliver personalized content and targeted advertising;
(c) Identify you across multiple devices for consistent service;
(d) Provide, monitor, and improve the effectiveness of our services;
(e) Measure aggregate metrics such as visitor numbers, traffic, and demographic trends;
(f) Diagnose and address technical issues; and
(g) Plan and enhance the functionality of our services.

Managing Cookies and Tracking Technologies

If you prefer not to accept cookies, most browsers allow you to:
(i) Adjust settings to notify you when a cookie is received, giving you the option to accept or decline;
(ii) Disable existing cookies; or
(iii) Configure the browser to reject cookies automatically.

Please note that disabling cookies may impact your experience, as some features and services may not function properly. Depending on your device and operating system, you may also be able to manage cookies and tracking technologies by modifying your browser or device settings. While these tools may not block all cookies, you can:

5. LINKS TO THIRD-PARTY WEBSITES AND SERVICES

For your convenience, our Service may include links to third-party websites or services that are not owned, operated, or controlled by us. We are not responsible for the privacy practices, content, or operations of these third-party websites or services. Any information you provide or activities you engage in while using those websites or services are governed by their respective policies, not ours.

Your use of any third-party website or service is at your own risk, and we strongly encourage you to review their privacy policies and terms of service before sharing any personal information.

6. CHILDREN’S PRIVACY

Our Service is not designed or intended for individuals under the age of 18. We do not knowingly collect or solicit personal information from anyone under 18, nor do we permit individuals under 18 to use our Service. By accessing or using our Service, you affirm that you are at least 18 years old.

If we discover that we have inadvertently collected personal information from someone under the age of 18, we will take prompt action to delete such information. If you believe that we may have received personal information from an individual under 18, please contact us so we can address the issue.

7. CHANGES TO PRIVACY NOTICE

We may update this Privacy Notice from time to time at our sole discretion. If we make material changes to how we handle your personal information, we will notify you through appropriate channels, such as sending an email to the primary address associated with your account, displaying a prominent notice on our Site, or using other suitable methods.

We encourage you to review this Privacy Notice periodically to stay informed about how we protect your information. Unless stated otherwise, all updates will take effect on the date they are published.

 9. CONTACT US

For additional inquiries about this Privacy Notice, please send us an email at (email ) or contact us at: (Address)

ADDITIONAL NOTICE FOR CALIFORNIA RESIDENTS

This Additional Notice for California Residents (“CA Disclosures”) supplements the information in our Privacy Notice and applies specifically to individual residents of California (“consumers” or “you”).

These CA Disclosures provide additional details about how we collect, use, disclose, and otherwise process the personal information of California residents, both online and offline, as required under the California Consumer Privacy Act of 2018 (“CCPA”). Unless otherwise stated, terms used in these CA Disclosures have the same meanings as defined in our Privacy Notice or as specified under the CCPA.

For the purposes of these CA Disclosures, “personal information” is defined by the CCPA and excludes information that is publicly available, deidentified, aggregated, or otherwise outside the scope of the CCPA. This section does not apply to information related to our employees, contractors, or other personnel.

1. COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about you for various purposes, as outlined in the Information We Collect and Our Use section of our Privacy Notice.

In the past 12 months, we have collected the following categories of personal information:

We collect this information directly from you, publicly available sources, and through service providers and other third parties, such as single sign-on partners, advertisers, creators, and information providers.

For more details about the personal information we collect and the methods of collection, please refer to the Information We Collect and Our Use section of our Privacy Notice.

2. RECIPIENTS OF PERSONAL INFORMATION

We share personal information with third parties for business purposes. The categories of third parties with whom we may share your personal information include:

  1. Affiliated Brands and Companies: Other brands and affiliates within our corporate family.

  2. Service Providers and Advisors: Third-party contractors and advisors who perform services on our behalf, such as payment processing, hosting, and marketing.

  3. Analytics Providers: Partners that help us understand and improve the usage and performance of our services.

  4. Government Agencies or Regulators: Entities to which we may disclose information as required or permitted by law.

For more information about how we share personal information with third parties, please refer to the How We Share Personal Information section of the Privacy Notice.

3. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have the following rights regarding your personal information, subject to certain legal limitations:

Additionally, you have the right to be free from discrimination for exercising any of these rights. However, please note that if exercising your rights affects our ability to process your personal information (e.g., a deletion request), we may no longer be able to provide certain products or services to you or interact with you in the same way.

Submitting Requests

To Exercise Your Right to Know or Right to Deletion

If you wish to exercise your right to know or right to deletion, you can submit a request by:

Before we process your request, we will need to verify your identity and confirm that you are a California resident. To verify your identity, we may require you to either successfully authenticate your account or provide sufficient information that matches the details we have in our systems. This verification process may involve requesting additional personal information from you, such as your email address, physical address, order number, or the date of your last interaction with customer service.

In some instances, we may decline a request to exercise the right to know or right to deletion, particularly if we are unable to verify your identity or if the request conflicts with legal or business requirements.

To Exercise Your Right to Opt-Out of Personal Information Sales

Unless you choose to exercise your Right to Opt-Out of Personal Information Sales, we may share personal information with third parties in exchange for monetary or other valuable consideration. These third parties may use your information for their own purposes, as outlined in their respective privacy policies, which could include reselling this information to additional parties. Such third parties may include:

Exercising Your Right to Opt-Out

You do not need to create an account to exercise your Right to Opt-Out of Personal Information Sales. However, we may request additional personal information, such as your name, email address, or postal address, to verify your identity in our system and ensure compliance with your request. Any personal information provided in connection with an opt-out request will only be used to process and document the request. If you choose not to provide sufficient information, we may only be able to process your request to the extent we can identify you in our systems.

Authorized Agents

California residents may designate an authorized agent to submit requests to know or delete personal information on their behalf. Authorized agents may submit such requests using the methods outlined in this Notice. To verify the agent’s authority to act on the consumer’s behalf, we require the following:

We reserve the right to request additional information to verify the identity of the consumer and/or the agent’s authority to act on their behalf, as necessary to comply with California law.

Financial Incentives

We may offer financial incentives to consumers who permit us to collect and retain certain personal information, such as Identifiers (e.g., name and email address) and Commercial Information (e.g., purchase history). These incentives could result in differences in the prices or services offered to consumers, including benefits such as payments (e.g., free products or services) or reduced prices for goods and services (e.g., discounts and promotions). For instance, we may provide discounts or free products to new customers as part of a financial incentive program.

The material terms of any financial incentive program will be clearly explained in the program’s terms or within the details of the specific incentive offer.

Participation in financial incentive programs is completely optional, and you may withdraw at any time. To opt out and discontinue participation in an incentive program, follow the instructions in the program’s terms and conditions or contact us using the information provided at the end of this Notice.

Each financial incentive or price/service variation related to personal information collection and use is based on a reasonable and good-faith evaluation of the estimated value of such information to our business. This evaluation takes into account the value of the incentive provided and the potential revenue benefits derived from fostering customer loyalty and repeat business.

Privacy Disclosures for the European Economic Area, United Kingdom, Switzerland, Australia, and New Zealand

These Privacy Disclosures explain how we process your personal data when you access our Service from the European Economic Area (“EEA”), United Kingdom (“UK”), Switzerland, Australia, or New Zealand. Please read these Privacy Disclosures together with our Terms of Service ("TOS") before accessing or using the Service. Terms defined in our TOS, such as "Member" and "Creator," retain the same meaning when used in these Privacy Disclosures.

Personal Data

In these Privacy Disclosures, “personal data” refers to information relating to an identified or identifiable natural person.

Controller

[Your Company Name], Inc., a company incorporated under the laws of the United States, is the “controller” responsible for the processing of personal data in connection with our Service. As the controller, we determine how your personal data is used.

Registered Address:
Featurefold
8424 Santa Monica Blvd, Suite A #770
West Hollywood, CA 90069

Contact Information:

For any questions regarding your rights, these Privacy Disclosures, our Privacy Notice, or general privacy matters, please contact our EU or UK representative. Ensure you reference [Your Company Name] in all correspondence.

EU Representative

Instant EU GDPR Representative Ltd.
Re: Featurefold
Office 2, 12A Lower Main Street
Lucan, Co. Dublin
K78 X5P8
Ireland
Email: contact@gdprlocal.com

UK Representative

GDPR Local Ltd.
Re: Featurefold
1st Floor Front Suite, 27-29 North Street
Brighton, England
BN1 1EB

Note for Residents of Australia and New Zealand

For residents of Australia and New Zealand, the following adjustments apply for interpreting these Privacy Disclosures under applicable privacy laws (specifically the Privacy Act 1998 (Cth) for Australia and the Privacy Act 1993 and Privacy Act 2020 for New Zealand):

1. PERSONAL DATA WE COLLECT FROM YOU WHEN YOU USE THE SERVICE, AND HOW WE USE IT

We collect the following categories of personal data that you voluntarily provide when using the Service:

Additional Information

The table in Annex 1 provides more details about the personal data we collect, how we use it, the legal basis for processing, and the recipients of this data.

When collecting personal data, we will indicate if the data is mandatory or optional. Certain information, such as your name, address, payment details, and service preferences, may be essential for accessing specific features. If you choose not to provide required information or provide incomplete/inaccurate data, we may be unable to deliver certain services or respond to your inquiries.

2. INFORMATION WE COLLECT FROM OTHER SOURCES

We may collect personal data about you from the following sources:

For more details about the categories of personal data we collect, how we use it, and the legal basis for processing it, please refer to the table in Annex 1.

 

1. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

We also collect personal data indirectly through your interactions with the Service and your devices. This includes:

(a) Usage Information: Data about the features you use, subscriptions you sign up for, and pages you view on the Service.

(b) Device Information: Information about the device you use to access the Service, such as your IP address, device identifier, device type, model, and manufacturer.

(c) Usage Patterns: Data about how you interact with the Service, including how frequently you use it and your language settings.

We use this information to provide the features and functionality of the Service, monitor and improve performance, and develop new features and services.

If you register for the Platform using a referral link provided by a user participating in our Affiliate Program, we will associate your account with that referral link so the referrer can claim their reward per the Affiliate Program Terms.

For additional details about the categories of personal data we collect automatically, how we use it, the legal basis for processing, and recipients of this data, please refer to the table in Annex 2.

 

Combining and Anonymizing Data

We may link or combine the personal data we collect directly from you with data collected automatically or from other sources.

Additionally, we may anonymize and aggregate personal data (removing any identifiers that link it to you). Anonymized data may be used for purposes such as IT system testing, research, data analysis, and improving the Service.

3. HOW LONG WILL WE STORE YOUR PERSONAL DATA

Except as outlined below, we do not generally retain personal data after you close your account on the Service unless required to comply with applicable laws or if the data is necessary to address a complaint or legal claim.

We will retain the following types of information for up to 7 years after you close your account:

  1. Identity Verification Information: Copies of identity documents provided for age verification and records of identity verification conducted.

  2. Creator Information: Records of payments made to you and any agreements you entered into with other Creators.

  3. Referrals: Details of amounts paid to you for referring another Creator, as outlined in our Referral Program Terms.

  4. Creator-Generated Content: Retained if complaints were made about such content or if there is a potential legal claim related to it.

  5. Live Chat, Live Streams, and Direct Messaging: Copies of any recordings or records of Live Chats, Live Streams, or Direct Messaging, retained in cases of complaints or potential legal claims.

  6. Communications: Records of any complaints made by or against you in communications with us.

Data retained under these conditions will only be used as necessary to fulfill legal, regulatory, or operational requirements and will be securely deleted once it is no longer needed.

5. RECIPIENTS OF PERSONAL DATA

We may share your personal data with the following parties, as required for the purposes outlined in Annex 1 and Annex 2:

  1. Service Providers and Advisors:
    We may share your personal data with third-party vendors and service providers who perform services on our behalf or assist us with operational needs. These services may include professional services (e.g., legal and accounting), mailing, email or chat support, fraud prevention, web hosting, and analytics. Details of the service providers that may receive personal data are provided in Annex 1 and Annex 2. We may also share your data with third-party vendors as outlined in our Monthly Compliance Report Policy.

  2. Affiliates:
    Your personal data may be shared with companies under common ownership or control with [Your Company Name], including subsidiaries and our ultimate holding company. These entities will use your personal data in accordance with this Privacy Notice.

  3. Purchasers and Third Parties in Connection With Business Transactions:
    Personal data may be disclosed to third parties in connection with a business transaction, such as a merger, sale of assets, reorganization, financing, or acquisition of all or part of our business.

  4. Law Enforcement, Regulators, and Other Legal Obligations:
    We may share your personal data with third parties when required to do so by law or when we believe it is necessary to:

    • Comply with legal obligations or respond to lawful requests from law enforcement agencies.

    • Detect and investigate illegal activities, security issues, or breaches of agreements, including our Terms of Service.

    • Protect the rights, property, or personal safety of [Your Company Name], its users, or others.

6. MARKETING AND ADVERTISING

From time to time, we may contact you to provide information about our services, including marketing messages and requests for feedback. Most of our marketing communications are delivered via email. We may also use the personal data we collect about you to tailor marketing messages and ensure they are relevant to your interests.

We will only send you marketing communications if you have given us your explicit consent. You can withdraw your consent at any time by:

Withdrawing your consent will not affect your ability to receive essential service-related communications, such as account notifications or transactional emails.

7. STORING AND TRANSFERRING YOUR PERSONAL DATA

Security

We employ appropriate technical and organizational measures to safeguard your personal data against accidental or unlawful destruction, loss, alteration, or damage. All personal data collected is stored on secure servers provided by our cloud hosting provider. We will never send unsolicited emails or contact you by phone to request sensitive information such as credit or debit card details or national identification numbers.

International Transfers of Your Personal Data

Your personal data may be transferred to and stored in countries outside your jurisdiction, where we and our third-party service providers operate. For users in the EEA, United Kingdom, Switzerland, Australia, or New Zealand, this may include transfers to and processing in the United States or other countries that may not offer the same level of data protection as your home jurisdiction.

When personal data is transferred internationally, we ensure that:

  1. The receiving country is recognized as offering an equivalent level of data protection, or

  2. Appropriate safeguards are in place, such as agreements incorporating standard contractual clauses adopted by the European Commission or approved by the UK Information Commissioner, which require the recipient to handle your personal data with protections equivalent to those in your jurisdiction.

Additionally, if required by applicable law or to protect the rights of [Your Company Name] or our users, we may disclose personal data to law enforcement authorities or regulators in any of our Supported Countries.

If you have questions about the safeguards used for international transfers, please contact us using the details provided at the beginning of these Privacy Disclosures.

8. PROFILING

We may analyze the personal data we collect about you to create a profile of your interests and preferences. This helps us provide you with information and communications that are more relevant to your needs. Where available, we may supplement this analysis with additional information about you obtained from external sources to enhance its accuracy and effectiveness.

Additionally, we may use your personal data to identify and mitigate risks, such as fraud or credit risk, to ensure the security and integrity of our services.

9. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

In accordance with applicable privacy laws, you have the following rights concerning the personal data we hold about you:

  1. Right of Access:
    You have the right to obtain:

    • Confirmation of whether, and where, we are processing your personal data.

    • Information about the categories of personal data we process, the purposes of processing, and how we determine retention periods.

    • Details about the categories of recipients with whom we may share your personal data.

    • A copy of the personal data we hold about you.

  2. Right of Portability:
    In certain circumstances, you have the right to receive a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format, or to request its transfer to another entity.

  3. Right to Rectification:
    You have the right to request the correction of any inaccurate or incomplete personal data we hold about you, without undue delay.

  4. Right to Erasure:
    In certain circumstances, you can request that we erase your personal data without undue delay, such as when continued processing is no longer justified.

  5. Right to Restriction:
    You may request that we limit the purposes for which we process your personal data, for example, when you contest the accuracy of the data or object to its processing.

  6. Right to Withdraw Consent:
    If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

  7. Right to Object:

    • You can object to processing based on our legitimate interests if there are grounds relating to your particular situation.

    • You can object to marketing activities for any reason, and we will honor your request.

If you wish to exercise any of these rights, please visit our Privacy Rights Request Center.

Due to the sensitive nature of data processing, we may require you to verify your identity before acting on your request.

Filing a Complaint

If you believe your rights have been violated, you have the right to lodge a complaint with your local data protection authority:

10. COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR SERVICES

Our Service uses cookies and similar technologies, such as pixels and Local Storage Objects (LSOs) like HTML5 (collectively, "cookies"). Cookies are small pieces of data that are stored on your device to help us distinguish you from other users, personalize your experience, and save your preferences (e.g., phone number or language selection). Cookies also enable us to monitor and analyze how you interact with our Service, allowing us to improve its functionality and provide targeted advertisements in collaboration with our advertising partners.

Types of Cookies We Use

  1. Strictly Necessary Cookies:
    Essential for the operation of our Service. These cookies enable secure logins and help maintain your session while you browse.

  2. Analytical/Performance Cookies:
    Used to measure and analyze visitor behavior, such as tracking how users navigate the Service. This information helps us improve usability and ensure users find what they need.

  3. Functionality Cookies:
    Enable personalization by remembering your preferences when you return to the Service, such as your language or region.

For a detailed list of the cookies used on our Service, please refer to Annex 3.

Your Cookie Preferences

Except for strictly necessary cookies, we will only place cookies on your device with your consent. When you first access our Service, you will be asked to specify which types of cookies you agree to receive. You can update your cookie preferences at any time through the Cookie Preferences page on the Platform.

Most web browsers also allow you to block or delete cookies. However, depending on your device or operating system, you may not be able to block all cookies or similar tracking technologies (e.g., LSOs). Please note that refusing all cookies may limit your ability to access certain features of our Service.

Managing Cookie Settings

To adjust your browser’s cookie settings, you can follow the links below or use your browser’s "Help" menu for more information:

For more general information about cookies and similar technologies, visit www.allaboutcookies.org or the Network Advertising Initiative at www.networkadvertising.org.

Please note that deleting or blocking cookies may not effectively disable all tracking technologies, such as LSOs like HTML5.