Privacy Policy

Effective February 21, 2020

 

Welcome to Fabric!

This Privacy Policy (“Policy”) describes how we collect, process, and share your Personal Data. We also describe Users' rights and choices with respect to your Personal Data and other important information. Please read this Policy carefully and contact us with any questions at privacy@sparkfabric.com.

Key Points

  • Fabric is a public, interactive platform, and your messages will be made publicly available to other Users near you for a period of time.

  • We value authentic conversations and interactions, and when your message is public, your real name, or the name you provide, and location will be publicly available to other Users near you for a period of time. 

  • We may use any Personal Data we collect from you to improve our services, personalize the service, and to help you discover and view more relevant content. 

  • You have rights and choices with respect to how we collect and use your Personal Data.

  • You can contact us at any time if you have questions.

Navigation

Who We Are

Scope of the Policy

About our Service

Processing of Personal Data

Personal Data we Process

How we Collect Personal Data

How we Process Personal Data

Purposes of Processing

Data Sharing

Users’ Rights and Choices

Users’ Rights

Users’ Choices

Information Security

Data Retention

Use of Service by Minors

International Transfers

Changes to Our Policy

Contact Us

Who We Are

This is the Policy of Fabric Global PBC, D/B/A Fabric. (“Fabric PBC,” "Fabric," “us,” “our,” or “we”), a California corporation with offices at 177 E. Colorado Blvd, Floor 2, Pasadena, CA 91105. You can contact us here.

Scope of the Policy

This Policy applies to our website at sparkfabric.com and other sites that link to/post this Policy, (including any subdomains or mobile versions the “Site(s)”) and the Fabric mobile application (the “App” and together with the Site, the “Service”).

This Policy applies only to the Personal Data we process. This Policy does not apply to other Users, or their use of any Personal Data you make available through the Service. This Policy also does not apply to information processed by other third parties, for example, when you visit a third-party website or interact with a third-party service. We encourage you to review any third party’s privacy policy before disclosing information to them, and to be cautious with what content you choose to make available in your messages or available to the public.

This Policy is incorporated into the Terms of Use governing your use of our Service. Any capitalized terms not defined in this Policy will have the definitions provided in our Terms of Use.

Your use of our Service indicates your acknowledgement of the practices described in this Policy.

About our Service

Fabric allows you to engage with the world in real-time using augmented reality. Users of Fabric (“Users”) can start and join conversations with other Users that are near certain points of interest (“POIs”). Through the Service, Users can post public messages (“Fabric Messages”) visible to other Users near the POIs for a period of time, and those Users can view, interact with, post Fabric Messages responding to the post during that time.

Processing of Personal Data

Personal Data we Process

We may process the following categories of data that relates to identified or identifiable individuals (“Personal Data”) (note, specific Personal Data elements listed in each category are only examples and may change):

Identity Data: Personal Data relating to an individual’s identity or representing that individual, such as your name, photo/avatar, username, unique ID, etc.

Contact Data: **Personal Data used to contact an individual, e.g. email address(es) or phone number(s).

Device/Network Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.

Location Data: Personal Data relating to your precise location, such as information collected from your device’s GPS, Wi-Fi network, cell towers, or other precise localization or augmented reality system active on your device.

Inference Data: Personal Data inferred about personal characteristics and preferences, such as demographics, interests, behavioral patterns, psychological trends, predispositions, or behavior.

User Content: Any Personal Data contained in a text box or other free-text field, such as when you email or contact us, including any content of a Fabric Message.

How we Collect Personal Data

The Personal Data we process under this policy comes from a variety of sources, that vary depending on the nature of processing and available technologies:

Data you provide to us: You may provide us with Personal Data directly, for example, when you provide your information and register for an account.

Data we create or infer: We (or third parties operating on our behalf) create and infer Personal Data (such as Inference Data or Aggregate Data) based on our observations or analysis of other Personal Data we process, and we may correlate this data with other data we process about you.

Data collected automatically: We (or third parties operating on our behalf) may collect certain Personal Data automatically, for example, Device/Network Data is typically collected automatically through the use of cookies and similar technologies used on our Site.

Data we receive from others: We may receive Personal Data from third parties with whom we have a relationship. For example, we may receive the Personal Data we process from our third-party service providers.

How we Process Personal Data

We generally process your Personal Data in connection with the following activities and purposes, as well as for the general processing purposes described below.

User Account Registration

We generally collect and process Identity Data, Device/Network Data, and Contact Data when Users register and create an account on our Service. We generally use this as necessary to create, maintain, and provide your account and the service/features you request. We may also use your Contact Data as necessary to contact you with important information about your account or our Service.

Using the App and Service

We generally process Identity Data, Contact Data, Device/Network Data, and Inference Data when you use our Service, and we may also process Location Data if you enable location services. We generally use this as necessary to create, maintain, and provide your account and the service/features you request. We also process Location Data, Inference Data, and Device/Network Data in order to locate POIs in your area, determine your proximity to POIs, and to find and alert you to nearby POIs or POIs or Fabric Messages that may be of interest to you. Note, Location Data may be required in order for you to use certain aspects of the service (learn more).

Messages & Replies

We generally process Identity Data, Contact Data, Device/Network Data, Inference Data, Location Data and User Content you include when you post a Fabric Message, or comment on or reply to a Fabric Message.

When you post a Fabric Message, your first name and last initial and your Fabric Message will be made available to all Users of the Service that are within a certain distance of a POI. Each Fabric Message is associated with the Location Data of the User posting the Fabric Message by the Service, but the Location Data is not made public. The Location Data we collect and associate with a post will update based with the User’s location, and may be updated periodically or in real time depending on the nature of the POI, configuration of the Service, and your choices. The Fabric Message will be publicly available to Users in the general vicinity of a POI for a limited period of time. After that time expires, the Fabric Message will no longer be available to Users in the active area. You may also remove Fabric Messages that you no longer wish to be publicly available.

When you reply to a Fabric Message, your first name and last initial and your comment/reply will be publicly available to any User that accesses the original Fabric Message. You may delete a comment, and if a Fabric Message is a deleted, your comment may also be deleted, or made unavailable.

For all Fabric Messages and comments/replies, we may collect log data, such as Device/Network Data and other metadata, such as your IP address, device identifiers, time stamps, etc., and we may use that to provide the services, create analytics, and for other purposes set forth below.

Note, we cannot prevent Users from storing screenshots, videos, or other copies of your Fabric Messages, comments, or replies. Any Fabric Message, comment, or reply you post may available to the public or made available outside the Service.

Communications

You may contact us through our Site, or sign up for certain communications from us. In each case, we generally collect Contact Data, and any Identity Data or User Content that you provide in the registration form. This information is primarily used to respond to your request, but where you consent, or if relevant to your request and permitted by law, we may send you marketing communications as described further below.

Cookies and Similar Technologies

When you use the Service you may interact with cookies and similar technologies that we operate on or allow access to our Service. We, and certain third parties, may automatically collect and process Device/Network Data and Inference Data when you interact with these cookies and similar technologies. In cases where these cookies and similar technologies are controlled by third parties, we may receive this data from third parties to the extent allowed by the applicable service provider or partner. Please note, some of these technologies can be used by third parties to identify you across platforms, devices, websites, and services. The privacy policies of third parties may apply to these third-party technologies and their own use of any Personal Data they collect.

Subject to Users' rights and choices, we use this data as follows:

  • for “essential” or “functional” purposes, such as to enable various features of the Service such as remembering passwords, or staying logged in during your session;

  • for “analytics” purposes, consistent with our legitimate interests in understanding how the Service is used or performs, how Users engage with and navigate through the Service, in providing and improving the user experience and efficiency of our Service, understanding information about the devices and demographics of visitors to our Service, what sites refer visitors to our Service, and how often they visit our Service, and other similar purposes; and

  • for “retargeting” or similar advertising purposes on our Service, so that you can see advertisements from us on other websites. These technologies and the data they collect, may be used by advertisers to deliver ads that are more relevant to you based on content you have viewed, including content on our Service. These tracking technologies may also help prevent you from seeing the same advertisements too many times, and help us understand whether you have interacted with or viewed ads we’ve delivered to you. This collection and ad targeting may take place both on our Service, as well as on third-party websites that participate in the ad network (e.g. any advertisements delivered by that ad network on a third-party website).

Purposes of Processing

We process Personal Data for numerous purposes in connection with our business, for example we process your

 

Personal Data:

  • To provide, improve, and secure our products and services

  • To fulfill our contractual obligations to you

  • For customer service and workforce training/development

  • To personalize the Service and make it more relevant to you

  • To enable the delivery of targeted marketing or other offers and promotional content to you

  • To comply with the law, and in the public interest

 

Please see below for more information regarding the purposes for which we process your Personal Data.

 

Service Provision and Contractual Obligations

We process any Personal Data as is necessary to provide the Service, authenticate Users and their rights to access the Service, and as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request.

Internal Processes and Service Improvement

We may use any Personal Data we process through our Service as necessary in connection with our legitimate business interests in improving the design of our Service, understanding how are Services are used or function, for customer service purposes, in connection with logs and metadata relating to service use, and for ensuring the security and stability of the Service. Additionally, we may use Personal Data to understand what parts of our Service are most relevant to Users, how Users interact with various aspects of our Service, how our Service performs or fails to perform, etc., or we may analyze use of the Service to determine if there are specific activities that might indicate an information security risk to the Service or our Users. This processing is subject to Users' rights and choices applicable to processing performed in accordance with our legitimate business interests.

Aggregate Analytics

We process Personal Data (including Location Data in pseudonymized or de-identified form) as necessary in connection with our legitimate business interests in creating aggregate analytics about how our Service is used and performs, to understand which aspects of our products and Service are most relevant to Users, and to create other reports regarding the use of our Service, demographics of our Users, user interactions with Fabric Messages and POIs, and other similar information and metrics (“Aggregate Data”). The resulting aggregate data will not contain information from which an individual may be readily identified. This processing is subject to Users' rights and choices applicable to processing performed in accordance with our legitimate business interests.

Personalization

We process Personal Data as necessary in connection with our legitimate business interest in personalizing the Service. For example, the Service may be customized to you so that it displays your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Service and other content. This processing is subject to Users' rights and choices applicable to processing performed in accordance with our legitimate business interests.

Marketing Communications

We use Personal Data as necessary to provide marketing communications, and consistent with our legitimate business interests, we may send you marketing and promotional communications if you sign up for such communications or purchase Service from us. We may also process Device/Network Data and Contact Data when you interact with our communications in connection with our legitimate business interest in understanding communication response and open rates.

 

Advertising and Partners

With your consent or where otherwise permitted by law, we may create or receive Inference Data, combine that with other Personal Data we hold about you, and use it to deliver messages or information to Users from third party partners that are interested in communicating relevant information to categories of Users through our Service. For example, we may use your Personal Data to deliver a sponsored post to you when a third party wants to reach Users like you in connection with an offer or promotion, or an event targeted to Users with certain interests. Third parties may have their own privacy policy that applies to any information you provide them. We may provide Aggregated Analytics to these third parties, as well as certain Aggregated Data other information in pseudonymized or de-identified form such that it does not identify you. This processing is subject to Users' rights and choices applicable to processing performed in accordance with our legitimate business interests.

 

For purposes of the California Consumer Privacy Act (Cal. Civil Code § 1798.101 et seq), we do not “sell” your Personal Data.

Compliance, Health, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Data subject to the Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.'

Other Processing of Personal Data

If we process Personal Data in connection with our Service in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to Users' rights and choices) unless otherwise stated when you provide it.

Data Sharing

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally share Personal Data with the following categories of recipients:

Public Messages: When you post a Fabric Message, your first name and last initial, Location Data, and any User Content in your Fabric Message will be made available to other Users of the Service. Depending on your use of location services, you may also share Location Data from your current location, or the location where you posted a Fabric Message.

 

Business Purposes: In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests or other business purposes, we may share your Personal Data with service providers or subprocessors who provide certain Service or process data on our behalf. For example, we may use cloud-based hosting providers to host our Service or may disclose information as part of our own internal operations, such as security operations, internal research, etc.) When we disclose information for business purposes we may disclose Identity Data, Contact Data, Device/Network Data, Inference Data, Location Data and User Content.

 

Affiliates: We may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies, for example, in order to streamline certain business operations, develop products and services that better meet the interests and needs of our customers, or to improve the quality and delivery of our Service.

 

Successors: Your Personal Data may be shared if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Lawful Recipients: In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person, or in such other circumstances as may be required or permitted by law. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Users’ Rights and Choices

Users’ Rights

To the extent required under applicable law, and subject to our rights to limit or deny access/disclosure under applicable law, you may have the following rights in your Personal Data. You may exercise your rights by contacting us at privacy@sparkfabric.com. All rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you log in to your account, or verify that you have access to your account or the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

You generally have the following rights in your Personal Data:

Access: You may receive a list of your Personal Data that we process, and a list of the third parties (or categories of third parties) with whom we have shared data, to the extent required and permitted by law. You may be able to access much of the Personal Data we hold about you directly using the account settings menu.

 

Rectification: You may correct any Personal Data that we hold about you to the extent required and permitted by law. You may be able to make changes to much of the information you provided to us using the account settings menu.

 

Deletion: To the extent required by applicable law, you may request that we delete your Personal Data from our systems.

 

Data Export: To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.

 

Regulator Contact: You may have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

California Rights: Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. Upon receipt of a verifiable request, you may also request that we provide you a copy of your Personal Data, direct us to stop selling or disclosing Personal Data for certain purposes (if we have done so), and receive information regarding: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties with whom we have disclosed your Personal Data, or sold, or disclosed it for a business purpose (if any); and (5) the specific pieces of Personal Data we have collected about you. You have the right not to be discriminated against in connection with the exercise of rights under the CCPA. See below for more information regarding your right to know how we process certain categories of Personal Data.

 

Restriction: You may have the right to request that we limit or cease processing data in certain cases, for example, the right of restriction may apply when data is being reviewed for accuracy, the processing is unlawful, no longer used, or you have objected to the processing.

 

Note: We may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity.

 

Users’ Choices

It is possible for you to use portions of our Service without providing any Personal Data, but you may not be able to access certain features or view certain content. To the extent required under applicable law, and subject to our rights under applicable law, you may have the following choices regarding the Personal Data we process.

Location Data: Location Data is required for certain aspects of the Service, including to post and view Fabric Messages and to locate POIs. You may disable our use of location services through the settings menu of your application. If you choose to disable location services, you may be unable to use aspects of the Service.

Consent: If you consent to processing, you may withdraw your consent at any time, to the extent required by law.

Notifications If you do not want to receive push notifications from us, you can change your notification preferences using your operating system’s notification setting functionality. To disable location services that may affect the notifications you receive, see above.

Direct Marketing: **You have the choice to opt-out of or withdraw your consent to processing related to direct marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing using the information below. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Objection: **You may have the right under applicable law to object to our processing of your Personal Data that we undertake without your consent as in connection with our legitimate business interests. You may do so by contacting us re: data rights requests. Note that we may not be required to cease, or limit processing based solely on that objection, and we may continue processing cases where our interests in processing are balanced against individuals’ privacy interests.

Automated decisions: To the extent we process Personal Data using automated means where such processing has legal or similarly significant effects (if any), or where otherwise required by law, you may opt-out of, or revoke your consent, to this processing or elect to have an individual review any of the results of processing.

Cookies & Similar Tech: If you do not want information collected using cookies and similar technologies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu, or any menus we may make available to you. You must opt out of third-party Service directly via the third party. For example, to learn more about or opt-out of Google’s analytics Service, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out. Please note, currently our Service does not respond to your browser’s do-not-track request.

Information Security

We implement and maintain reasonable security measures to safeguard the Personal Data we process. However, we sometimes share Personal Data with, or process data on behalf of third parties, as noted above. While we may require our service providers to follow certain security practices, we do not have control over and will not be liable for third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.

Data Retention

Generally, we retain Personal Data for the periods stated above, or if none, for so long as it remains relevant to its purpose or for so long as is required by law (if longer). Note, when a Fabric Message is removed from public view after the set time period, that Fabric Message is not deleted, and may be retained before it is set for permanent deletion in accordance with our data retention policies. We will review retention periods periodically, and if appropriate, we may de-identify or anonymize data held for longer periods.

Use of Service by Minors

Our Service is neither directed at nor intended for direct use by individuals under the age of 16. Do not access or use the Service if you are not of the age of majority in your jurisdiction.

International Transfers

We operate and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. may not provide the same legal protections of Personal Data as your home country. If you are a resident of the European Union, your Personal Data may be transferred to the U.S. pursuant to the E.U.-U.S. Privacy Shield Framework, the Standard Contractual Clauses, or other adequacy mechanisms, or pursuant to exemptions provided under EU law. Contact us or review any supplemental notices to determine which method we use to transfer your information in specific circumstances.

Changes to Our Policy

We may change this Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your acknowledgement of these changes, or use of the Service following notice of any changes (as applicable) indicates your acceptance of any changes.

Contact Us

Feel free to contact us with questions or concerns using the appropriate address below.

General inquires: privacy@sparkfabric.com

Physical address:

Fabric Global, PBC

D/B/A Fabric Global

177 E. Colorado Blvd, Floor 2

Pasadena, CA 91105

 

CCPA Right to Know Disclosure

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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