I. COLLECTION OF INFORMATION

I.I. Information You Provide to Us. We collect information that you provide directly to us. For example, we collect information when you create an account, update your profile, communicate with customer support, or otherwise interact with the Services. The types of information we may collect include your first and last name, title, email address, phone number, address, organization, and any other information you choose to provide.

I.II. Information We May Collect Automatically When You Use the Services. When you use the Services, we may automatically collect certain information about your device and your interactions with the Services, including:

(a) Usage Information: We may collect information about how you use the Services, including which features you access, your interactions with the Platform or App, any subscriptions you purchase, and the dates and times you access the Services. Usage information may also include metadata associated with the User Content you provide, such as file sizes, the number of users granted access, view counts, and similar operational data.

(b) Log Information: We may collect server logs in connection with your use of the Services. This may include your IP address, device information, browser type and language, the specific actions you take within the Services, the date and time of such actions, and the page you visited before navigating to the Services.

(c) Cookies and Other Tracking Technologies: We and our service providers may use a variety of tracking technologies, including cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your device that help us improve the Services, enhance your experience, identify popular features, and count visits. Web beacons (also called pixel tags or clear GIFs) are small electronic images used to deliver cookies, count visits, and measure engagement and the effectiveness of communications.

I.III. Information We Collect From Other Sources. We may also receive information about you from other sources. For example, organizational administrators may provide information about authorized users within their organization, including names, titles, roles, email addresses, and phone numbers.

II. USE OF INFORMATION

II. I. We use the information we collect about you to:

(a) to operate, maintain, and improve our products and services;

(b) to process and manage transactions and account-related activities;

(c) to send technical notices, account verification codes, safety alerts, and administrative messages, and to respond to your comments, questions, and support requests;

(d) to communicate with you about products, services, events, and other information that may be of interest to you;

(e) to personalize and enhance your experience with the Services, including by presenting content or features that may be relevant to you;

(f) to monitor, analyze, and understand usage patterns and trends in connection with the Services;

(g) to detect, investigate, and prevent security incidents, fraudulent activity, and other harmful or illegal conduct; to comply with applicable laws; and to protect the rights, property, and safety of Closure AI, our users, and the public; and

(h) to fulfill any other purpose described to you at the time the information was collected.

III. SHARING OF INFORMATION

III.I. We share information about you in the following circumstances:

(a) with service providers that perform services on our behalf, such as payment processing, web hosting, customer relationship management, email delivery, analytics, and support services;

(b) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;

(c) if we believe your actions are inconsistent with our user agreements or policies, or if necessary to protect the rights, property, or safety of Closure AI, our users, or the public;

(d) in connection with, or during negotiations of, any merger, sale of company assets, financing, divestiture, reorganization, or acquisition of all or a portion of our business by another company;

(e) with our current and future parent companies, affiliates, subsidiaries, and other entities under common ownership or control;

(f) with your consent or at your direction; and

(g) with the organization through which you access the Services, such as a victim services agency, nonprofit, law enforcement agency, or other subscribing entity, to the extent necessary to provide the Services and consistent with your permissions and account settings.

We may also share aggregated or de-identified information with third parties, provided that such information cannot reasonably be used to identify you.

III.II. Your Choices. (a) You may update the account information you provide to us by logging into your online account; (b) you may opt out of receiving promotional emails from us by following the instructions in those emails, though we may still send you non-promotional communications such as messages about your account or our ongoing business relationship; and (c) most web browsers are set to accept cookies by default, but you may choose to remove or reject browser cookies through your browser settings, noting that removing or rejecting cookies may affect the availability or functionality of certain features of the Services.

IV. INFORMATION FOR CALIFORNIA RESIDENTS

This section provides additional details about the personal information we collect about California residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”). In the last twelve months, we collected the following categories of personal information: identifiers such as name, contact information, and device identifiers; commercial information such as subscriptions purchased; professional or employment-related information such as company name and title; and internet or other electronic network activity information such as browsing behavior. For more details about the personal information we collect, including the categories of sources, please see the “Collection of Information” section above. We collect this information for the business and commercial purposes described in the “Use of Information” section above, and we share this information with the categories of third parties described in the “Sharing of Information” section above. We do not sell the personal information we collect, and we will not sell it in the future without providing a right to opt out.

Subject to certain limitations, the CCPA provides California residents with the right to request additional details about the categories and specific pieces of personal information we collect, to request deletion of their personal information, to opt out of any sales that may occur, and to not be discriminated against for exercising these rights. California residents may make a rights request by emailing us at hello@foundclosure.ai. While we may not meet the operational thresholds required to be subject to the CCPA, we will generally seek to honor the rights requests we receive.

V. SECURITY

We implement a variety of technical and organizational measures designed to protect information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest; multi-factor authentication and single sign-on options for certain users; six-digit PIN codes and biometric authentication features for eligible devices; camouflage functionality within the survivor mobile application; access controls; role-based permissions; and infrastructure designed to support multi-tenant isolation. The specific security controls available to you may vary based on your organization’s configuration, your device capabilities, and your method of accessing the Services. While we maintain these safeguards, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

VI. CHILDREN’S PRIVACY

The Services are intended for individuals 18 years of age or older. We do not knowingly collect personal information from children, and the Services are not directed to children. If we become aware that we have collected personal information from a child, we will take appropriate steps to delete that information promptly.

CONTACT US

If you have any questions about this Privacy Policy, please contact us using our contact form at www.foundclosure.ai/contact.