SMALL FOOTPRINT MEDIA LLC (“SFM”)

PRIVACY POLICY

Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our User Content and Services, and your choices about the collection and use of your information. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

If you have any questions about this Privacy Policy or the Service, please contact us at any time at info@smallfootprintmedia.com.

For the purposes of EU data protection laws (“Data Protection Legislation”), SFM is the data controller (i.e. the company which is responsible for, and controls the processing of, your personal data).

LEGAL PRIVACY POLICY

What Information We Collect From You:

We ask for certain information such as your username, first and last name, phone number, email address and physical address when you register for an account or if you correspond with us. We may also retain any messages you send us and may collect User Content you upload to us.

We may receive information about you from third parties. This information could include, but is not limited to, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service.

How Do We Use the Information We Collect:

We use this information to operate, maintain, and provide to you the features and functionality of Services, as well as to communicate directly with you, such as to send you email messages and push notifications and to permit you to share content with others on the Service.

Legal basis for processing in the EU:

In the EU, the purposes for which we process your personal data are:

1. Where we need to perform the contract we are about to enter into or have entered into with you for the Service;
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
3. Where we need to comply with a legal or regulatory obligation in the EU.

Here are all of the ways we plan to use your personal data, contact information and basic personal details such as your first name, last name, phone number, and email address.

• We use this information to operate, maintain and provide to you the features of Services.
• We use this information to communicate with you, including sending Service-related communications (such as invoices and information about updates to the Service, and any news, alerts and marketing communications (in line with your settings and options)).
• We use this information to deal with enquiries and complaints made by or about you relating to the Service.
• Profile and account information such as your unique name, username, password, any additional information that you share with us such as your user biography, content such as photos and contacts names, contacts’ user ID’s and your connection to those ID’s, connection to those contacts.
• We use this information to operate, maintain and provide to you the features of the Service (such as to create your profile/account)

Here are all of the ways we plan to use your payment and transaction information including payment information (such as your credit or debit card details or your bank account details), and time, date and value of transactions.

• We use this information to facilitate transactions and provide you with the Service.
• We use this information to provide customer support.
• We use this information to detect and prevent fraud.
• We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to communicate with you, to monitor and improve our Service and business, and to help us develop new products and services.

Please contact us using the details above if you need information about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.

Use of Cookies and Other Technology to Collect Information:

We, and our third party partners, automatically collect certain types of usage information when you visit our website or use our Service, read our emails, or otherwise engage with us. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. When you access our Service by or through a mobile device, we may receive or collect and store a unique identification number associated with your device (“Device ID”), mobile carrier, device type and manufacturer, phone number, and location data (e.g., city and state) of your mobile device. We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; (f) otherwise to plan for and enhance our Service; and (g) automatically update the SFM application on your mobile devices.

Sharing of Your Information:

Our Service allows you to share information about yourself with other individuals. By using the Service, you consent to have your information displayed to other members of the Service. Consider your own privacy and personal safety when logging in to our Service and sharing your information with anyone. SFM never shares your name, phone number, email address or physical address with other users on the Service without your consent.

We may also share your personal information with third parties who we require to operate, maintain and provide the features and functionalities of Service. Examples of these necessary third parties include:

• Other companies owned by or under common ownership as SFM, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns;
• Third party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us which may include providing payment, mailing or email services, tax and accounting services, data enhancement services, fraud prevention services, web hosting, and/or analytic services, email server services (to send messages to users), product development services and identity verification services;
• Third parties with whom we partner;
• The public and other members of the Service at your request. Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public. Copies of User Content posted to the Service may remain viewable in cached and archived pages of the Service or if other Users have copied or saved that information; and

When we grant these necessary third parties access to your personal information, we require that they use your personal information solely in accordance with the rights granted to us and restrictions placed on us in this Privacy Policy.

We may also share your information with other parties in connection with any company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

We may also share your information with third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of SFM, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

How We Store and Process Your Information:

Your information collected through the Service may be stored and processed in the United States or any other country in which SFM or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards.

How We Protect Your Information:

SFM cares about the security of your information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from SFM, at all times. However, SFM cannot ensure or warrant the security of any information you transmit to SFM or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. SFM is not responsible for the functionality or security measures of any third party. In the event that any information under our control is compromised as a result of a breach of security, SFM will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Your Choices About Your Information:

We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails.

You may update your account information at any time by logging into your account and changing your settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at info@smallfootprintmedia.com.

The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, located at http://www.networkadvertising.org ). Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents SFM or its business partners from tracking your browser’s activities in relation to the Service. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at info@smallfootprintmedia.com.

Your rights in respect of your personal information if you are resident in the EU and Switzerland:

If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

a) Right of access. The right to obtain access to your personal data.
b) Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
c) Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
e) Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
f) Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
g) Right to withdraw consent. You should be aware that you are entitled to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.

If you wish to exercise one of these rights, please contact us at info@smallfootprintmedia.com.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

How Long Does SFM Keep Information About Me:

Following termination or deactivation of your User account SFM may retain your profile information and User Content.

For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under “WHAT INFORMATION DO WE COLLECT FROM YOU?”), except if required otherwise by law

“Do Not Track Signals”:

Although we do our best to honor the privacy preferences of our customers, we are not able to respond to Do-Not-Track signals from your browser at this time. As discussed above, we track website usage information through the use of cookies for analytic and internal purposes only. Because we do not collect this information to track you across websites over time, your selection of the “Do Not Track” option provided by your browser will not have any effect on our collection of cookie information for analytics or internal purposes.

Children’s Privacy:

SFM does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at info@smallfootprintmedia.com.

Links to Other Web Sites and Services:

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not have any control over any third-parties that you authorize to access your User Content. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

Changes to our Privacy Policy:

SFM may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the ‘last modified’ date at the bottom of this page.

This Privacy Policy was last modified on March 1, 2021.