Privacy Policy

FOOTCI PRIVACY POLICY AND COOKIE POLICY

Welcome to Footci’s Privacy and Cookie Policy. This explains how Footci Systems LLC (“Footci” or “we” or “us”) uses, collects, processes, and shares personal data, including information obtained through the website at https://footci.com (“Footci Site”), the Footci mobile application (e.g., Footci iOS, Footci Android) (“Footci App”).

As a global social networking application, the Footci App allows you to share sensitive information about yourself, including your sexual orientation and precise location, with us and other Footci users. This Privacy and Cookie Policy also explains how you can control your personal data. We recommend you read this Privacy and Cookie Policy, and our Terms and Conditions, carefully. 

EEA/UK Data Subjects: If you are accessing the Footci Services from the European Economic Area (“EEA”) and/or the United Kingdom, please note that Footci Systems LLC, a U.S.-based company, is the controller of your Personal Data; additional information for EEA data subjects is available below.

What Personal Data We Collect and Process.

When you use Footci’s Services, we collect personal data about you. “Personal Data” means any information that allows someone to identify you as defined under applicable law. Note that not all of the Footci Services collect all of the data listed below.

Personal Data You Provide

Account Credentials. For authentication purposes, we require you to provide an email address and password, a phone number, or a third-party social log-in (e.g., Facebook or Google) to use the Footci App or other Footci Services. In order to keep the Footci Services safe and authentic, we may ask for, and retain a hashed version, your phone number for account authentication and/or verification purposes. 

Community Profile Information. When you create a Footci account, you choose to provide us Personal Data about yourself for your public Footci profile. For example, in the Footci App, you may voluntarily provide your Personal Data, such as your photo, display name, relationship status, ethnicity, age or date of birth, gender, pronouns, email address, height, weight, body type, position, foot size, social network link, “Looking For,” “About Me,” “Favorites,” “Meet at,” “Accept NSFW Pics,” and any other information that you add to your profile on the Footci App. Remember that if you choose to include information in your Footci community profile, that information will become public to other Footci users. As a result, you should carefully consider what Personal Data to include in your profile. Additionally, you can review and change your Community Profile Information at any time by accessing the “Edit Profile” section of the App.

Feedback/Support. If you provide us feedback or contact us for support, we collect your name and e-mail address and possibly other Personal Data (e.g. IP address), as well as any other content that you send to us in order to reply and address any issue. If you contact us for support, we also collect and retain certain technical diagnostic data, such as your phone model. We may keep records of our communication with you, including any complaints we receive from you about other users (and from other users about you).

Mailing List. When you sign up for the Footci Services, we collect your email address to send you Footci news, Footci Services updates, the latest information on products and services, and third-party offers with your consent.

Surveys. When you participate in a survey, you provide us additional Personal Data through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. Unless noted otherwise, we use Survey Monkey for surveys. You can view Survey Monkey’s privacy policy here.

Partner Promotion. We collect Personal Data if you provide such data in the context of a Partner Promotion (described below).

Personal Data We Receive When You Use Footci Services

Photos and Videos. If you wish to upload a photo or video to your Footci community profile or chat messages, you will be required to permit Footci to access your camera and photo gallery, in which case Footci will have access to the photos and videos stored in your photo gallery.

Location and Distance Information. When you use the Footci App, we collect your precise location (e.g. your latitude and longitude) (“Location”) to determine your distance in feet or meters from other users (“Distance Information”). When determining an iOS users’ Location, the Footci App utilizes the iOS Core Location and Map Kit framework. To determine an Android users’ Location, the Footci App utilizes the Google Geolocation API. Both of these frameworks utilize various technologies to determine Location, including Internet Protocol (IP) address, GPS, and other sensors in your device that provide information on nearby devices, Wi-Fi access points, wireless networks, and cell towers and the Footci App relies solely on these frameworks in determining your Location. We store your last known Location to calculate Distance Information (please see Data Retention section for more information). Should you choose not to allow the Footci App to access your Location, certain features (such as displaying nearby user profiles or features that include Live Location Sharing) of the Footci Services will not function properly. You may also revoke this permission and disable the location services on your device. You can do so on an iPhone by going to settings, privacy, location services, Footci; and on Android, by going to settings, location, Footci, permissions, location.

Messages. When you send a message using the Footci Services (which could include photos, location, audio, or video) to other users of the Footci Services, we may collect Personal Data that includes the content of the message, including photos, location, audio, or video.

User Activity. We collect certain Personal Data that is generated through your use of the Footci Services. This Personal Data includes information about whose user profiles you have viewed, products and services you have purchased through the Footci Services and how you communicate with other users.

Hardware and Software Information. We collect certain hardware and software information about you and your device such as device make, device model, carrier, data connection type, browser type, operating system, IP address, domain name, date/time stamp for your visit, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA which can be reset by going to your device’s setting) an ID that is unique to the device or browser on which you install and/or access the Footci Services (“Device ID”) and may collect sensor information such as barometric pressure, accelerometer measurements, gyroscope measurements, device orientation, magnetic field measurements, direction of travel, motion activity (e.g.,walking) or other similar measurements (all of the foregoing collectively known as “Hardware and Software Information”. In addition, when you use the Footci Services, we may collect information about other applications installed on your device, including the settings and characteristics of those applications. To opt-out of this collection, please send an email to privacy@footci.com.

Cookies, Log Files and Other Tracking Technologies. We use cookies and URL information to gather information regarding the date and time of your visit and your searches. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on the Footci Services and to improve our marketing efforts, including through the use of targeted advertising. Persistent cookies may be removed by following instructions provided by your browser. If you choose to disable cookies, some features of the Footci Services may not work properly. For more Information regarding cookies and other tracking technologies, please see Cookie Information below.

Personal Data We Receive from Third Parties

Purchase Information. When you choose to make a purchase through the Footci Services, you submit Personal Data such as your name, payment card information, billing information, address, telephone number, and email address to one of our third-party payment processors.

Footci does not receive or process payment card information directly; however, our third-party service providers may provide certain information to us (e.g., your name, phone number, partial payment card number, and email address). We use Google Play for purchases on Android devices, Apple for purchases on Apple devices. Please review their privacy policies at https://www.google.com/policies/privacy/, and http://www.apple.com/privacy, respectively, to better understand their practices.

Third-Party Platforms. If you use or connect to the Footci Site or download the Footci Services through a third-party platform, such as Facebook, Google, or WeChat, you allow us to access and/or collect certain information(e.g., date of birth) from your third-party platform profile/account (“Third-Party Data”). We may also access information contained in cookies placed on your device by the third-party platform. Remember, when you elect to create a Footci account via a third-party, you are also giving them Personal Data, so we recommend you read their privacy policies as Footci does not control how they use your information.

Third-Party Tracking. Our advertisers and certain service providers also use their own cookies or other tracking technologies (such as software development kits or “SDKs”) which may collect information about you within the Footci Services. You can find more information about third-party tracking technologies in our Cookie Policy.

Some Personal Data about your use of the Footci Services and certain third-party services may be collected using tracking technologies across time and services, and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Footci Services and certain third-party services.

How And Why We Use Your Personal Data.

In order to provide the Footci Services and facilitate connections with the community, we use your Personal Data for the purposes described below. Please note that even if we are not relying on consent to use your Personal Data, we may ask you for permission to access your device for Personal Data such as photos and location. Under E.U. and U.K. data protection laws, we may only use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases on which we rely. Where the legal basis is consent, you can withdraw your consent at any time (typically by controlling what data you provide in your Footci community profile). Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Privacy Policy how you can withdraw consent or opt-out of certain data uses.

Processing purpose Categories of Personal Data Lawful Basis
Provide you with the services and products associated with a Footci account, including without limitation creating and managing your Footci account and Footci user profile. Personal Data we collect from you, including: Account Credentials; Profile Information; Location and Distance Information; Hardware and Software Information; and Cookies, Log Files and Other Tracking Technologies.Additional Personal Data we receive about you, including: Third-Party Data. Performance of contractManifestly made public by the data subject
Display your profile and your Footci activity to other users and enable you to see nearby user profiles. Personal Data we collect from you, including: Location and Distance Information, Profile Information; User Activity; Cookies, Log Files and Other Tracking Technologies. Performance of contract
Facilitate messages between users of the Footci Services, which may include photos (including explicit photos), location, audio or video. Personal Data we collect from you, including: Hardware: Software Information; Location and Distance Information; Messages; Photos and Videos; User Activity. Performance of contract
Communicate with you through the App to provide updates, service-related notifications, news, and promotions. Personal Data we collect from you, including: Profile Information; Hardware and Software Information; Location and Distance Information; Cookies, Log Files and Other Tracking Technologies; Feedback and Support; Mailing List; Partner Promotions. Additional Personal Data that we receive about you, including: Payment Information. Performance of contract
Respond to user inquiries and complaints and to provide you customer support. Personal Data we collect from you, including: Account Credentials; Hardware and Software Information; Profile Information; Location and Distance Information; Messages; Photos and Videos; User Activity; Cookies, Log Files and Other Tracking Technologies; Feedback and Support; Surveys. Additional Personal Data that we received about you, including: Payment Information. Legitimate interests – it is in our legitimate interests to respond to your inquiries in order to provide you with the assistance you expect when raising a support query.
Develop and improve Footci Services and products. Personal Data we collect from you, including: Account Credentials; Profile Information; Hardware and Software Information; User Activity; Cookies, Log Files and Other Tracking Technologies; Feedback and Support; Surveys.
Additional Personal Data that we receive about you, including: Payment Information; User Activity.
Legitimate interests/Consent – it is in our legitimate interests to understand the ways in which our users engage with the Footci Services and other third-party tools/applications so that we can further protect Footci users, improve the current Footci Services as well as develop new services and products for future use.
Process your purchases and transactions. Personal Data we collect from you, including: Hardware and Software Information; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data that we receive about you, including: Payment Information.
Performance of contract
Conduct Partner promotions. Personal Data we collect from you, including: Profile Information; Authentication Information; Location and Distance Information; Partner Promotions. Legitimate Interests – it is in our legitimate interests to provide you with partner promotions in which you may be interested.
Access and collect your Personal Data from third-party platforms. Personal Data we collect from you, including: Third-Party Platform Data; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data we receive about you, including: Third-Party Platform Data, Hardware and Software Information Payment Information
Performance of contract
Share your Personal Data with our service providers in order to provide you with the Footci Services. Personal Data we collect from you, including: Hardware and Software Information; Profile Information; Location and Distance Information; Messages; Photos and Videos; Cookies, Log Files and Other Tracking Technologies. Performance of contract
Share your Personal Data with analytics partners to improve our services, marketing, user relationships and experiences. Personal Data we collect from you, including: Hardware and Software Information; Profile Information; Location and Distance Information; Cookies, Log Files and Other Tracking Technologies. Legitimate interests/Consent – it is in our legitimate interests to analyze the way in which users are accessing and using the Footci Services so that we can further improve them.
Allow third-party advertisers to use tracking technologies on the Footci Services. Personal Data we collect from you, including: Hardware and Software Information; Cookies, Log Files and Other Tracking Technologies. Legitimate interests/Consent – it is in our legitimate interests to target advertisements so that users see relevant advertisements in furtherance of the Footci Services and the Company’s business operations.
Provide safety and security features (authentication, anti-spam, fraud protection and quality and abuse prevention). Personal Data we collect from you, including: Account Credentials; Hardware and Software Information; Profile Information; Location and Distance Information; Messages; Photos and Videos; User Activity; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data that we receive about you, including: Payment Information and User Activity.
Legitimate interests – it is in our legitimate interests to ensure that Footci accounts are not fraudulent in order to safeguard users and provide an authentic and safe platform.
Comply with valid legal requests. Personal Data you share with us, including: Account Credentials; Hardware and Software Information; Profile Information; Location and Distance Information; Messages; Photos and Videos; User Activity; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data that we receive about you, including: Payment Information.
Comply with legal obligations
Address legal issues and disputes. Personal Data you share with us, including: Account Credentials; Hardware and Software; Information; Profile Information; Location and Distance Information; Messages; Photos and Videos; User Activity; Information and Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data we receive about you, including: Payment Information.
Comply with legal obligations
Investigate, prevent or respond to suspected illegal activities or fraud. Personal Data you share with us, including: Account Credentials; Hardware and Software Information, Profile Information; Location and Distance Information; Messages; Photos and Videos; User Activity; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data that we receive about you, including: Payment Information and User Activity.
Legitimate interests – it is in our legitimate interests to prevent and respond to unauthorized behavior within the Footci Services and to maintain the safety and authenticity of the Footci Services.
Administer and protect our services (troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Personal Data you share with us, including: Account Credentials; Hardware and Software Information; Profile Information; Location and Distance Information; Messages; Photos and Videos; User Activity; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data that we receive about you, including: Payment Information and User Activity.
Legitimate interests – it is in our legitimate interests to ensure the stability of the Footci Services and are able to use analytical data to troubleshoot problems.
Access your camera and photo roll and allow you to include photos in your Community Profile and photos and video messages in your private and group messages. Personal Data we collect from you, including: Profile Information; Messages; Photos and Videos. Consent
Facilitate the sharing of live location between you and other users. Personal Data we collect from you, including: Location and Distance Information; Profile Information; Messages. Consent
Share your Personal Data with our advertising partners. Personal Data we collect from you, including: Hardware and Software Information; Profile Information; Location and Distance Information; Cookies; Log Files and Other Tracking Technologies.
Additional Personal Data we receive about you, including: Third-Party Tracking Technologies.
Consent
Provide or show advertising on the Footci Services based on the Personal Data you provide or that we collect through the Footci Services. Personal Data we collect form you, including: Hardware and Software Information; Profile Information; Location and Distance Information; Cookies, Log Files and Other Tracking Technologies.
Additional Personal Data that we receive about you, including: Payment Information and User Activity.
Consent
Process your Personal Data to provide personalized advertising. Personal Data we collect from you, including: Hardware and Software Information; Profile Information; Location and Distance Information; Cookies, Log Files and Other Tracking Technologies. Consent
Create and/or administer surveys and conduct research of users’ behavior to improve the Footci Services. Personal Data we collect from you, including: Profile Information; Location and Distance Information; Hardware and Software Information; User Activity; Cookies, Log Files and Other Tracking Technologies; Feedback and Support; Surveys.
Additional Personal Data that we receive about you, including: Payment Information.
Consent

Automated Decision-Making.

Your safety and security are important to us. As such, we use automated decision-making as a part of our platform moderation efforts (for example, removing spammers) in order to ensure our platform is inclusive, safe, authentic, and open for all Footci users to make connections. Automated decision-making assists us in our attempts to prevent and respond to illegal, malicious, and unauthorized activity. If you are notified that your account has been banned and you believe this is an error, please email a Customer Support representative at support@footci.com to seek an appeal.

How We Share Your Personal Data.

We share Personal Data in the following situations:

Distance Information. The Footci App is designed to allow users to share Distance Information. Distance Information is public and indicates to other users of the Footci App the distance you are in feet or meters from them. Footci App users can use the explore feature in the Footci App to search for other users in a geographic location outside of their immediate location. Your Distance Information will be displayed in your profile in those users’ search results should you elect to display your relative distance. Sophisticated users who use the Footci App in an unauthorized manner, or other users who change their location while you remain in the same location, may use Distance Information to determine your exact location and may be able to determine your identity. Please note, you may choose to hide your Distance Information; however, the Footci App will continue to sort and display your profile based on your relative distance from other users. Accordingly, even if you choose to hide your Distance Information, others may nevertheless be able to determine your Location. You can disable location services on an iPhone by going to settings, privacy, location services, Footci and on Android, by going to settings, location, Footci, permissions, location.

Third Party Tracking Companies. When you sign up for the Footci Services we share your hashed Device ID, a portion of your Profile Information, Location Information, and demographic information with analytics partners. These third parties may also collect information directly from you as described in this Privacy Policy through tracking technologies such as cookies. The privacy policies of these third-party companies apply to their collection, use and disclosure of your Personal Data. For example, one of our partners is Google Analytics which collects information and reports website trends without identifying individual visitors. Information about Google’s privacy policy can be found here

Third-Party Advertising Companies. We share your hashed Device ID, your device’s advertising identifier, a portion of your Profile Information, Location Information, and some of your demographic information with our advertising partners. These third parties may also collect information directly from you as described in this Privacy and Cookie Policy through tracking technologies such as cookies. The privacy policies of these third-party companies apply to their collection, use and disclosure of your Personal Data. One of these advertising partners is Google AdMob that helps Footci deliver personalized advertising. You can follow the link to Google’s privacy policy. For more information on third-party tracking technology, please visit Cookie Information below. Note that for California consumers, by clicking that you agree to our Privacy and Cookie Policy you are directing us to disclose the information described in this paragraph to third-party advertising companies.

Third-Party Service Providers. We share your Personal Data with third-party service providers to: provide you with the Footci Services; conduct quality assurance testing; monitor activity on the Footci Services; provide technical support; and/or to provide other services to Footci. Except as otherwise stated in this Privacy Policy, these third-party service providers are required by contract not to use your Personal Data other than to provide the services requested by Footci.

Partner Promotion. From time-to-time we may offer contests, sweepstakes, or other promotions with third-party partners. If you decide to enter a contest, sweepstake, or promotion that is sponsored by a third-party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this Privacy Policy.

Business Transactions. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy and Cookie Policy.

Other Disclosures With Your Consent. We may explicitly ask if you would like us to share your information with other third parties who are not described elsewhere in this policy. For example, we may ask you if you would like to back-up your account, or the information stored within your local device, to a third-party back-up service such as Apple or Google cloud backup.

Legal Obligations. Footci may preserve or disclose Personal Data in response to a lawful legal requeest, including: subpoenas, warrants, or court orders, or in connection with any legal process; to comply with relevant laws; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law.

You share your Personal Data in the following situations:

Community Profiles. The Footci App is a social networking platform that is designed to allow users to connect and share information. When you use the Footci App, your Community Profile Information is public, and other users of the Footci App can see your Profile Information and other Personal Data (including sensitive personal data) posted by you. For example, other users can search for you, search for your profile characteristics, see if you’ve viewed their profile, or see you listed as being within their vicinity. Do not include information in your profile that you want to keep private. While the Footci App permits you to make certain items (e.g., Profile Information, preferences, or other information) non-public, sophisticated users who use the Footci App in an unauthorized manner may nevertheless be able to obtain this information and may be able to determine your identity.

Messages. You may choose to send messages, including photos, audio, location or videos, to other users. If you send messages, you will be providing Footci with your Personal Data as well as the user who views your message. Please don’t send messages or share content that you wouldn’t want someone to save or share as users may save content or copy it outside the Footci App. Please note, chat messages are stored locally on devices. Therefore, if you choose to delete your account, any chat messages you sent to another user may still be available on the other user’s device. Do not share your Account Credentials or payment information via chat (or any third-party platforms).

Live Location Sharing. You may elect to utilize the “Live Location Sharing” feature. If you use this feature, you share your specific location with another user for a predetermined period of time, as well as with Footci. Please note that while the Live Location Sharing is active, your Location is continuously shared in the background. You can revoke your consent to this sharing at any time by utilizing the in-app “stop sharing” button.

Social Features. The Footci Services include features that are designed to permit interactions that you initiate between the Footci Services and third-party websites or services, including third-party social networks (collectively, “Social Features”). For example, you may be able to “like” or “share” content from the Footci Services on other websites or services, such as Facebook, Twitter, Instagram, YouTube and LinkedIn. If you use Social Features on the Footci Services, both Footci and the third-party services that operate those Social Features may have access to certain Personal Data about you and your use of both the Footci Services and theirs. The Personal Data we collect in connection with your use of Social Features, such as usage information, is subject to this Privacy and Cookie Policy. The Personal Data collected and stored by third parties remains subject to those third parties’ privacy practices, including whether the third parties continue to share Personal Data with us, the types of Personal.

You agree and consent that the information and data outlined above may be shared with third parties as described throughout this document.

Data Retention.

We retain your Personal Data for no longer than is necessary to fulfill the purposes for which the information was collected (as indicated above), or as otherwise permitted or required by applicable law or pursuant to Footci Terms of Service or Footci Community Guidelines. Generally, Footci does not maintain user chat messages for longer than 24 hours once the message has been delivered to the recipient.

If you delete your account from within the Footci App, or instruct Footci to delete it on your behalf, your Profile Information and Location Information associated with your account will be removed from our systems within seven (7) days, unless retention is required for a legal propose. Chat images, user activity, and other Personal Data outlined above is deleted within 120 days of an account deletion. With respect to accounts that have been banned for violations of the Footci Terms of Service and/or Community Guidelines, Footci retains the hashed authentication mechanism used to create the account (e.g., phone number, email address, etc.) and limited log information associated with the reason for the ban. In some circumstances, Footci may retain chat messages used for reporting violative behavior resulting in an account’s ban.

Please note, as chat messages, images, and recordings are retained locally on user devices, chat messages, images, and recordings you have shared with other Footci users may still be retained on the recipient user’s device even after you have deleted your account.

How We Protect Your Personal Data.

At Footci, we take the privacy and security of your Personal Data seriously. We have a dedicated data security team that actively works to monitor the integrity and safety of the Footci Services. We have strict policies in place to help ensure your Personal Data is protected. We consistently strive to improve our defenses in the ongoing battle against bad actors. As such, we do not disclose any specific security tools or techniques we use so that we can better protect your Personal Data as we do not want to unwittingly educate those with malicious intent. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and Footci cannot guarantee the security of your Personal Data. In the event that we are required by law to inform you of any unauthorized access to your Personal Data, we may notify you electronically, in writing, if permitted to do so by law.

Your Choices.

You can make the following choices regarding your Personal Data:

Community Profile Information. When you create a Footci account, you choose to provide us Personal Data about yourself for your public Footci community profile. You can review and change your Community Profile Information at any time by accessing the “Edit Profile” section of the App.

Promotional Emails. You may choose during the registration process to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials related to Footci and/or the Footci Services, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you unsubscribe from receiving such promotional emails, we may still send you service-related communications, and our applications may deliver notifications directly to your mobile device in the Footci Ap.

Behavioral Advertising On Websites. Our websites may allow for third-party behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. For more information on third-party tracking technology, please visit Cookie Information below. That advertising may appear either on our website, or on other websites not operated by Footci. If you do not want third parties to collect information about your use of the Footci Services, or your affiliation to Footci, or to tailor any of the advertising that you see, you can opt out from some third party behavioral advertising at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the Footci Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

Behavioral Advertising Within The Footci App.If you are using the Footci Services on an Apple iOS device, you can opt-out of behavioral targeting by going into Settings > Privacy > Advertising on your iOS device, or visiting Apple’s website for more information. To opt out on an Android device, open the “Google Settings,” click on “Ads” and enable “Opt out of interest based ads.” Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the Footci Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.

Third-Party Tracking. You may opt-out of Google Analytics’ collection and use of your Personal Data by following the instructions here to download an opt-out browser add-on.

Your Rights.

You have the following rights regarding your Personal Data:

Subject to certain conditions, you may ask us to:

  • Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
  • Update or correct inaccuracies in your Personal Data.
  • Delete your Personal Data.
  • Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
  • Restrict the processing of your Personal Data.
  • Withdraw consent that you have previously given us. You may make this request at any time. Note that revocation of your consent will only apply to future processing activities and will not apply retroactively.
  • Object to reliance on our legitimate interests as the basis for processing of your Personal Data.

Note that these rights are not unlimited; there may be exceptions to these rights under applicable laws. For example, it will not be possible for us to delete your Personal Data if we are required by law to keep it (e.g., for tax and account purposes), or if we hold it in connection with a contract with you. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from disclosing such information. If we decline your request, we will tell you why, subject to legal restrictions.

Please note that due to Footci’s retention practices, some historical data may not be available as it is no longer held in Footci’s systems. Please see “Data Retention” above for information on Footci’s data retention practices. You can submit a request by email to privacy@footci.com or our postal address provided below. Where necessary, we may request specific information from you to help us confirm your identity prior to processing your request.

If you would like to submit a complaint about our use of your Personal Data or our response to your requests regarding your Personal Data, you may contact us at privacy@footci.com.

For EEA/U.K. Data Subjects.

  • You transfer your Personal Data to us in the United States. If we transfer your Personal Data onward to a jurisdiction not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be based upon one of the following safeguards recognized by the European Commission as providing adequate protection for Personal Data:
  • Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer.
  • The EU-U.S. Privacy Shield Framework (for transfers to third parties in the United States that have self-certified to the Framework).
  • Footci complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and/or Switzerland, as applicable, to the United States. Footci has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. 

Please note that in certain situations, Footci may be obligated to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

In accordance with the EU-U.S. Privacy Shield and Swiss-US Privacy Shield Principles, Footci is committed to resolving privacy complaints regarding our Personal Data practices. EU and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Footci at privacy@footci.com.

EEA individuals also have the right to lodge a complaint with a supervisory authority in the EEA Country where they reside or work, or where the alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) took place. You can find information about your data protection regulator here. Swiss individuals also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner. For complaints from EEA data subjects or Swiss individuals that cannot be resolved with Footci directly, Footci will cooperate with EEA and Swiss authorities and will implement the advice they provide with respect to such unresolved complaints, including by taking appropriate steps to correct Privacy Shield compliance issues.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield panel. With respect to the Personal Data received or transferred pursuant to the Privacy Shield Framework, Footci is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

For Footci App users in India or communicating with users in India: Footci may utilize an Amazon Web Services relay server based in Mumbai, India. The relay server does not typically store user data but facilitates the transmission of user data to the United States.

For California Residents.

California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations must disclose what categories of information are “collected,” “sold,” or transferred for an organization’s business purpose” as those terms are defined under California law. Note that Footci does not necessarily collect all categories of information about you. For example, while we may collect government issued identification as part of authenticating some users that make access requests, we do not collect such information from the majority of Footci users who are California residents. Footci may collect and transfer for business purposes the following categories of personal information from Footci’s California users: Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information; Characteristics of protected classifications; Commercial information; credit card information; debit card number; Driver’s License Number; Electronic network activity; Email address; Geolocation data; Identifiers (e.g., display name); Online identifiers (e.g., IP address); Passport number; Physical characteristics; Postal address; Signature; Social Security Number; Telephone number; Transaction Information. Further, you can learn more about the Personal Data we collect and how we use it by reading the “What Personal Data We Collect and Process” and “How and Why We Use Your Personal Data” section of this Privacy Policy. If you would like more information concerning the categories of Personal Data (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the Contact Information below. Note that for California consumers, by clicking that you agree to our Privacy Policy and Cookie Policy you are directing us to disclose the information described in this paragraph to third-party advertising companies and therefore Footci  does not sell your Personal Data. If you are a California resident and wish to exercise your rights under the California Consumers Protection Act (“CCPA”)(as outlined in the Your Rights section of this Privacy Policy), you may contact us by (1) clicking “Support” from within the settings menu in the Footci  App. Footci does not discriminate against California residents who exercise any of their rights described in this Privacy and Cookie Policy.

Cookie Information.

What are cookies:

“Cookies” are small text files placed on your device or browser when you visit a website or otherwise interact with an online service. Cookies collect and store information, which is sent back to our servers or those of third parties. Typically, cookies contain the domain name from which the cookie originated, the “lifetime” of the cookie (i.e., how long it lasts), and a randomly generated unique number or similar identifier. A cookie can also contain information about your device, such as settings, browsing history, and activities while using the Footci Services. To learn more about cookies, we encourage you to visit www.allaboutcookies.org.

First-party and third-party cookies. There are first-party and third-party cookies in connection with the Footci Services. First-party cookies are cookies placed on your device directly by us. For example, we use first-party cookies to adapt our website to your browser’s language preferences and to better understand your use of the Footci Services. Third-party cookies are placed on your device by our partners and service providers. For example, we use third-party cookies to gather performance data or to enable you log on using a third-party social media platform.

Session and persistent cookies. All cookies have an expiration date. There are session cookies which only last until you close your browser. We use session cookies for many reasons, including to learn more about your use of the Footci Services during a single browsing session so we can continue to ensure the Footci Services are effective and efficient. Persistent cookies have longer lifespans and are not automatically deleted when you close your browser. These types of cookies are typically used to help expedite your use of the Footci Services and for performance evaluation purposes.

Do you use other tracking technologies besides cookies?

Yes, we use other tracking technologies such as web beacons (also known as pixel tags or clear gifs), tracking URLs or software development kits (“SDKs) for similar purposes as cookies. Web beacons are tiny graphics files that contain a unique identifier that enable us to recognize when a person visits our Services. Tracking URLs are custom generated links that help us understand where the traffic to our webpages comes from. SDKs are pieces of code includes within apps which function like cookies and web beacons.

How does Footci use cookies?

As described in greater detail below, we may use cookies for the following purposes:

  • To collect statistical data on our users’ interactions with the Footci Services;
  • To conduct essential functions, such as identifying trusted web traffic;
  • To integrate with third-party social media platforms;
  • To track your behaviors and browsing activities over time across multiple websites or other platforms; and
  • To serve you with interest-based or targeted advertising on other websites.

When you use the Footci Services some or all of the following cookies may be set on your device:

Essential Cookies: these cookies are strictly necessary for the Footci Services to function optimally and provide you with the expected services. We do not allow the option to disable essential cookies, because without them the Footci Services cannot function optimally.

Analytics Cookies: these cookies help us understand how the Footci Services are being used, how effective marketing campaigns are, and help us customize and improve our Services for you. The information they gather is generally aggregated and anonymous, though some of these cookies may send certain pieces of information about you, including your personal data, to third-party service providers (e.g., Google).

Advertising Cookies: these cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on your interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad. Some of these cookies may send certain pieces of information about you, including your Personal Data, to parties outside of Footci.

Social Networking Cookies: these cookies are used to enable you to login to the Footci Services using a third-party platform. These cookies may be used for advertising purposes as well. These cookies may send certain pieces of information about you to the third-party platform (e.g. Facebook).

We may link the information collected by cookies with other information we obtain from you pursuant to this Privacy Policy and may use the combined information in ways as outlined herein. Similarly, the third parties who serve cookies within the Footci Services may link the data they obtain through their cookies within the Footci Services to other information they may have collected about you. Anytime you interact with or provide your Personal Data to a third-party site, we encourage you to consult the site’s privacy policy.

How can you control cookies?

There are several options available for you to use in order for you to manage cookies while using the Footci Services.

General Opt-Out. Most web browsers accept cookies automatically. You also may be able to configure your browser settings to use the Footci Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools -> Internet Options -> Browsing History -> Delete to view manual and automatic options.

To learn about how to manage cookies on popular browsers, please visit the links below:

You may also be able to reset device identifiers through settings on your mobile device. The procedure for managing device identifiers if different for each device. You can check the specific steps in the help or settings menu of your particular device.

Interest-based Advertising. You can opt out of seeing online interest-based advertising through the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Please note that opting-out of behavioral advertising does not mean that you will not receive advertising while using the Footci Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. You may also reset your advertising identifier on your device, or use the AppChoices app, or turn off location tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which many include “Do Not Track” instructions.

Google™ Analytics Cookies. We use Google Analytics, a Google service that uses cookies and other data collection technologies, to collect information about your use of the Footci Services. You can opt out of Google Analytics tracking by clicking here or by downloading the Google Analytics opt-out browser add-on here.

Flash Cookies. We may also use Flash cookies (also known as “persistent identification elements” or “local shared objects”) on certain websites. Because Flash cookies cannot be controlled through your browser settings, you may click here to adjust your preferences. You can also identify Flash cookies running on your computer by visiting the Flash Player folder. Flash cookies, or LSO files, are typically stored with a “.SOL” extension. Please note that if you block cookies, some functions on the Footci Services may be unavailable, and we may not be able to present you with personally-tailored content.

How we share. You agree and consent that the information and data outlined above may be shared with third parties as described throughout this document.

Additional Information.

The following additional information relates to our privacy practices:

Permissible Age. The Footci Services are intended only for users eighteen (18) years of age and older (or twenty-one (21) years of age in places where eighteen (18) years is not the age of majority). We do not intentionally gather Personal Data about visitors who are under the age of majority. If you are aware that a child or minor has submitted Personal Data on the Footci Services, please contact us using the information provided below, or using the in-app reporting tool, so that we can take appropriate action.

Third-Party Applications/Websites. We have no control over, do not review, and cannot be responsible for the privacy and data handling practices of other websites or applications. Once you click on a link to another website or third-party application, the terms of this Privacy and Cookie Policy do not apply.

Changes To This Privacy and Cookie Policy. If we make a material change to this Privacy and Cookie Policy we will, at a minimum, attempt to notify you of that change either by sending an e-mail to the last e-mail address that you provided to us (if any) or by notifying you when you log into the Footci Services.

Translations. In the event there is a discrepancy between this English language version and any translations of this Policy, the English version shall prevail unless otherwise required under applicable law.

Contact Information. Footci welcomes your comments or questions regarding this Privacy and Cookie Policy. Please contact us by email at privacy@footci.com or by postal mail at the following address:

Footci Systems LLC

Attn: Data Protection Officer

PO Box 202

Highmount, NY 12441

Effective Date: January 1, 2020 or the date of user acceptance.