Last Updated: December 23, 2019
This Privacy Statement explains how FaceWallet LLC and its subsidiaries and affiliated companies (“Company”) collects, uses, and discloses information about you through its website http://beta.facewallet.io/, mobile application and related products and services (collectively, the “Services”) or when you otherwise interact with us.
We may change this Privacy Statement from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Statement and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
Collection of Information
Information You Provide to Us
When you register for the Services and open an account, we ask you to provide certain information such as your name, email address, phone number, home address and credit card information. We also collect information when you participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, initiate and complete a transaction, communicate with us via third-party social media sites, request customer support or otherwise communicate with us, and any other information you choose to provide to us.
Information We Collect Automatically from our Services
When you access or use our Services, we automatically collect information about you, including:
- Transaction Information: We collect information in connection with each transaction you engage in via the Services, including transaction initiation time, transaction location, amount of transaction, and other transaction details.
- Log Information: We collect log information about your use of the Services, including the type of browser you use, mobile application version, access times, pages viewed and time spent on those pages, your IP address and the web page you visited before navigating to our Services.
- Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, web browser software, unique device identifiers, and mobile network information.
- Location Information: In accordance with your device permissions, we collect information about the precise location of your device in order to provide the Services. For more details, please see “Your Choices” below.
- Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Pixel tags (or web beacons) are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Your Choices” below.
Information We Collect from Other Sources
We may obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers and publicly available sources. Additionally, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media sites.
Use of Information
We use the information we collect to provide, maintain, and improve our services, such as to administer your account, deliver the services you request and customize your experience with us. We may also use the information we collect to:
- Develop new products and services;
- Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions and customer service requests;
- Communicate with you about products, services, offers, and events offered by Company and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Company and others;
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
- Facilitate contests, sweepstakes and promotions, and process and deliver entries and rewards; and
- Carry out any other purpose for which the information was collected.
Sharing of Information
We may share information about you as follows or as otherwise described in this Privacy Statement:
- With vendors, consultants and other service providers, including third-party payment processors, who need access to such information to carry out work on our behalf;
- With third parties for their own services and marketing purposes, unless you opt-out of this type of sharing by emailing us at email@example.com;
- In response to a request for information if we believe disclosure is in accordance with or required by, any applicable law, regulation or legal process;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Company or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among Company and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
- With your consent or at your direction.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Advertising and Analytics Services Provided by Others
Company takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.
We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations.
The Company also makes use of automatically collected information using the device camera and the TrueDepth API provided by Apple. The only use of this information is to track the user’s head and face so that the user can control the Service by moving their head.
Transfer of Information to the U.S. and Other Countries
The company is based in the United States and we process and store information in the U.S. and in other countries. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
Residents of the European Economic Area
If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the Company services you have requested).
We have a legal obligation to, or legitimate interest in, processing your personal data. We process your personal data where necessary for us to comply with legal and regulatory obligations we are under, and also where it is necessary for legitimate interests, we have in conducting our business. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
You have consented to the processing of your personal data for one or more specific purposes.
Data Subject Requests
If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.
Questions or Complaints
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For the contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
You may update, correct or delete information about you at any time by logging into your online account or emailing us at firstname.lastname@example.org. If you wish to delete or deactivate your account, please email us at email@example.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
When you first launch any of our mobile applications that collect location information, you will be asked to consent to the application’s collection of this information. We currently require this location information to use our Services, so if you do not consent to this collection, you cannot use our Services. If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our mobile applications, or certain features thereof, will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove all of our mobile applications from your device.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
You may opt-out of receiving promotional communications from Company by following the instructions in those messages or by emailing us at firstname.lastname@example.org If you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
If you have any questions about this Privacy Statement, please contact us at email@example.com