Privacy Policy

Frankly Co. Privacy Policy

Last Updated: April 8, 2015

Protecting your privacy is really important to us. Accordingly, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive when you use our website located at www.franklyinc.com (“Site”) and instant messaging and social networking services for professionals, accessible via our mobile device application (“App”). To make the terms in this Privacy Policy easier to read, our Site, services and App are collectively called the Services. This Privacy Policy applies only to those websites, services and applications included within “Services” and doesn’t apply to any third-party websites, services or applications, even if they are accessible through our Services.

How do we collect and use information?

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account (defined below), if you are an Account holder), and to enable you to enjoy and easily navigate our Services.

ACCOUNT INFORMATION

To use the Services you’ll have to create an account (“Account”). When you create an Account we’ll collect certain information that can be used to identify you, such as your name, email address, and phone number (“Personally Identifiable Information” or “PII”). We may also collect certain information that is not PII because it cannot be used by itself to identify you, such as your interests and organization. You can create an Account via the App or through your account with certain third-party social networking services such as Facebook (each, an “SNS Account”), if and when such functionality is available. If you choose to create an Account through one of your SNS Accounts, you may have to provide us with your username (or userID) so that your identity can be authenticated by the SNS Account. When the authentication is complete, we’ll be able to link your Account with the SNS Account and access certain PII, such as your name and email address, and other PII that your privacy settings on the SNS Account permit us to access, in connection with creating your Account. We don’t receive or store passwords for any of your SNS Accounts.

We may use your PII (e.g., email address) to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the Opt-Out procedure described in this policy below.

In addition, our Services may request access to your contacts in order to populate your list of contacts that also use the Service and enable you to invite more friends to join. We do not collect this information unless you authorize it via the Services. We do not store or use your contacts for any purpose other than administering the Services for you.

INFORMATION COLLECTED USING COOKIES

We collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by any third party service providers (including third-party advertisers) that we may engage.

INFORMATION RELATED TO USE OF THE SERVICES

Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the pages or features of our Services to which a User browsed and the time spent on those pages or features, frequency with which the Services are used by a User, search terms, the links on our Services that a User clicked on, and other statistics. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.

LOCATION INFORMATION

When you use our App we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation and utilizing your mobile phone number to approximate rough geolocation information (based on area code). We may use location information to improve and personalize our Services for you and to enable chat functions with those in your approximate geolocation as described below under “Discover Other Account Holders”.

What Information Do We Share With Third Parties?

We will not share any PII that we have collected from you except as described below:

INFORMATION SHARED WITH OTHER ACCOUNT HOLDERS

As part of our Services, Account holders may communicate with other Account holders through the use of our direct messaging functionality and when this happens your identity may, if you choose, be available to those other Account holders. In addition, the content of your communications will be visible and available to those other Account holders. By default, our Service scrambles messages until you decide to read them and then deletes the messages (unless the sender selects an option to retain the message). We encourage you to use your good judgment for such communications and not post any private or sensitive information. Other information about you, such as your name or PIN may be viewable by other Account holders and users of the Service – this will depend on how you set your privacy settings via the Service.

DISCOVER OTHER ACCOUNT HOLDERS

You may be asked via the App if you would like to discover, chat and/or connect with other Account holders who may be unknown to you – either (i) in reasonably close proximity to you, (ii) in the country which is associated with your account and your telephone number or (iii) elsewhere in the world. If you indicate to us that you would like to discover, chat and/or connect with other Account holders by an affirmative action (e.g. selecting a “Yes I would like to connect with other users” button), then your name and Account profile image will be made available via that feature of the App to other Account holders and other Account holders may communicate with you via the App.

You may also decide that you want to join a conversation with other Account holders who share similar interests to yours – via the Frankly group features and functionality. If you decide to join a Frankly group, then your name and Account profile image will be made available to other members of that Frankly group and you will be able to communicate with other members of the group.

As noted above, when you communicate with other Account holders via the App, the content of your communications will be visible and available to those other Account holders, so we encourage you to use your good judgment for such communications and not post any private or sensitive information.

INFORMATION SHARED WITH OUR SERVICES PROVIDERS

We may engage third party service providers to work with us to administer and provide the Services. These third-party services providers have access to your PII only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your PII for any other purpose.

INFORMATION SHARED WITH THIRD PARTIES

We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes.

INFORMATION DISCLOSED IN CONNECTION WITH BUSINESS TRANSACTIONS

Information that we collect from our users, including PII, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your PII may be disclosed or transferred to the third-party acquirer in connection with the transaction.

INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS

It is our policy to protect you from having your privacy violated through abuse of the legal systems, whether by individuals, entities or government, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary: (i) to satisfy or comply with any applicable law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders; (ii) to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and (iii) to prevent or stop activity we consider to be illegal or unethical.

INFORMATION WE DISCLOSE WITH YOUR CONSENT OR AT YOUR REQUEST

We will share your PII with third-party sites or platforms, such as social networking sites, if you have expressly requested that we do so.

The Security of Your Information

We take reasonable measures to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Links to Other Sites

Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information we recommend that you carefully review the privacy policies of other websites and services that you access.

Messaging Via Your Account

As noted above, as part of our Services, Account holders may communicate with other Account holders through the use of our direct messaging functionality. If you choose to link your Account with an SNS Account we may, at your option, and depending on our ability to access your SNS Account, access your personal contacts on such SNS Account in order to create a list of potential contacts through our App. As an Account holder, you will be able to message other Account holders individually as well as engage in group chats with multiple Account holders, and may do so anonymously if you choose. For anonymous chats, the transcript of the chat can’t be saved or shared and although chat participants will know the names and identities of the other chat participants, nobody will be able to associate a particular statement with a particular chat participant. In addition to sending and receiving text messages, you will also be able to send and receive media files via our Services’ functionality. Through the App, Account holders can also invite non-Account holders and non-App users to try the Services. When an Account holder invites someone to try the Services, the Account holder may send an SMS or have an automated email sent to the invitee indicating that a particular Account holder has invited such invitee to try the Services and this SMS or email will include a link to the appropriate app store or distribution platform where the App is made available.

Modifying Your Information

You can access and modify the PII about you associated with your Account through the profile page in your Account. If you want us to delete your PII and your Account, please contact us at help@franklyinc.com with your request. We’ll take steps to delete your information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Opting Out

If you do not wish to receive promotional emails, newsletter notifications, or other communications from us, please follow the unsubscribe instructions provided in any of the communications. If you no longer want to be included in a Frankly group or the “Discover Other Account Holders” features of our Services, you can opt-out via the App or by sending an email to us at help@franklyinc.com and we will use commercially reasonable efforts to disable these features as soon as possible.

International Transfer

Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there. Your consent to this Privacy Policy followed by your submission of any PII represents your agreement to that transfer.

Our Policy Toward Children

Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13 we will take steps to delete such information from our files as soon as possible.

Changes to Privacy Policy

Any information that we collect is subject to the privacy policy in effect at the time such information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of such changes by posting them on the Services or by sending you an email or other notification, and we’ll indicate when such changes will become effective.

Questions?

Please contact us at help@franklyinc.com if you have any questions about our Privacy Policy.

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