PRIVACY POLICY

Last modified: October 2, 2019

Introduction

At FindShadow, PBC, a Delaware public benefit corporation (“FindShadow” or “we”), we respect your privacy and are committed to protecting it through our compliance with this privacy policy (the “Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you download, install, register with, access or use our services, including our various websites, SMS, APIs, email notifications, applications, buttons, widgets, ads, commerce services and other covered services that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy applies to information we collect:

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, access or use our Services. By downloading, registering with, accessing or using the Services, or by allowing others to access or use the Services through your Account, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Services or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@findshadow.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We may collect several types of information from and about you through the Services, including information: (i) by which you may be personally identified, such as name, postal address, e-mail address, phone number or any other identifier by which you may be contacted online or offline (“personal information”); (ii) that you provide or create, including, videos, audio, or photos of you, or your acquaintances, a lost or found pet, or leads about a lost or found pet; (iii) that you provide that relates to a lost or found pet, such as the name, breed, ID or microchip number, size and description, temperament, and last known location, and whether there is a reward; (iv) that is about your precise or approximate  location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers; (v) that is about your internet connection, the equipment you use to access our Services and usage details; (vi) that you otherwise provide directly, such as communications between you and us; and (vii) that you permit us to extract from your mobile device’s address book, including information about your contacts such as your contacts’ names and numbers.

We collect this information: (i) directly from you or from persons with access to your Account, in each case, when your Account is accessed to login to or use our Services, (ii) directly from you or from persons with access to your Account, in each case when provided to us or created for us, (iii) automatically as you or persons with access to your Account navigate through the site, including usage details, IP addresses, and information collected through cookies, and (iv) from third parties.

Information may also be provided or created for publication or display on public areas of the Services, or transmitted to other users of the Services or third parties by you or persons with access to your Account (collectively, “Story Content”). Story Content is posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your Story Content. Therefore, we cannot and do not guarantee that Story Content will not be viewed by unauthorized persons.

When you download, access, and use our Services, they may use technology to automatically collect: (i) certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services; (ii) information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number; (iii) metadata and other information associated with other files stored on your device, which may include, for example, photographs, audio and video clips, personal contacts, and address book information; and (iv) real-time information about the location of your device.

If you do not want us to collect this information do not download, access or use our Services, and delete our Services from your device.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). The technologies we use for automatic information collection may include small files placed on your device (cookies) and/or small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs).

When you use our Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include analytic companies, your mobile device manufacturer and your mobile service provider.

These third parties may use tracking technologies to collect information about you when you our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. We do not control these third parties' tracking technologies or how they may be used.

How We Use Your Information

We do not share your personal information with third parties other than as disclosed in this Privacy Policy.

We use information that we collect about you or that is provided to or created for us, including any personal information:

In addition, if you have enabled the device location services on your mobile device, you may enable FindShadow to share your location with other users from the time. This makes it easier for you and other users to coordinate (e.g., the posting of street flyers).

Certain third-party companies and individuals provide or facilitate certain aspects of the Services on our behalf. We provide these third-party service providers with access to your information, including your phone number, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your personal information similar to the ones that we provide.

For example, we may periodically send you text messages through a third-party cloud communications service provider. If you respond to these text messages by text message, the service provider may receive your phone number and text message in real time and store certain data, including the content, date and time of your text message.

To facilitate communication between an owner seeking a lost pet (a “Seeker”) and a member of the community who finds a lost pet (a “Hero”) or assists with finding a lost pet (a “Volunteer”), we will set up a temporary phone number through a third-party phone solution.

If a Hero or a Volunteer has information regarding a lost pet, they may call (or text message) this number and the call (or text message) will be connected (or forwarded) to the Seeker’s phone number. To ensure user privacy, our phone solution provider will mask the phone numbers of Heroes, Volunteers and Seekers from each other during any communication over this number. In addition, our phone solution provider will record all calls or text messages (including multimedia) exchanged over this number.

Without prior consent, we will not disclose the contact information of any Hero or Volunteer to any Seeker, nor disclose the contact information of any Seeker to any Hero or Volunteer. Any information you voluntarily disclose to a third party (whether such third-party is a Hero, Volunteer or Seeker), including your phone number or personal information, will become available to that third-party. If you later decide that you no longer want to receive communication from that third party, you will need to contact that third-party directly.

You will be solely responsible for your interactions with all third parties. You understand that we do not conduct criminal or any other background checks or verify the identity of any third-party, nor do we attempt to verify the statements or information received from third parties relating to a lost pet.

This Privacy Policy will be applied to any personal information received from third parties, unless we have disclosed otherwise.

Disclosure of Your Information

We may disclose personal information that we collect or that is provided to or created for us as described in this Privacy Policy:

We may also disclose your personal information:

Accessing and Correcting Your Personal Information

You may send us an email at privacy@findshadow.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you instruct us to delete your user account, copies of your Story Content may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided on our mobile application, including Story content, is governed by our terms of service (found at findshadow.com/terms).

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights 

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Our Services have collected the following categories of personal information from its consumers within the last 12 months:

Category

Collected

A. Identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Yes

C. Protected classification characteristics under California or federal law.

Yes

D. Commercial information.

No

E. Biometric information.

No

F. Internet or other similar network activity.

Yes

G. Geolocation data.

Yes

H. Sensory data.

Yes

I. Professional or employment-related information.

Yes

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

No

K. Inferences drawn from other personal information.

Yes

Personal information does not include:

FindShadow obtains the categories of personal information listed above from the following categories of sources:

We may use or disclose the personal information we collect for one or more of the following purposes:

FindShadow 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.

California – Sharing Personal Information

FindShadow may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

California – Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, FindShadow has disclosed the following categories of personal information for a business purpose or to aid in the reunion of a lost pet:

We disclose your personal information for a business purpose or to aid in the reunion of a lost pet to the following categories of third parties:

California – Sales of Personal Information

In the preceding 12 months, FindShadow had not sold personal information.

California – Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

California – Access to Specific Information and Data Portability Rights

You have the right to request that FindShadow disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see California – Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

California –Deletion Request Rights

You have the right to request that FindShadow delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see California – Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

California – Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see California – Personal Information Sales Opt-Out and Opt-In Rights.

California – Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, to the email address you provide in your request.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California – Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California – Other California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@findshadow.com or write us at: 228 Park Ave S #26500, New York, New York 10003.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes to Our Privacy Policy

The date the Privacy Policy was last revised is identified at the top of the Privacy Policy. You are responsible for periodically visiting this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: 228 Park Ave S #26500, New York, New York 10003, privacy@findshadow.com or (866) 400-4001.