Last Revised: March 31, 2017
2. USER CONSENT
3. COLLECTION OF PERSONAL AND NON-PERSONAL INFORMATION
We collect Personal Information in connection with our Services. “Personal Information” means information that can be used to identify or contact an individual and may include, but is not limited to, your first and last name, by itself or combined with your unique user ID, password, gender, date of birth, address, email address, interests, hobbies, photos, phone numbers, your brand preferences, your Facebook, Twitter or other social media handles, your geographic location if you are accessing the Services from a GPS-enabled mobile device, any other personal profile or account information you choose to submit through our Services, and (if applicable) your company name and business contact information. FreeMo or its third party payment transactions services provider may also collect credit, debit or other billing account information. You may always choose not to provide Personal Information, but this may prevent you from receiving certain Services or rewards credits. For example, in order to set up an End User account, you must provide a valid email address to log in and to receive important account activity information. If you do not complete the account registration process, you will not be able to collect or redeem Reward Credits. If you choose to use our Site’s social networking function to post information to Facebook, Twitter or another social networking site, we may collect your user ID and password information for that social networking site as necessary to make it easier for you to log in to the Services or to interact with your social networks in other ways (for example, to share Ad Content with your friends on those social networks). Specifically, and without limiting the generality of the foregoing, the Services may allow users to access “Facebook Connect” to interact with friends and to share on Facebook while using FreeMo. Should you choose to use the Facebook Connect feature, FreeMo may collect certain information about you from your Facebook account, which will be specified at the time you first agree to sign in using Facebook Connect. You can edit privacy settings for posts that appear on Facebook or disconnect the Facebook Connect service by using the privacy tools provided through Facebook. FreeMo may also collect your telephone number, which we may use to verify users and prevent duplicative accounts. FreeMo may also collect non-Personal Information (aggregate, non-individually identifiable or demographic information). An example of non-Personal Information is system-related information such as IP addresses, click-through and other Application and Site use information (for example, we typically track each time you click on Ad Content from your mobile device lockscreen), browser and browser speed, bandwidth of your Internet connectivity, general location of your server and the pages of our Site or Application that were viewed during a visit. We use this information to manage End User and Advertiser accounts as well as for internal purposes such as to diagnose problems, monitor traffic patterns and otherwise continually improve our Services. Please note that the Services may provide links to third party sites, such as links to the websites of Advertisers and other third-party organizations, businesses, and merchants who have agreed to make Ad Content and offers available to End Users through FreeMo (including, but not limited to Tapsense Inc). We are not responsible for the privacy policies, practices or the content of websites owned by others that you may link to or that may be linked from the Services. Accordingly, we encourage you to review the privacy policies and terms of service of those websites so that you understand how those websites collect, use and share any Personal Information.
4. USE OF PERSONAL AND NON-PERSONAL INFORMATION
5. DISCLOSURE OF PERSONAL AND NON-PERSONAL INFORMATION
If you are an End User, in order to effectively manage the Services, your non-Personal Information (including, without limitation, de-identified, aggregated Personal Information) will be disclosed to Advertisers to facilitate such account-related activities and to manage and improve our Services. We may also disclose your Personal Information to Advertisers where such sharing is required to deliver products or services you have requested (including but not limited to facilitating your receipt or acceptance of offers or fulfillment or redemption of offers). In addition, we may disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our Site, marketing of our products and services, conducting audits, and performing web analytics). We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues. We may also disclose non-Personal Information to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications. We do NOT sell, rent, share or trade your Personal Information to third parties for their own marketing purposes unless you have granted us permission to do so. P We may, however, allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and / or with certain interests). In the event that you interact with a certain Advertisement, the advertiser (or the company with which the advertiser works, for example, its ad agency or an advertising network) may determine certain characteristics about you.
6. ACCESSING AND UPDATING PERSONAL INFORMATION
When you use our Services, we make good faith efforts to provide you with access to your Personal Information and to either correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Please e-mail us at info@getFreeMo.com if you need assistance accessing or changing your Personal Information or if you would like to have your Personal Information deleted. Please be aware that if you delete your Personal Information, you may not be able to continue to use the Services, Application or Site. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.
7. COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES
We do not knowingly collect Personal Information from individuals under 13 years of age. Nor do we authorize users who are less than 13 years old to use the Services (including, without limitation, the Application and Site). If we learn from the individual or from the individual’s parent or legal guardian that we have collected Personal Information about a person under the age of 13, we will make efforts to delete their Personal Information from our systems within a commercially reasonable period of time.
9. SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the security of your Personal Information. We utilize reasonable information security measures to safeguard your Personal Information. For example, industry-standard encryption (Hyper Text Transfer Protocol Secure a/k/a “https”) is used to protect communications between our servers and our users’ web browsers and mobile devices. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security.
10. ANONYMOUS DATA COLLECTION
11. CALIFORNIA PRIVACY RIGHTS
12. PUBLIC MESSAGE BOARDS AND OTHER ONLINE FORUMS
Please note that when you choose to post messages and/or profile content on messages boards and other online forums that we may make available on our Site or Application, such content is viewable by third parties and, in the case of public online forums and any public profiles, is publicly viewable. Accordingly, you should exercise discretion with regard to what Personal Information you post on our Site or Application and you should not post highly confidential or sensitive information. FreeMo is not responsible for how third parties who view your Personal Information may use this information (such as to send you unsolicited messages).
14. NOTICE TO CONSUMERS
Notice to Consumers. Provider will provide notice to its end users that complies with Applicable Law and includes, without limitation, a disclosure that: (i) it is collecting information about their usage of Provider’s websites and/or mobile applications; and (ii) end users may opt-out of the collection of Provider Data by turning off the “Advertising Services” setting on their mobile devices or, for web users, by using the Digital Advertising Alliance (http://www.aboutads.info/choices/), Network Advertising Initiative (http://www.networkadvertising.org/choices/), and/or European Digital Advertising Alliance (http://www.youronlinechoices.eu/) opt-outs. Such notice must be linked to conspicuously from the home page and other relevant pages of Provider’s website and/or within Provider’s mobile application (as applicable), and will contain the word “Privacy.” In addition, as necessary, As necessary, Provider will provide notice to its end users that advertisements that are tailored based on the user’s interests may be delivered to their mobile device.
15. HOW TO CONTACT US
Attn: Privacy Matters
215 3rd Avenue
Kirkland, WA 98033
2017 FreeMo, Inc. All rights reserved