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Privacy Policy

Last modified date: June 28, 2024


Please read this Privacy Notice carefully, as your access to and use faproulette.co (“Website”) signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your Personal Information.

For greater certainty, the term “Personal Information” or “Personal Data” means any information or data regarding a person or a user which can lead to identify such person or user, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person or user.

If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.

1. Scope

For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on Personal Information, personal data or on sets of personal data or information (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Information on disclosure of Personal Information or of sets of Personal Information is found in the “Disclosure of Your Personal Information” section below.

This Privacy Notice applies to information we process:

  • - on the Website;

  • - from your communications with the Website, via email, online support chats, phoneline support or otherwise;

2. The Data We Process About You

We may process different kinds of Personal Information about you, depending on whether you chose to create an account and subscribe with us or not.

Persons who visit the Website without logging in or registering (“Unregistered Users”):

  • - Contact Data: We will only process your email address or any other information which you voluntarily provide to us at your direction for a specific function, namely, to participate in a contest or survey.

  • - Online Forms and Communication Data: We process Contact Data and other information that you submit through online forms provided on the Website or information send to us via email, online support chats or such as information provided in the context of support requests or any other inquiries, the content reporting and moderation of content, and our internal complaint handling system.

For persons who choose to create an account and subscribe to the Website, (collectively, the “Registered Users”), we process the same categories of information just described herein above for Unregistered Users, and additionally the following information:

  • - Contact Data: We process names, usernames, and email address.

  • - Website activity data: We process information about how you use the Website, products and services and interact with content, and advertisements if case may be, including the pages you visit on the Website. We process internet protocol (IP) address information and we set cookies as explained below in the section on Cookies and Automatic Data Processing Technologies.

  • - User Submitted Personal Information: We process information you submit to personalize your account or for a specific function, for example date of birth, age, gender, your interests, preferences, feedback, survey responses, your preferences in receiving marketing from us and our third parties, and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function.

  • - User Contributions including Audio/Video Information: We may provide areas on our Website where you can post information about yourself and others, communicate with others, upload content (e.g., pictures, video files, etc.), and post comments or reviews of content found on the Website, whenever applicable (collectively, “User Contributions”).

Please use caution in providing User Contributions. By providing User Contributions you are making that content and information publicly available. User Contributions can be read, collected, used, and disclosed by others, and we cannot control who accesses your User Contributions or what other users may do with the information you voluntarily post or submit. User Contributions are governed by the respective Terms and Conditions of the Website.

We may use your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.

We prohibit minors from using the Website. Our Website are not forbidden of access to persons under the age of eighteen (18) years old or the applicable age of majority in the jurisdiction from which the Website is accessed. As indicated throughout this Privacy Notice, some users may be asked to provide some information to us and our service providers for us to verify that you are over the age of majority required to have access to the Website. We do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, please contact us immediately via our contact form to have that minor’s personal information deleted.

3. The Sources from Which We Process Personal Information

We process Personal Information in the following ways:

  • - Directly from you: We process the categories of information listed above directly from you.

  • - Automated technologies or interactions: As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and other automatic techniques to process website activity data when you visit the Website.

  • - Third-Party Single Sign-on: We may obtain information if you choose to create or sign-in your account through a third-party platform, if available, we will have access to certain information from that platform such as your name, email address or such other information you may have submitted and allowed this third party to share.

4. Purposes for Which We Process Your Personal Information

We process Personal Information for the purposes described below.

  • - Provision of services: We process website activity data, and, additionally for Registered Users, and User Contributions to present our Website to you, Contact Data, including any interactive features on our Website, to provide you with information, subscriptions information that you may request from us, and to verify your eligibility and deliver prizes in connection with contests and sweepstakes.

  • - Customization of content and marketing (Unregistered Users and Registered Users): We process Contact Data, and website activity data; and for Registered Users, user submitted personal information and User Contributions, to analyze your use of, or interest in the content, products, or services, to display content and advertising tailored to your interests on our Website.

  • - Communications and handling of requests: We process Online Forms and Communications Data and other information as necessary to respond to and resolve any of your requests, including where this is required to ensure compliance with our legal obligations.

  • - Analytics: We process website activity data to determine whether users of our Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.

  • - Functionality and security: We may process any of the categories of data we process to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.

  • - Platform Safety: To promote safety and security on the Website. We use the information we collect to help protect users from harm and provide safe, secure product.

  • - Compliance: We may process any of the categories of data we process to enforce, this Privacy Notice, our terms and conditions, and to comply with any legal obligations, namely but not limited to responding to your data subject requests, to verify the age of users having access to the Website, to respond to content reports, and to comply with applicable content moderation and complaint handling obligations.

  • - Hash Values: We may create hash values from any of the categories of data we process, such as infringing or illegal content to detect, prevent, and combat illegal activities including fraud, sexual assault, or exploitation. We reserve the right to share any hashes with law enforcement agencies.

  • - Information you provide: We will process Contact Data and user submitted personal information in any other way we may describe when you provide the information (e.g., for a contest); or for any other purpose with your consent provided separately from this Privacy Notice.

5. Our Legal Bases under Canadian and European Union (EU) Privacy Law

To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your Personal Information only where:

  • - You provide your consent to do so for a specific purpose for example, when you allow us to show you personalized ads or to send you e-mail marketing.

  • - It is necessary to perform our contractual obligations as per our terms and conditions on the Website, for example, to create your account.

  • - It is necessary to comply with legal obligations, for example, we may be required to collect, use, or disclose your information in connection with civil, criminal, corporate, taxation, regulatory matters, or litigation.

  • - It satisfies a legitimate interest which is not overridden by your data protection interests, for example, to keep the Website safe and secure from fraud and illegal activities.

  • - It is used to protect your or others’ vital interests: for example, in case of emergency or to prevent a crime or fraud.

  • - It is used for tasks carried out in the public interest: for example, to combat unlawful behaviour where it is in the public interest to do so and where the public interest is laid down by applicable law.

Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.

6. Disclosure of Your Personal Information

We disclose personal information:

  • - To the public: When you submit User Contributions, you are using our Website and services to make that information public.

  • - Within our corporate group: We may disclose any of the categories of unidentifiable Personal Information to members of our corporate group (including affiliates and related entities) to the extent this is necessary for our purposes listed in the sections above.

  • - Service providers: We disclose the categories of Personal Information we process to our authorized service providers that perform certain services on our behalf. These services may include identity verification, age verification, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, or hosting our Website or supporting our Website’ functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to process such information for any other purposes. Where required under applicable laws, we entered into data processing agreements with such service providers to ensure that personal information is only processed securely within our instructions.

  • - Legal successors: We may disclose all categories of Personal Information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

  • - To comply with the law or protect our rights or the rights of third parties: We access, preserve and share all of the categories of Personal Information with regulators, law enforcement, out-of-court dispute settlement bodies or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Website or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

For more information on recipients of personal information, please see the section “Contact Information” below on how to contact us.

7. Cookies and Automatic Data Collection Technogies

As you navigate through and interact with our Website, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.

We currently use the following types of cookies, which are set by the Website’ domains:

  • - Strictly necessary cookies: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.

  • - Functionality cookies: These cookies help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.

  • - Session or persistent cookies: Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies.

8. Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect Personal Information about you when you click to view, access, or use any of the Website, third-party feature on the Website or directed to such third-party website. Unless expressly stated otherwise, the Website does not provide any Personal Information directly to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access the Website. They may use such information to provide you with interest-based advertising or other targeted content.

You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.

9. Your Choices About How We Collect, Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us.

  • - You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of our Website because such information may be required for you to register and subscribe as a member; subscribe and create an account, purchase or use our products or services; participate in a contest, promotion, survey, or sweepstakes; communicate with our support teams; or initiate other transactions or activities on our Website.

  • - You can opt out of receiving marketing emails from us using the opt-out link provided in our emails or by changing your preferences in your account settings if you are a Registered User, we may also continue to send you other types of transactional and relationship e-mail communications, such as important emails about your account or orders, administrative notices, and surveys.

  • - You may use your account settings to delete your User Contributions and audio/video library information.

  • - You may also delete and deactivate your account with us at any time unless we are required not to do so by law or by a court order. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

  • - Where we provide personalised services, we may analyse the information you provide us as well as your activity on the Website so that we can offer a more relevant, tailored service. For instance, we could use your favourites list to provide you with personalised content and recommendations. If you do not want to receive these services, you can switch off the recommendations toggle on the “recommended” page or via the bar at the left of our page.

10. California Rights and Choices

As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, Consumers have the right to:

  • - Opt-out of the sale of their personal information, should we sell their personal information;

  • - Be informed of certain information concerning our collection and use of their personal information;

  • - Request that we delete certain personal information we collected from them;

  • - Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;

  • - Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

The Website does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable consideration. We may however disclose certain personal information with third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf, and namely to make the Website function properly, as further described in the section above titled Disclosure of Your Personal Information.

We respect California residents’ right to exclude personal information from such sharing arrangements and grant them the option to opt-out of any future sale of their personal information. If you are a Registered User and the CCPA is applicable to you and you would like to exercise your rights, please contact us via our contact form with the subject line “CCPA Request”.

In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

11. Resident’s Rights – Jurisdictions in the United States, Where Applicable

We do not sell, trade, or exchange the Registered Users’ personal information with anyone for money.

12. Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by contacting us via our contact form.

13. Transfers of Your Personal Information to Other Countries

Where the laws of your country allow you to do so, by using the Website you consent to the transfer of information that we process about you, including, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer Personal Information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws.

Where available, we rely on decisions of the European Commission, known as “adequacy decisions”, recognizing that certain countries offer a level of protection of Personal Information that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.

For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.

14. Retention of Personal Information

We will only retain your Personal Information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider several factors, including what Personal Information we are processing, the risk of harm from any unauthorized disclosure, why we are processing your Personal Information and whether we can achieve this outcome by another means without having to process it.

Where we no longer need to process your Personal Information for the purposes set out in this Privacy Notice, we will delete your Personal Information from our systems.

For more information on data retention periods, please see the section “Contact Information” below on how to contact us.

Where permissible, we will also delete your Personal Information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.

15. Third-Party Links and Sites

If you click on a link to a third-party website, you will be taken to Website we do not control. This Privacy Notice does not apply to the privacy practices of these Website. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.

16. Changes to Our Privacy Notice

We may modify or revise our Privacy Notice from time to time, We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes, the date of change will be reflected in the “last modified date” mentioned in the header of this Privacy Notice.

17. Contact Information

If you have any questions about this Privacy Notice or our information-handling practices, please contact us via our contact form.

18. Your Rights Related to Your Personal Information

Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your Personal Information:

  • - Right of access: you have the right to receive information on the Personal Information we hold about you and how such Personal Information is used, as well as a copy of your Personal Information;

  • - Right to rectification: you have the right to rectify inaccurate Personal Information concerning you;

  • - Right to be forgotten: you have the right to delete/erase your Personal Information;

  • - Right to data portability: you have the right to receive the Personal Information provided by you in a structured, commonly used, and machine-readable format and to transmit this Personal Information to another data controller;

  • - Right to object: you have the right to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests;

  • - Right to restriction of processing: you have the right in some cases, to restrict our use of your Personal Information; and

  • - Right to file a complaint: If you are in the EEA or the UK, you also have a right to file a complaint with your local data protection authority.

If we ask for your consent to process your Personal Information, you have the right to withdraw your consent at any time with effect for the future. Note that, in that case, you may no longer able to use several functionalities on the Website or access the Website in some cases.

You can exercise your rights of access or deletion of your data by contacting us via our contact form. Please note that we have one month to respond to your request.

Prior to processing an access or deletion request of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.

Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be able to respond to your request. Additionally, in some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.

Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address). If you delete your account, your Personal Information and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible by you. If, after deleting your account, you wish to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

19. Manage Your Personal Information

Registered Users may request a copy of their Personal Information via our contact form or immediately initiate the deletion of their Personal Information by deleting their account in their Account Settings page.

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