Privacy Policy

Effective on March 20, 2020

Your Privacy Matters

This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy Settings.

Introduction

We are a social network. People use our Services to find to connect with others and find information. Our Privacy Policy applies to any Member or Visitor to our Services.

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge, post and view relevant content. Content and data on some of our Services are viewable to non-members (“Visitors”).

Services

This Privacy Policy, including our Cookie Policy, applies to your use of our Services.

This Privacy Policy applies to Factogram.ai, Factogram-branded apps, and other Factogram-related sites, apps, communications, and services (“Services”), including off-site Services, such as our ad services and the “Apply with Factogram” and “Share with Factogram” plugins, but excluding services that state that they are offered under different privacy policy.

Data Controllers and Contracting Parties

Factogram Corporation is the controller of your personal data provided to or collected by or for, or processed in connection with, our Services. As a Visitor or Member of our Services, the collection, use, and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

Factogram (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use, and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

Registration

To create an account you need to provide data including your name, mobile number, and a password.

Profile

You have a choice about the information on your profile, such as photos, location, and endorsements. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

You give other data to us, such as by syncing your address book or calendar.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.2 Data From Others

Others may post or write about you.

Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you are opt-out, we collect public information about you and make it available as part of our Services (e.g. suggestions for your profile, or notifications to others).

Others may sync their contacts or calendar with our Services.

Contact and Calendar Information

We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, scan and upload business cards, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.

Customers and partners may provide data to us.

Partners

We receive personal data about you when you use the services of our customers and partners.

Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates.

1.3 Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app, and platform technology, such as when you view or click on content or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps or share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies and Similar Technologies

We collect data through cookies and similar technologies.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. If you are outside the Designated Countries, we also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system, and browser information) so we can provide our Members with relevant ads and better understand their effectiveness. You can opt-out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

1.5 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser, and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a Factogram connection request, we track whether you have acted on it and will send you reminders.

1.7 Sites and Services of Others

We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your Factogram account.

We receive information about your visits and interaction with services provided by others when you log-in with Factogram or visit others’ services that include some of our plugins or our ads, cookies or similar technologies

1.8 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make so that our Services (including ads) can be more relevant and useful to you and others.

2.1 Services

Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive.

We use your data to authorize access to our Services and honor your settings.

Stay Connected

We use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for specific tasks.

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, job title, region). We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

Stay Informed

Our Services allow you to stay informed about news, events, and ideas regarding topics you care about, and from others you respect. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We use your content, activity and other data, including your name and photo, to provide notices to your network and others. For example, subject to your settings, we may notify others that you posted content, took a social action, used a feature, made new connections or were mentioned in the news.

2.3 Communications

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Factogram inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services.

2.4 Advertising

We serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
Member-provided information (e.g., profile, contact information);
Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
Information from advertising partners, vendors and publishers; and
Information inferred from data described above (e.g., using your feed activity to infer your interests, or using device data to recognize you as a Member).

We will show you ads called sponsored content that look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take social action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the Factogram Services, that action may be mentioned with related ads.

Ad Choices

We adhere to self-regulatory-principles for interest-based advertising and participate in industry oot-out from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads.

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks except for (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

2.5 Marketing

We promote our Services to you and others.

In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.

2.6 Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

Other Research

In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.7 Customer Support

We use data to help you and fix problems.

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.8 Insights That Do Not Identify You

We use data to generate insights that do not identify you.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.

2.9 Security and Investigations

We use data for security, fraud prevention, and investigations.

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our Terms of Services and/or attempts to harm our Members, Visitors or others.

3. How We Share Information

3.1 Our Services

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.

Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, vouches, follows, debunks and comments.

When you share an opinion or a fact publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors, and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
When you follow a user, you are visible to others.
We let senders know when you act on their message, subject to your settings where applicable.
Subject to your settings, we let a Member know when you view their profile.
When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile, and photo if you provided it).

3.2 Communication Archival

Regulated Members may need to store communications outside of our Service.

Some Members need, for legal compliance, to archive their communications and social media activity, and will use the services of others to provide these archival services. We enable archiving of messages by and to those Members outside of our Services.

3.3 Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your Factogram contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, and social media aggregators). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

3.4 Related Services

We share your data across our different Services and Factogram affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed or job recommendations based on your learning history.

3.5 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing, and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.6 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of Factogram, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.7 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases, we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use, and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-out and communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can:

Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of the personal data you provided in a machine-readable form.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Residents in the Designated Countries and other regions may have additional rights under their laws.

4.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your Factogram account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws that are different from, and potentially not as protective as, the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have a lawful base. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Factogram Services you have requested) and “legitimate interests.".

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us.

5.4. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5. Contact Information

You can contact us at support@factogram.ai or use other options to resolve any complaints.