Privacy Policy

Effective Date: 06/01/2023

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.

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:

• First and last name
• E-mail address
• Mailing address
• Phone number

Source:

• You

Third Parties with Whom we Share Data for Business Purposes:‍

• AWS
• Stytch
• Stripe

Consumer Demographic Data

Examples of Personal Information Collected:

• None

Source: 

• You‍
• Third Parties with Whom we Share Data for Business Purposes: None

Other Identifying Information That You Voluntarily Choose to Provide

Examples of Personal Information Collected:

• Unique identifiers such as passwords
• Personal Information contained in emails or letters you send to us

Source:

• You

Third Parties with Whom we Share Data for Business Purposes:

• Service Providers

Device/IP Information

Examples of Personal Information Collected:

• IP address
• Device ID
• Browser type
• System type

Source:

• You
• Third Parties

Third Parties with Whom we Share Data for Business Purposes:

• Service Providers

Web Analytics

Examples of Personal Information Collected:

• Web page interactions (i.e. the content and pages that you access on the Site, the pages you navigate to on the Site and from which you leave the Site, as well as the time you spend on the Site)
• Referring webpage/source through which you access the Service
• Non-identifiable request IDs
• Statistics associated with the interaction between device or browser and the Service.
• The content and pages that you access on the Service

Source:

• You
• Third Parties

Third Parties with Whom we Share Data for Business Purposes:

• Service Providers
  

2.2 Categories of Sources of Personal Information

You

• When You Provide Information Directly to Us‍
• When you create an account or provide information through the Service.
• When you voluntarily provide information in free-form text boxes through the Service.
• When you send us an email or otherwise contact us.‍
• When Personal Data is Automatically Collected When You Use the Services‍
• Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out section below).
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices. 

Third Parties

• Service Providers‍

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

• Advertising Partners

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

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you with the products, services and information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services
• Improving the Services, including testing, research, internal analytics, and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Fraud protection, security and debugging.

Marketing the Services

• Marketing and selling the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Services.
• Sending email and other communications that display content that we think will interest you and according to your preferences. 

Legal Requirements

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Feathery or another party.
• Enforcing any agreements with you.
• Resolving disputes.
  

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:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors.
• Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment. 
• Please see Stripe’s terms of service and privacy policy for information on its use and storage of your personal data.

Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• Ad networks.
• Data brokers.
• Marketing providers.

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners. These parties partner with us in offering various services. They include:

• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate

• Third parties you access through the Services.
• Social media services.
• Other users.

Legal Obligations

We may also disclose personal information if we believe that doing so is legally required or necessary in order to:

• Fulfill our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities;
• Protect our property or other legal rights (including, but not limited to, enforcement of our agreements);
• Protect the rights or property of you or others; and
• Resolve disputes.

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:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  

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:

• The categories of Personal Information that we have collected about you.
• The categories of sources from which that Personal Information was collected.
• The business or commercial purpose for collecting or selling your Personal Information.
• The categories of third parties with whom we have shared your Personal Information.
• The specific pieces of Personal Information that we have collected about you.
  

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:

• Email us at: support@feathery.io
  

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.