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Privacy Policy

Last updated June 24, 2023

 

This privacy policy for Finders Keepers (“We,” “us,” “our,” “company”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“services”) when you sign up for early access.

Reading this privacy policy will help you understand your privacy rights. Should you have any questions or concerns, please contact us at hello@finderskeepers.design.

SUMMARY

Depending on your geographic location, there may be additional privacy laws in place that grant you additional rights not stated in this privacy policy. Should you require access to your data, please complete the “Data Request Form” in the APPENDIX: EXHIBIT A section at the end of this privacy policy.

 

1. INFORMATION COLLECTION

We do not process any sensitive information, nor do we receive any information from third parties. We also do not knowingly collect data from or market to minors under 18 years of age. We simply collect and process the information you provide to offer our services and comply with law.

Specifically, we collect your:

  • Phone number

  • City

  • Community

This information is collected at the time you sign up for early access.

Should you contact us, we may also collect information regarding your:

  • Name

  • Email address

  • Physical address

By signing up, you also expressly agree to receive text messages via your phone number. In these events, standard data and messaging rates may apply depending upon your carrier. If you wish to stop receiving text messages, simply send us an email at hello@finderskeepers.design with a completed “Data Requested Form” attached. Furthermore, if are relying on your consent to process your information, which may be express and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. To do this, send us an email at hello@finderskeepers.design with a completed “Data Request Form” attached.

 

 

2. INFORMATION PROCESSING

At this point in time, we process your information in the following ways:

  • To inform you of Finders Keepers launch in your city and to advertise future city availability

  • To comply with legal requirements, including responding to legal requests and exercising, establishing, and defending our legal rights

 

3. INFORMATION RETENTION

We keep your information for as long as necessary to fulfill the purposes of this privacy policy unless otherwise required or permitted by law (such as legal requirements). When we no longer have an ongoing legitimate business need to process your information, we will either delete or anonymize your information, or, if not possible (i.e., in cases where information is stored in backup archives), we will securely store your information and isolate from further processing until deletion is possible.

 

4. INFORMATION SAFETY

While we do have organizational and technical processes in place to protect your information, including password-protected and encrypted files, logs, and documents, no electronic transmission can be guaranteed to be 100% secure. As such, we cannot promise that cybercriminals will not be able to defeat our security and improperly access and steal your information.

 

5. DO-NOT-TRACK FEATURE CONTROLS

While most mobile operating systems and web browsers include a Do-Not-Track (“DNT”) feature you can activate to signal your privacy preference not to have data about your online browsing activities monitored. Right now, there is no uniform technology standard for recognizing and implementing  DNT signals. As a result, we do not respond to DNT browser signals, but if a standard is adopted in the future, we will inform you of this in a revised version of this privacy policy.

 

6. CALIFORNIA RESIDENT PRIVACY RIGHTS

While we do disclose your information to third parties, California Civil Code Section 1798.83 (“Shine the Light” law) does permit you to request and obtain from us information about our disclosure practices once a year and free of charge. If you would like to submit a request, send an email to hello@finderskeepers.design with a completed “Data Request Form” attached.

 

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

  • Every individual who is in the State of California for other than a temporary or transitory purpose and

  • Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your information.

Aside from “Identifier” information such as phone number and city, and in some cases name, email address, and physical address, we do not collect any other type of information, including but not limited to commercial information, biometric information, internet activity, protected classification characteristics, geolocation data, sensitive personal information, education information, professional or employment-related information, and audio, visual, electronic, thermal, olfactory, or similar information.

Your rights with respect to your personal data

Right to request deletion of data:

You can ask for deletion of your information, and if you do so, we will delete it except in cases provided by law such as compliance requirements resulting from a legal obligation or processing required to protect against illegal activities.

Right to be informed:

Depending on the circumstances, you have a right know:

  • Whether we collect and use your personal information;

  • The categories of personal information that we collect;

  • The purposes for which the collected information is used;

  • Whether we sell or share personal information to third parties (WE DO NOT SELL YOUR INFORMATION);

  • The categories of information sold, shared, or disclosed for a business purpose (WE DO NOT SELL YOUR INFORMATION);

  • The categories of third parties to whom the information was sold, shared, or disclosed for a business purpose (WE DO NOT SELL YOUR INFORMATION);

  • The business or commercial purpose for collecting, selling, or sharing information (WE DO NOT SELL YOUR INFORMATION);

  • The specific pieces of information we collected above you.

Right to non-discrimination:

We will not discriminate against you if you exercise your privacy rights.

Right to limit use and disclosure of sensitive personal information:

We do not process sensitive personal information.

Verification process:

Upon receiving a request, we do have to verify your identity to determine you are the same person about whom we have information. In these cases, we will request information including but not limited to your name, email address, and physical address, as well as confirm the validity of the information we do have, including your phone number, city, and community.

Other privacy rights:

  • You may object to the processing of your information.

  • You may request correct of your information if it is incorrect and no longer relevant, or ask to restrict the processing of your information.

  • You can designate an authorized agent to make a request under the CCPA on your behalf, but we may deny this request unless the agent submits proof that they are authorized to act on your behalf.

  • You may request to opt out – in this case, please send an email to hello@finderskeepers.design with a completed “Data Request Form” attached, and we will cease sending you text messages.

 

7. VIRGINIA RESIDENT PRIVACY RIGHTS

Under the Virginia Consumer Data Protection Act (CDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition of “consumer” applies to you, we will adhere to certain rights and obligations regarding your information.

Your rights with respect to your personal data:

  • Right to be informed whether or not we are processing your personal data

  • Right to access your personal data

  • Right to correct inaccuracies in your personal data

  • Right to request deletion of your personal data

  • Right to obtain a copy of the personal data you previously shared with us

  • Right to opt out of the processing of your personal data

Finders Keepers does not and has not sold any personal data to third parties, and we will not sell your personal data in the future.

Exercise your rights provided under the Virginia CDPA:

You can send us an email at hello@finderskeepers.design with a completed “Data Request Form” attached to request deletion of your personal data or opt out of text messages. You can designate an authorized agent to make a request under the CCPA on your behalf, but we may deny this request unless the agent submits proof that they are authorized to act on your behalf.

Verification process:

Upon receiving a request, we do have to verify your identity to determine you are the same person about whom we have information. In these cases, we will request information including but not limited to your name, email address, and physical address, as well as confirm the validity of the information we do have, including your phone number, city, and community. We will respond to such requests within forty-five (45) days of receipt.

Right to appeal:

If we decline to take action regarding your request, we will provide with the reasoning behind our decision. If you wish to appeal our decision, please send an email to hello@finderskeepers.design. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response, including the reasoning behind our decision. If your appeal is denied, you may contact the Attorney General to submit a complaint.

 

8. PRIVACY POLICY UPDATES

We may update this privacy policy from time to time. The updated version will include the latest date of the updates after the “Last Updated” text at the top of this privacy policy. It will be effective as soon as it is accessible. Additionally, we will ensure you are notified via text at the phone number you provided when you signed up for early access. We encourage you to review the privacy policy frequently to remain informed of how we are protecting your information.

 

9. VISITOR ANALYTICS

Visitor Analytics is a simple website analytics service that measures traffic on our website and collects general information from our website visitors. We create statistics to improve the experience of our website visitors. We never use cookies for this purpose.

As a website operator using Visitor Analytics to conduct reach measurement, depending on the level of data protection we have activated, we may process information about the device you are using and its characteristics, information about technical characteristics of the website visit, the number of page visits and statistically relevant behavior of our website visitors. The technology does not use the collected data to identify individual visitors or to match the data with additional information about an individual user.

Depending on the location from which you access our website, Visitor Analytics may not collect any information about the device you are using due to our technical settings.

10. CONTACT

If you have questions about this privacy policy, you may email us at hello@finderskeepers.design.

________________________________________________________________________________________

 

APPENDIX: EXHIBIT A – Data Request Form

 

Your name: ________________________________

Your phone number: _________________________

Your email address: __________________________

 

You are submitting this request as:

___ The person whose name appears above.

___ An agent authorized by the user to make this request on their behalf.

 

Under the rights of which law are you making this request:

___ CCPA

___ CDPA

___ General Privacy Law

___ None

 

I am submitting a request to:

___ Know what information is being collected from me.

___ Have my information and/or personal data deleted.

___ Withdraw consent to have my information / personal data processed.

___ Opt out of text messages.

 

Please leave details regarding your action request or question.

______________________________________________________________

______________________________________________________________

______________________________________________________________

______________________________________________________________

______________________________________________________________

 

I confirm that:

___ Under the penalty of perjury, I declare all the above information to be true and accurate

___ I understand that the deletion or restriction of my personal data is irreversible and may result in the termination of early access to Finders Keepers.

___ I understand that I will be required to validate my request by email and provide additional information, as required. Further, I understand that I may be contacted in order to complete the request.

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