Privacy Policy

1. PURPOSE
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This Privacy Policy is incorporated by reference into the Fohr Terms of Service (the "Terms"). The terms "Fohr," "we," and "us" include Fohr Card Inc and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined in Section 11 or otherwise herein will have the meanings set forth in the Terms.

2. SCOPE
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This Privacy Policy applies to Personal Information (as defined below) that is Processed by Fohr in the course of our business, including on Fohr websites (each a "Site"), mobile applications, web services databases, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Fohr, the "Services"). All individuals whose responsibilities include the Processing of Personal Information on behalf of Fohr are expected to protect that data by adherence to this Privacy Policy.

3. TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

3.1 TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
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While using our Services we collect certain information that can be used to contact or identify you (“Personal Information”) regarding our current, prospective, and former clients, customers, users, visitors, and guests (collectively "Individuals"). The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Fohr and the requirements of applicable law. The Personal Information we collect can include the following, which for reference is categorized in conformance with the California Privacy Rights Act (California Civil Code 1798.140(v)(1)):

• (A) Identifiers such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• (B) Any personal information described in subdivision (e) of California Civil Code Section 1798.80, such as name and address.
• (C) Characteristics of protected classifications under California or federal law.
• (D) Commercial information, including records of products or services purchased, obtained, or considered.
• (F) Internet or other electronic network activity information, including, but not limited to, browsing history and information regarding a consumer’s interaction with our Sites.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information.

‍Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Fohr, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Account Creation. We may collect Personal Information from when you sign up to create an account on our Site. Generally, Personal Information such as name and email address are required when you create an Account.

Services. We collect and maintain certain commercial, identifying, and protected classification data from users necessary for us to perform services for you. Commercial data includes, but is not limited to, products and services purchased by users. Identifiers include, but are not limited to, name, unique identifiers (“UID”), email addresses, alias’ and usernames. Protected classification information includes, but is not limited to, race, religion and gender.  If you voluntarily provide such data, we collect protected classification data for the creation of user profiles for influencers to use on their personal social media platforms. We collect identifying information for the purpose of creating user accounts for our clients' employees to access the Site.

‍Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you choose to request information about our Services, register for Fohr's newsletter that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.

Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products and/or Services and in any manner consistent with the policies provided herein.

Posting on the Services. Fohr may offer publicly accessible blogs, private messages, or community forums ("Community Features"). You should be aware that, when you disclose information about yourself through Community Features, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Services, such content will be considered "public" and will not be subject to the privacy protections set forth herein.

‍Automatic Data Collection. We may collect, either independently or through service providers, certain information automatically through our Services, email marketing, or other methods of web analysis. Such information includes your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, emails you interact with, the date and time of your visit, the amount of time you spend on each page, information about the links you click, search terms and pages you view within the Services, how others interact with your social-media content, and other actions taken through use of the Services such as preferences.

‍Feedback Submitted Via Services. You agree that Fohr is free to use the content of any feedback or other communications submitted to Fohr by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Fohr will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

‍Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you connect your Account with or otherwise use a Third-Party application, such as social networking sites like Twitter or Instagram (each, a "Social Network") or an app store, such as the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, "App Stores"), we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or Social Network accounts may include your name, your Social Network user identification number, your Social Network user name, location, sex, birth date, email, profile picture, and your contacts on the Social Network. We may also collect audience demographics data for Social Networks. This supplemental information allows us to verify information that you have provided to Fohr and to enhance our ability to provide you our Services, products and information about our business.

3.2 HOW FOHR USES YOUR INFORMATION
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We acquire, hold, use, and Process Personal Information about Individuals for the following purposes, and as otherwise described in this Privacy Policy or at the time of collection:

‍Delivery of Services. We may use your Personal Information in order to achieve our legitimate business interest of delivering Services you request or to fulfill contractual obligations to you.

‍Administrative Purposes. Fohr may use Personal Information about you for its administrative purposes, including to:

• Measure interest in Fohr's Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual Accounts and activities on Fohr's Services and systems, and, in Fohr's discretion, changes to any Fohr policy;
• Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
• Process payment for products or services purchased;
• Process applications and transactions;
• Prevent potentially prohibited or illegal activities;
• Enforce our Terms.

‍Direct Marketing. Fohr may use Personal Information to provide you with marketing materials about offers, products, and Services that may be of interest, including new content or Services as permitted by law. You will have the ability to opt-out of our marketing and promotional communications by following the unsubscribe link at the bottom of our marketing communications as detailed in Section 5 below.

‍Research and Development. Fohr may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. We may share anonymous Individual and aggregate data for research and analysis purposes.

‍To Comply with Laws and Regulations. We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

‍For Compliance, Fraud Prevention and Safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.

For any other purpose you consent to at the time of collection. Provided that if we intend to subsequently use your Personal Information for a different purpose, we will obtain your consent for such different purpose.

3.3 COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits as outlined in Section 5.5 below.

3.4 THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS

The Services, including any emails or advertisements, may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Fohr does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

The Site and our other Services may also contain links and interactive features with various Social Networks (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online through such Social Networks may be accessible by the providers of such Social Networks and, if posted publicly, may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a Social Network, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

We may use Third-Party application programming interface (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow Third-Parties including analytics and advertising partners to collect your Personal Information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact Fohr by email at privacy@fohr.co. We use YouTube API Services, for more information on Google’s privacy practices, please visit http://www.google.com/policies/privacy. You can revoke access to your Personal Information via the Google security settings page at https://security.google.com/settings/security/permissions or by contacting Fohr by email at privacy@fohr.co.

3.5 THIRD-PARTY PAYMENT PROCESSING

When you make purchases through the Services, we process your payments through a Third-Party payment processor, such as Stripe, Inc. ("Payment Processor"). The Payment Processor may collect certain financial information from you to process a payment on behalf of Fohr, including your name, email address, address and other billing information.

4. ONWARD TRANSFER-FOHR MAY DISCLOSE YOUR INFORMATION

4.1 INFORMATION WE SHARE

We may share your Personal Information, for the purposes outlined above, with the following categories of recipients or for the following reasons:

‍Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) payment processing; (iii) customer service activities; and (iv) other providers that may be necessary for the provision of the Services.

‍Business Partners. Fohr may share Personal Information with our business partners, and affiliates for our and our affiliates' internal business purposes, as part of the Services we provide to you or at your request.

‍Discovery & Ambassador Management Platform. Fohr may share Personal Information with third party customers (including brands) for the provision of the Discovery and Ambassador Management Platform offerings provided to such third parties.

‍Displaying to Other Users. When you post or make information available using the Community Features, that information will be available to other users that can access that post. We are not responsible for the privacy practices of the other users who will view and use the posted information.

‍Marketing - Interest-Based Advertising and Third Party Marketing. Through our Services, Fohr may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Fohr related websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.

‍Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours', ours' or others' rights, property, or safety; (iv) to enforce Fohr policies or contracts; (v) to collect amounts owed to Fohr; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes - e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

‍Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Fohr will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

4.2 INTERNATIONAL DATA TRANSFERS

You agree that all Personal Information collected via or by Fohr may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Fohr, you explicitly consent to the storage of your Personal Information in these locations.

If you live in the European Economic Area (the “EEA”), the Personal Information that we collect from you may be transferred to, and stored at, a destination outside the EEA.  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. By submitting your Personal Information, you agree to this transfer, storing or processing outside of the EEA. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of United States and the adjudication of any disputes arising in connection with Fohr or the Site will be in accordance with the Terms.

4.3 SALE OF PERSONAL INFORMATION

We do not sell your Personal Information and will not do so in the future without providing you with notice. We may disclose your Personal Information for the following purposes, which are not a sale: (i) if you direct us to share your Personal Information, (ii) disclosures as part of a merger or asset sale, and (iii) as otherwise required or permitted by applicable law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information.

5. OPT-OUT

5.1 GENERAL

You have the right to object to and opt out of certain uses and disclosures of your Personal Information by deleting your Account. Where you have consented to Fohr's Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent and delete your Account at any time and opt-out to further Processing by contacting curran@fohr.co or through the functionality of the Services. To the extent you opt-out of our use of Personal Information and/or Sensitive Personal Information but continue to use the Services, we may collect and use non-Personal Information such as de-identified data and publicly available information.    

5.2 EMAIL AND TELEPHONE COMMUNICATIONS

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Please note: We may also send you certain non-promotional communications, however you will not be able to opt out of those communications (e.g., transactional communications, including emails about your account or products or services you have requested; and communications regarding updates to our Terms or this Privacy Policy).

5.3 MOBILE DEVICES

Fohr may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Fohr may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

5.4 "DO NOT TRACK"

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not currently respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.5 COOKIES AND INTEREST-BASED ADVERTISING

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada..

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. This Privacy Policy does not cover the use of tracking technologies by third parties in connection with their websites. These third parties may use cookies or other tracking technologies to collect information about you when you interact with their content on the Services. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites. Please be aware that we do not control these third parties' tracking technologies or when and how they may be used. Therefore, Fohr does not claim nor accept responsibility for any privacy policies, practices, or procedures of any such third party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly.

6. PRIVACY CONTROLS AND HOW TO EXERCISE SUCH CONTROLS

6.1 PRIVACY CONTROLS

At Fohr we put our customers first and respect your ability to exercise your privacy rights and choices. Where possible, we give you control over the personal data we collect about you, to ensure it is accurate and reflects your preferences.  This Section describes key controls for managing your privacy across our Services. You may request the follow as it pertains to any Personal Information we collect:

Request Deletion. You may request that we delete any Personal Information about you that we maintain.

Request Correction. You may request that we correct any inaccurate Personal Information that we maintain.

Know What Personal Information is Being Collected. You may request that we inform you of the (i) categories of Personal Information we have collected about you; (ii) categories of sources from which any Personal Information is collected; (iii) business or commercial purpose for collecting, selling, or sharing any Personal Information we have collected about you; and (iv) categories of third parties to whom we have disclosed any Personal Information.  The categories of Personal Information collected over the past 12 months and the categories of sources from which we collect Personal Information are outlined in the Section above entitled "TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT.” The business/commercial purpose for the collected information is outlined in the Section above entitled “HOW FOHR USES YOUR INFORMATION” The categories of third parties to whom we have disclosed any Personal Information is outlined in the Section above entitled “THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS.”

Access the Personal Information We Collect. You may request a copy of the Personal Information that we have collected and maintained in the period that is 12 months prior to the request date.

Know What Personal Information is Being Sold. You may request the (i) categories of Personal Information that we have sold or shared to a third party and the category of the third party to whom we sold or shared your Personal Information; and (ii) categories of Personal Information we have disclosed to a third party for a business purpose and the category of the third party to whom we disclosed your Personal Information. The categories of third parties to whom we have disclosed any Personal Information is outlined in the Section above entitled “HOW FOHR USES YOUR INFORMATION.” We do not sell your Personal Information to third parties and have not sold Personal Information in the preceding 12 months.

Opt Out of Profiling and Targeted Advertising. You may opt out of the processing of your Personal Information obtained from your activities on non affiliated websites or online applications for the purposes of targeted advertising.

Opt Out of Sale and Sharing. To the extent we sell or share Personal Information, you may direct us to opt out of that sale or sharing. We do not sell your Personal Information to third parties and have not sold Personal Information in the preceding 12 months.

Restrict Processing of Personal Information. You may request that we restrict the Processing of your personal data, under certain conditions with exceptions provided for by applicable Data Privacy Laws.

Object to Processing of Personal Information. You may object to our processing of your personal data, under certain conditions with exceptions provided for by applicable Data Privacy Laws.

Opt-Out of Sharing Personal Information with Third Parties for Marketing Purposes. You may opt-out of a company’s disclosure of Personal Information to third parties for its direct marketing purposes, to the extent we disclose your Personal Information to third parties for such purposes. It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.

‍Request Data Portability. You may request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions with exceptions provided for by the applicable Data Privacy Laws.

Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the use of your Personal Information to only uses that are necessary to perform the services or provide the goods

6.2 EXERCISING YOUR PRIVACY CONTROLS

If you have us with your Personal Information, you may request the above by submitting a verifiable consumer request to us by email at privacy@fohr.co  or at the mailing address below.

Under applicable Data Privacy Laws, you may also designate an authorized agent to make these requests on your behalf. If you use an authorized agent to submit a request, we may need to collect additional information, such as a government issued ID, to verify your identity before processing your request to protect your information. In most cases, we will facilitate your request through automated tools available through your password-protected account.

We cannot respond to your request if we are unable to verify your identity or authority. Your verifiable request must include the reference “Request for Privacy Information” in the subject line and the body of the message must: (a) provide sufficient information that allows us to reasonably verify that you are the person whose Personal Information we have collected; (b) describe your request with sufficient detail; and (c) include an email address or mailing address, as applicable, for us to send our response. Such requests will be processed in line with applicable Data Privacy Laws.

We strive to respond to verifiable consumer requests within 30 days; however, if we require an extension (up to an additional 60 days) we will inform you of this extension and the reason in writing. Data disclosure request will only include data collected within the 12-month period preceding the receipt of the verified request. We do not charge a fee to process requests to exercise your rights unless the requests are found to be excessive, repetitive, or unfounded.

Although Fohr makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Fohr is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If Fohr determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.

If you have any questions or comments about the processing of your Personal Information, you may contact us at: privacy@fohr.co.

7. DATA RETENTION

Fohr retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Site or sending an email to you. You may have a legal right to receive this notice in writing.

9. CHILDREN'S PRIVACY

The Services are not directed to children under 13 years of age, and Fohr does not knowingly collect Personal Information from children under 13 years of age. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the user’s Account.

10. CHANGES TO OUR PRIVACY POLICY AND PRACTICES

10.1 CHANGES TO OUR PRIVACY POLICY AND PRACTICES

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

‍Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

‍Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Fohr will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

‍New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by Data Privacy Laws or contract, Fohr will endeavor to comply with the applicable Data Privacy Laws or contract.

11. DEFINITIONS

The following capitalized terms shall have the meanings herein as set forth below.

"Agent" means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Fohr or to which Fohr discloses Personal Information for use on its behalf.

“Data Privacy Laws” means all privacy, data protection and information security-related laws and regulations applicable to Processing of Personal Information, including, where applicable, but not limited to, the General Data Protection Regulation (“GDPR”), United Kingdom General Data Protection Regulation (“UK GDPR”), Federal Act on Data Protection of 25 September 2020 (“FADP”), and California Privacy Rights Act of 2020 (“CPRA”).

"Personal Information" is any information relating to an identified or identifiable natural person that can be used to contact or identify an Individual.

"Process" or "Processing" means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Sensitive Data" or "Sensitive Personal Information" is a subset of Personal Information which, due to its nature, has been classified by applicable Data Privacy Laws as deserving additional privacy and security protections; including  following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual's sex life; or (8) information relating to the commission of a criminal offense.

"Third Party" is any company, natural or legal person, public authority, agency, or body other than the Individual, Fohr or Fohr's Agents.

12. CONTACT

If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Fohr by email at privacy@fohr.co or by mail to the following address: 72 Allen St., Third Floor, New York, New York 10002. We will address your concerns and attempt to resolve any privacy issues in a timely manner.