PRIVACY POLICY

Revised: May 22, 2018

Your privacy is very important to us. We have prepared this Privacy Policy to explain how we collect, use protect, and share information and data when you use the FatTail Web site (“Site”) or FatTail services (“Services”). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information. By using the Site or Services you consent to this Privacy Policy.

Managing Your Information Preferences

You can always review, correct, update, or delete your Personal Information.  You can opt out of receiving certain e-mails from us by e-mailing us at privacy@fattail.com. E-mail publications from our advertiser and e-mail newsletter publisher clients are sent only to people who have consented to receive that particular e-mail publication or mailing from the client. If at any time you would like to end a subscription  to an e-mail publication or mailing, you can follow either the directions posted at the end of the e-mail publication or mailing, or, where applicable, the directions at the particular client’s Web site.  If you have questions or concerns regarding this Privacy Policy, please e-mail us at privacy@fattail.com.

Information We Collect

Personal Information

In the course of advertisement delivery, FatTail does not collect any Personal Information. We only collect information that personally identifies you, such as your name, address, e-mail, and other personally identifiable information that you choose to provide us with or that one of our clients has provided us with in order to use our Services (“Personal Information”). For e-mail publications from our clients, e-mail addresses may be joined with the information provided at our client’s Web site and may be augmented with other data sources. However, FatTail does not link e-mail addresses to any other Web browsing activities or clickstream data.

Usage Data

We collect anonymous data about users of our Site and Services (“Usage Data”). For example, each time you use the Site we automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site. We also collect data regarding whether you responded to an ad delivered. This anonymous information, however, does not identify any specific person. We use Usage Data to improve the quality of our Site and Services and to measure ad effectiveness on behalf of FatTail’s advertiser and e-mail newsletter publisher clients who specifically request it.

Cookies and Web Beacons

We use cookies (a small text file placed on your computer to identify your computer and browser). We also use Web beacons (an electronic file placed on a Web site that monitors usage). We use cookies and Web beacons to improve the experience of the Site and Services. We do not use cookies or Web beacons to collect Personal Information. Most Web browsers are initially set up to accept cookies. You can reset your Web browser to refuse all cookies or to indicate when a cookie is  being sent. However, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers may use their own cookies and Web beacons in connection with the services they perform on our behalf.

How We Use Information and When We May Share Information

General

We use Personal Information for internal purposes only, such as providing you with the Site and Services, to improve the Site and Services, to notify you of new products or Services, and to otherwise communicate with you about FatTail, the Site, and the Services. We will not disclose Personal Information to third parties without your consent, except as explained in this Privacy Policy.  We may disclose to third parties, certain Usage Data regarding the Site and Services. However, in such cases, your Usage Data is aggregated with Usage Data of others and does not identify you individually.

Service Providers

From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect Personal Information from unauthorized access, use or disclosure. Service Providers are prohibited from using Personal Information other than as specified by FatTail.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with FatTail. If FatTail is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, the new entity plans to handle your information in a way that differs materially from this Privacy Policy.

Compliance with Laws and Law Enforcement

FatTail cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property or rights of FatTail or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

Security

FatTail recognizes the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

Links To Other Web Sites

Our Site and Services may contain links to other Web sites, or allow others to send you such links. A link to a third party’s Web site does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party Web sites. You access such third-party Web sites or content at your own risk. You should always read the privacy policy of a third-party Web site before providing any information to the Web site.

Children’s Privacy

We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.

Special Note for EU Users - Your Rights and Choices

The data controller for the Site and Services is:

FatTail, Inc.

23586 Calabasas Rd.

Calabasas, CA 91302

We use the information we collect about you to pursue the following purposes, which are necessary for the performance of the contract between us to provide you with the products or services you requested or which we consider in our legitimate interests:

  • To enable you to register to the Site and Services;

  • To send you transaction-related emails or push notifications;

  • To offer you the features for which you provide information;

  • To handle any request you may have to our consumer services such as resolving your problem or question, manage any complaints or deal with any feedback you may provide us;

  • For statistical analysis of aggregated data to help us segment our offering and develop our products and services;

  • To better understand the way in which the Site and Services are working, to offer better experience to you when using the Site and Services, to create statistics in relation to the use of the Site and Services, and our other services and offerings in general; and

  • To help us diagnose technical and service problems and administer the Site and Services.

  • Based on your voluntary consent, we also use:

  • Your browsing data to better understand your profile, interests, preferences to enhance your user experience and facilitate your experience and offer you relevant information and promotional materials and interest-based advertising; and

  • Your Personal Information and we may combine these with third-party data to send you personalized emails and push notifications tailored to you and your interests.

In order to comply with our legal obligations, we may also use some of your Personal Information to detect and prevent illegal uses, abuse, spam, fraud, security incidents and other harmful activity or government or court orders.

You may have certain rights under EU data protection legislation with respect to your Personal Information, such as the right to:

  • Request access to and be provided with information on the processing of your Personal Information;

  • Request corrections of your Personal Information if such Personal Information proves inaccurate or incomplete;

  • Request your Personal Information to be deleted (i) if it is no longer necessary for the purposes described in this Privacy Policy, (ii) should you decide to withdraw your consent where you gave it, (iii) should you object to its processing for direct marketing purposes, (iv) should you identify that it would have been unlawfully processed, (v) should we be under a legal obligation to erase it to comply with EU law or the law of an EU country and always provided we are not under a legal obligation to keep it;

  • Restrict the processing of your Personal Information (i) if you contest its accuracy; (ii) if the processing is unlawful and you oppose the erasure; (iii) if it is no longer needed for the purposes set out in this Privacy Policy but you require it for the establishment, exercise or defense of a legal claim, (iv) if you object to profiling;

  • Object to the processing of your Personal Information for direct marketing purposes or to any processing which we would have based on our legitimate interest (e.g. profiling);

  • Receive Personal Information which you provided to us in a structured, commonly used and machine-readable format and to transmit it to another provider provided it is processed based on your consent or our contract; and

  • Lodge a complaint with your relevant data protection authority.

If you wish to exercise any of your above rights, please reach out to us by any of the ways mentioned in the “Managing Your Information Preferences” section of this Privacy Policy.

Regarding the transfer of Personal Information to countries outside the EU, we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the Commission of the European Union for international transfer of personal information to controllers or processors established in third counties as the case may be, when appropriate.

The principle that we apply is that your Personal Information will be deleted when they are no longer necessary for the purpose for which they were collected.

Privacy Policy Changes

From time to time, we may change this Privacy Policy. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the Revision Date shown in the revised  Privacy Policy. Your continued use of our Site or Services constitutes your consent to the revised Privacy Policy.