PRIVACY & COOKIE POLICY

INTRODUCTION

Privacy and security of your personal information are very important to us. This Privacy & Cookie Policy describes how we, FOUND ME, a corporation governed by the laws of Switzerland (“Company,” ”we,” “our,” or “us”), collect, store, use, and disclose personal information (as defined below) of users of the websites found at www.foundme.com, and www.found.me, (collectively “Platform”).

We aim to limit our collection of personal information to only such personal information as required for legitimate purposes. We take appropriate security measures to protect your personal information and we respect your right to access your personal information or have it corrected or deleted, at your request. If you have any questions or want to know exactly what personal information we have collected about you, please contact us. All capitalized terms not defined herein are defined in our Terms & Conditions.

We may amend this Privacy & Cookie Policy from time to time. We will post any changes to this Privacy & Cookie Policy here so that you always know what information we gather, how we might use that information, and whether we will disclose that information to anyone. Please refer back to this Privacy & Cookie Policy on a regular basis. By using the Platform, you acknowledge that you accept the practices and policies outlined in this Privacy & Cookie Policy and you hereby consent that we will collect, store, use, and disclose your personal information as outlined in this Privacy & Cookie Policy. If you do not agree with any practices in this Privacy & Cookie Policy, please stop using the Platform and our Services.

PERSONAL INFORMATION COLLECTED THROUGH PLATFORM

“Personal information,” also known as personal data or personally identifiable information, is any information related to an identifiable person. When you sign up for an Account on the Platform, or place an order, we may collect the following personal information from you: first name, last name, profile photo, email address, phone number, emergency contact information, your physician’s contact information, insurance information, marital status, weight, height, date of birth, language spoken, distinctive signs, eye color, pet information (if any), billing information, IP address, whether you would like to donate your organs in case of your death, whether you have any infectious diseases and other medical conditions, and any personally identifiable and medical information that you provide to us voluntarily. You can provide us with as little information as possible, but we will ask you to provide us with your email address at a minimum, however, if you would like to make the best use of the Platform and the services we are offering, we encourage you to provide more than the minimum.

NON-PERSONAL OR AGGREGATE INFORMATION WE MAY COLLECT

We may collect data, which is non-personal, anonymous, or pseudonymous, including, but not limited to, time zone you are in, information on how you first heard about us, brand of your phone and software version, browser type, browsing history, number of logins, page views, language settings, and time/date of login.

PURPOSES FOR WHICH WE USE INFORMATION ABOUT YOU

We use information about you to support your experience throughout the Platform or to communicate with you about lost items, medical card, pet or person. In particular, we collect information about you to:

● recognize you as the user of the Platform;
● process your orders;
● respond to your inquiries or requests;
● send you newsletters and promotions about our subscriptions and products (FOUND ME Identifiers);
● conduct market research;
● allow our vendors (including payment processing and email marketing companies) to help us run our business smoothly;
● comply with all applicable laws or if we are required by law or by a court order to do so;
● analyze non-personal or aggregate information for the sake of Platform improvement; or
● transfer information in connection with the sale or merger or change of control of the Company

We reserve the right to use and disclose non-personal information and anonymous aggregate statistics for any purpose and to any third party at our sole discretion.

CONFIDENTIALITY OF YOUR CONTACT INFORMATION

Our goal is to make our Platform safe, secure and compliant with all applicable laws. By default, your contact information is not shared with Finders. However, you can choose which contact and medical information is publicly displayed and shared with Finders. We do not recommend making any contact information of yours available to the public, except for medical data, which can be useful for first responders (medical professionals). Examples of useful medical data is information on allergies, blood type, pregnancy, if any, etc.

To increase your confidentiality you can activate the Medical Info protection. This feature requires a medical emergency contact to release your profile once they have confirmed the emergency. In case of loss of the medical identifier you can block the medial part of the identifier. If a good Samaritan finds your identifier they can still get in touch with your to return it but will not have access to any medical information.

Nevertheless, please exercise caution in order to safeguard your identity, privacy, and anonymity by limiting contact and medical data you display to the public. You may change privacy settings at any time via your Account.

NOTIFICATIONS ABOUT YOUR LOST ITEMS, PETS, MEDICAL IDENTIFIERS, OR PERSONS

You can choose the way you are notified (emails, SMS / Text message, or in-app push notifications) when your lost item, pet, or person is found or when your identifier is scanned. If you have our mobile application installed and you are available, you may receive an in-app chat invitation to converse with the Finder. If you are not available to chat or you simply do not want to receive an in-app notification, we will use other methods of communicating with you based on your notification preferences. Notifications preferences can be managed in your Account.

BUSINESS TRANSFERS

We may sell, transfer or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets.

HIPAA PRIVACY RULE

The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers (“covered entities”) that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patient’s rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections. To learn more about HIPAA Privacy Rule, click here.

The Company is not considered a covered entity; therefore, we do not need to comply with the HIPAA Privacy Rule. Nevertheless, rest assured that we keep your medical information secure and in confidence by using HIPAA-compliant servers and share it only with intended parties, including Finders and first responders (medical professionals).

SOCIAL LOGINS

Social login is a form of single sign-on using existing information from a social media service such as Facebook or Google, to sign in and register on a third-party website. We offer you an option to register and sign in on our Platform using your social media accounts from Facebook and Google. If you choose to register and sign in on our Platform using any of your social media accounts, we may have access to certain information about you. The profile Information we receive may vary depending on the social media service concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. We will use the information we receive only for the purposes that are described in this Privacy & Cookie Policy. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media services. These social media services may collect your personal information and monitor your activity on the Platform. Please refer to their respective privacy policies to learn more about their data collection, storage and usage policies.

FEEDBACK & REVIEWS

If you submit any feedback, review, or suggestion (collectively, “Feedback”) to us, you hereby assign to Company all rights in the Feedback and agree that Company shall have the right to use such Feedback and related information in any manner it deems appropriate. We will treat any Feedback you provide to us as non-confidential and non-proprietary. You agree that you will not submit to us any information or ideas that you consider to be confidential or proprietary.

COOKIES POLICY

This Cookie Policy provides information about our use of cookies in connection with your use of and interaction with our Platform.

A “cookie” is a small piece of data sent along with pages of a website and stored by the user’s web browser on the user’s computer or mobile device. Cookies were designed to be a reliable mechanism for websites to remember certain information (such as items added in a shopping cart) or to record a user’s browsing activity (including clicking particular buttons, logging in, or recording which pages were visited in the past). Cookies are intended to help you access a website faster and more efficiently, because they can store information to help you enter a website without having to log in. In effect, cookies tell the website that your browser has been to the website before. It does not need to know your exact identity. Cookies can also be used to remember arbitrary pieces of information that the user previously entered into form fields such as names, addresses, passwords, and credit card numbers.

Like many other websites, we also use cookies on our Platform. By using the Platform, you agree that we may install cookies listed below. These cookies ensure that certain parts of the Platform work properly and that your user preferences remain known. You do have the right to opt-out and to object against the further use of any cookies. However, if you do so, please keep in mind that our Platform may no longer function properly for you.

Cookies we use:

Type of cookie	What it does
Cookies necessary for essential website purposes	These cookies are essential to provide you with the Platform and any service available through the Platform and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible.
Functionality Cookies	Functionality cookies record information about choices you’ve made and allow us to tailor the Platform to you. These cookies mean that when you continue to use or come back to the Platform, we can provide you with our Services as you have asked for them to be provided. These cookies allow us to: ● Remember settings you have applied, such as layout, text size, preferences, and colors; ● Store accessibility options.
Performance Cookies	We use performance/analytics cookies to analyze how the Platform is accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Platform. We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Platform. Like many services, Google Analytics uses first-party cookies to collect information about how users use our site. This information is used to compile reports and to help us improve the Platform. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit the Platform – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout. These cookies allow us to: ● Better understand our visitors so that we can improve how we present our content; ● Test different design ideas for particular pages, such as our homepage; ● Collect information about the Platform visitors such as where they are located and what browsers they are using; ● Determine the number of unique users of the Platform; and ● Improve the Platform by measuring any errors that occur.
Advertising and Targeting Cookies	As you use the Platform, you will notice that it features advertising. We allow third party companies, including advertising companies, to place cookies on the Platform. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. Such cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used to help tailor the ads you see, and to measure the effectiveness of ads.
Social Media Cookies	On some pages of the Platform, third parties that provide applications through the Platform will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of the Platform will also contain embedded content, such as video content from YouTube, and these sites will set their own cookies. These cookies are used when you share an article using a social media sharing button on our Platform (e.g., Facebook, Twitter, or Youtube) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.

MINORS (CHILDREN) POLICY

We are committed to protecting children’s personal information and comply with the strictest privacy laws out there. We do not knowingly collect or solicit personal information from anyone under the age of majority. If you have not reached the age of majority in your state or province of residence (normally age of majority is set to 18), please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a minor, we will delete that information as quickly as possible. Please contact us if you believe we may have collected information from a minor.

HOW LONG WE KEEP YOUR INFORMATION

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy & Cookie Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements) or up until such time when you withdraw your consent for processing it. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

DATA STORAGE

We use secure servers to safely store your information. The data centers where we store your information are located in Switzerland. Please keep in mind that the data protection and privacy laws of Switzerland may not be as comprehensive as the laws in your country. For example, personal data transferred to Switzerland may be subject to lawful access requests by state authorities in Switzerland. By providing your personal information, you consent to any transfer of your data and processing in accordance with this Privacy & Cookie Policy.

SECURITY

Security, privacy and compliance are in our DNA, which is why we are constantly working to ensure our solutions meet the latest global data safety standards. We undergo external audits and reviews to ensure our services are ready for Operating Systems and hardware changes and updates, which could disrupt service availability and data safety.

In order to protect the Platform against random QR code and serial number attacks we are using cyclic redundancy checks (CRC). CRC is designed to detect deliberate as well as accidental changes in raw data. A part of the QR code is used to check if the supposed Finder is attacking our servers by entering random codes. When a CRC error is detected for the first time, a series of corrective actions can be taken against data corruption with a reinforcement of the security using anti-robot inputs. Our security system can escalate and block the source IP when the error is repetitive.

Moreover, access to the Platform’s database with your personal information is held behind administrative logins and managed, controlled and limited to authorized website administrators and support technicians only. Data transmitted between browser and application servers is encrypted using an HTTPS/SSL certificate. We do not collect or store your passwords. We use XSRF against cross-domain attacks. Data is backed up daily. The Platform’s server software is updated regularly to ensure we are running the latest and safest software (where applicable and depending on compatibility). The server’s firewall is configured to prevent unauthorized access, and activity is automatically monitored to detect and ban malicious activity.

Please be aware, however, that despite our efforts, no security measures are impenetrable. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your personal information, we cannot ensure and do not warrant the security of any information you transmit to us.

THIRD PARTY ADVERTISING & LINKS

Occasionally, at our discretion, we may include or offer third party ads on our Platform. These third-party ads may contain links that would lead to third party websites. We have no responsibility or liability for the content and activities of these linked sites, and we encourage you to read their privacy policies before buying any product or service from them. Nonetheless, we seek to protect the integrity of our Platform and welcome any feedback about these third-party websites.

Moreover, we may allow third-party companies to serve ads and/or collect certain anonymous information when you access the Platform. These companies may use non-personally identifiable information (e.g., clickstream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to our Platform in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third-party web beacon to collect this information. To learn more about this behavioral advertising practice, or to opt out of this type of advertising, visit the website of Network Advertising Initiative or “NAI”. Please keep in mind that opt out does not apply to advertising from non-NAI members. We are not an NAI member, and do not represent that the Platform fully complies with all NAI standards.

AFFILIATE PROGRAM & LINKS

We run an affiliate marketing program, through which an affiliate earns a commission for marketing our Platform, FOUND ME Identifiers and Services through his/her social media channels. We may share your personal information with an affiliate if you placed any order through an affiliate link. We do not share personal information with all of the affiliates, only a selected few.

If you are a California resident, you have the right to say no to the sale of personal information. To learn more, please visit our Do Not Sell My Personal Information webpage.

WE DO NOT RESPOND TO DO NOT TRACK SIGNALS

Our Platform does not respond to and does not support the Do Not Track (DNT) header request field. If you turn DNT on in your browser, those preferences will not be communicated to us in the HTTP request header, and we will continue tracking your browsing behavior.

YOUR RIGHTS UNDER GDPR

The European General Data Protection Regulation (“GDPR”) is a regulation in EU law on data protection and privacy for all-natural persons accessing the Internet from the European Union and the European Economic Area, whatever their nationality or place of residence is. It also addresses the transfer of personal data outside the EU and EEA areas. Our collection, processing and protecting of personal information of those who access the Platform from a European country, is compliant with GDPR.

If you are accessing and using the Platform from the European Union and the European Economic Area, you have the following rights with regard to your personal information:

a. the right to be informed about what kind of information about you is collected, stored, processed and disclosed by us (that is why we have compiled this Privacy & Cookie Policy for you);

b. the right of access (you can request us to provide you verbally or in writing with the type of information we store about you and we have a month to respond to your request);

c. the right to rectify (amend/correct) any personal information about you that is inaccurate;

d. the right to erasure (some conditions apply, see Data Retention section below);

e. the right to restrict processing your personal information, however, if you restrict us from processing a part of your personal information that is essential to our provision of the Platform and Services, you may be asked to terminate your Account and stop using the Platform;

f. the right to data portability (the right to data portability allows users of the Platform to obtain and reuse their personal information for their own purposes across different services; you may request us to transmit your personal information directly from our servers to another company’s servers and we will do so if it is technically feasible);

g. the right to object (for example, you have an absolute right to stop us from using your personal information for direct marketing – read our opt-out instructions below; you may express your objection verbally or in writing and we have a month to respond to any such objection; we might still continue processing your personal information if we are able to show that we have a compelling reason for doing so);

h. the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or that affects you significantly.

We represent and warrant that your personal information is:

processed lawfully, fairly and transparently;
collected only for specific legitimate purposes;
collection of personal data is adequate, relevant and limited to what is necessary;
accurate and kept up to date (with your help);
stored only as long as is necessary; and
is secure and kept in confidence.

Data Retention: Generally, your personal information will be erased when (i) it is no longer needed for its original processing purpose, (ii) you withdraw your consent for us to store by deleting your Account, (iii) there is no preferential justified reason for the processing of your personal information and you object to our processing of your personal information, or (iv) erasure of your personal information is required in order to fulfil a statutory obligation under the EU law or the right of the EU Member States. Therefore, we will make sure your personal information will be erased under all of the above-mentioned circumstances. You may request us to erase your personal information verbally or in writing and we have one (1) month to respond to any such request.

Data Breach Notification: Should there be a personal data breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we will notify you and appropriate supervisory authority without undue delay and, where feasible, not later than seventy-two (72) hours after having become aware of it.

YOUR RIGHTS UNDER CCPA

The California Consumer Privacy Act (“CCPA”) is a state-wide data privacy law that regulates how businesses all over the world are allowed to handle the personal information of California residents. CCPA provides California residents with five core rights to data privacy and an effective way to control their personal information

If you are a California resident, you have the following rights with regard to your personal information:

the right to know what personal information is being collected about you.
the right to know whether your personal information is sold or disclosed and to whom.
the right to say no to the sale of personal information (“the right to opt out”); we have created a Do Not Sell My Personal Information webpage that provides you with more details on this matter.
the right to access your personal information (under CCPA, a business may provide personal information to a consumer at any time, but shall not be required to provide personal information to a consumer more than twice in a 12-month period);
the right to equal service and price, even if you exercise your privacy rights.

Additionally, a California consumer has the right to request that a business delete any personal information about the consumer which the business has collected from the consumer. However, a business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to: Additionally, a California consumer has the right to request that a business delete any personal information about the consumer which the business has collected from the consumer. However, a business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to:

complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
debug to identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business;
comply with a legal obligation;
otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Conflict resolution under CCPA: Prior to initiating any action against a business for statutory damages on an individual or class-wide basis, a California consumer shall provide a business 30 days’ written notice identifying the specific provisions of this title the consumer alleges have been or are being violated. In the event a cure is possible, if within the thirty (30) days the business actually cures the noticed violation and provides the consumer an express written statement that the violations have been cured and that no further violations shall occur, no action for individual statutory damages or class-wide statutory damages may be initiated against the business. Contact us should you need to exercise any of your rights under CCPA.

YOUR RIGHTS UNDER LGPD

Lei Geral de Proteção de Dados (“LGPD”) is the Brazilian general data protection law, which applies to businesses that process the personal data of users located in Brazil. LGPD establishes rules on collecting, handling, storing and sharing of personal data managed by organizations.

According to the article 18 of LGPD, individuals have the following nine rights over their data processing:

The right to receive a confirmation about processing of their personal data;
The right to access their personal data;
The right to correct incomplete, inaccurate or out-of-date personal data;
The right to anonymize, block or delete unnecessary or excessive data or data processed in noncompliance with the provisions of LGPD;
The right of portability of the data to another service or product provider, by means of an express request and subject to commercial and industrial secrecy, pursuant to the regulation of the controlling agency;
The right to delete their personal data;
The right to know who their data is being shared with (e.g., third parties, sub-processors, public, and private entities);
The right to know how to deny consent and what would be the consequences of denying consent to collect personal data; and
The right to revoke consent.

Company has appointed a Data Protection Officer (DPO), who will receive requests and complaints, and who will communicate with its clients and local authorities (as and when required under LGPD). If you are located in Brazil, you may exercise any of the above rights by contacting Company’s DPO, whose contact information you will find at the bottom of this Privacy & Cookie Policy.

MARKETING EMAILS, OTHER COMMUNICATIONS & OPT-OUT OPTION

With your consent, you will receive updates, newsletters, surveys, offers, ads and other promotional materials from us via your email, SMS, and push notifications. You may indicate a preference to stop receiving further marketing communications from us by changing your email marketing preferences in your Account. Despite your indicated preferences, we may send you service-related communication, including notices of any updates to Platform’s Terms and Conditions, Privacy & Cookie Policy, disclaimers, or other statements.

CONTACT US

If you would like to exercise any of the above rights or learn more about this Privacy & Cookie Policy, please contact us. Email: legal@foundme.com