FASELIS, INC.

PRIVACY POLICY

REVISED DATE: June 1, 2019

1. INTRODUCTION

PURPOSE OF POLICY.
Faselis, Inc. (“Faselis,” “we,” “us,” “our,” or “Company”) is committed to respecting the privacy of the information collected from its customers, visitors, and other users (“you” or “your”) of the Faselis cloud-based media relations management platform, which includes our mobile applications, website, and social networking pages (the “Site”) and various features, products, and services available via the Site and or in connection with our platform (the “Services”). The Site and Services are collectively referred to as the “Faselis PR Platform”. We created this Privacy Policy (this “Policy”) to explain how we collect, use, disclose, and safeguard your information when you use the Faselis PR Platform.

This Policy is only applicable to the Faselis PR Platform, and not to any other websites that you may be able to access from the Site or via the Services, each of which may have data collection and use practices and policies that differ materially from this Policy.

PLEASE READ THIS POLICY CAREFULLY.
We take the security and privacy of your personal information very seriously and only collect personally identifiable information that is Appropriate for you to use, interact and improve Faselis. If you do not agree with the terms of this Policy, please do not download the Site, access the Services, or otherwise use the Faselis PR Platform.

Dutch version of this Privacy Policy is only provied for conveniency purposes. Should there be a conflict between the Dutch version and the English version of this Privacy Policy, you hereby agree, understand and undertake that the English version of this Privacy Policy will prevail, and will be valid.

2. INFORMATION COLLECTION PRACTICES

WHAT BASIC INFORMATION DOES THE COMPANY COLLECT? We may collect information about you in a variety of ways. This Policy does not apply to the third party mobile application online stores from which you may download the Site. Such app stores may also collect and use information about you and you may be subject to their privacy policies. The information we may collect depends on your use of the Faselis PR Platform and includes, but is not limited to:
(a) PERSONAL INFORMATION. By using the Faselis PR Platform, we may collect contact details, demographic data, and other personally identifiable information (such as your name, phone number, email address, home address), depending on the information you agree to share with us.
(b) PUBLICATION INFORMATION. Faselis is a media database. We collect data about publications and journalists listed as part of our Services, including: name, email, phone number, job title, media connection, address; information users voluntarily provide via the Services; and analytical usage information collected by Google Analytics and other statistics services. We update this data by calling offices of the publications and asking them to provide the current information about the journalists. We do not make the publications’ and the journalists’ data public; it is only available to the users of our Service.
(c) PRESS RELEASES. Journalists receive press releases by email. They can organize their press release profiles to only receive certain categories of press releases (e.g. press releases only for Consumer Electronics industry) or to block certain brands and PR agencies. Faselis users can search and see the information even about journalists who blocked emails. Blocking Faselis does not delete journalist’s information from the Service.
(d) PAYMENT DETAILS. When you purchase, order, or request Services, we may collect data related to your payment method (e.g. card brand, expiration date). We do not, however, view or store your credit card information. This is managed by a third party payment processor. Please see our Sub-Processors List for more information, and see which third party providers we engage with to provide you the Faselis PR Platform.
(e) VOICE RECORDINGS. When we obtain journalist information over the phone, and ask for your freely given, specific, informed and unambiguous oral consent, we record such phone calls to demonstrate and prove that we obtained the journalist’s freely given, specific, informed and unambiguous consent.
WHAT ADDITIONAL INFORMATION (“OTHER INFORMATION”) DOES COMPANY COLLECT?
(a) AUTOMATIC COLLECTION. We may automatically collect the following information about your use of our Services: access time, device ID, Application ID or other unique identifier; domain name, IP address, language information; device name and model; operating system information; your activities within the Services; and the length of time that you are logged in.
(b) COOKIES. From time to time, we may use the standard “cookies” feature of major browser Applications that allows us to store a small piece of data on your device about your activity on our Site. We do not set any personally identifiable information in cookies, nor do we employ any data capture mechanisms on our website other than cookies. Cookies help us learn which areas of our site are useful and which areas need improvement. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this function, your experience with our Site may be diminished and some features may not work as they were intended.
(c) PUBLIC INFORMATION. Some information we collect is publicly available. For example, we may collect data about you from other entities. By gathering additional information about you, we can correct inaccurate information, enhance security of your transactions, and provide recommendations and special offers that may be of interest to you.

3. USE AND SHARING OF INFORMATION

WHAT DOES COMPANY DO WITH COLLECTED INFORMATION? Faselis relies on performance of a contract to provide you Faselis PR Platform while using your personal information. Faselis uses Other Information in furtherance of our legitimate interests in operating our Services, Sites and business. Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Below please see how we use the information we collect from you:
(a) PERSONAL INFORMATION. We will not share your personal information with any third parties without your consent, except as necessary to provide you with the Services or to comply with the law. We may use your personal information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site. We may also use your contact information to inform you of any changes to the Site, or to send you additional information about Company. If you give your permission, we may share your contact information with our business partners or other companies that we integrate with.
(b) ANONYMOUS INFORMATION. We use anonymous information to analyze our Site traffic, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.
(c) MARKETING. We may use your personal information to:
  • to provide you with information about other services, features we add to Faselis PR Platform that are similar to those that you have already purchased or enquired about;
  • to make suggestions and recommendations to you and other users of Faselis PR Platform about additional features or services that may interest you, which may be based on your activity on Faselis PR Platform.
  • to provide you updates about Faselis, and our success innovating Faselis PR Platform.

(d) SERVICE IMPROVEMENTS AND ACCOUNT MANAGEMENT. To manage and maintain the integrity of Faselis PR Platform we may use your personal information to:
  • to ensure that content from Faselis PR Platform is presented in the most effective manner for you and for your computer.
  • to administer Faselis PR Platform and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to notify you about changes to Faselis PR Platform and to send you service emails relating to your account;
  • as part of our efforts to keep Faselis PR Platform safe and secure; and to manage and operate your account with us.

(e) USE OF COOKIES. We may use cookies and other tracking technologies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our Site, or for other purposes. Promotions or advertisements displayed on our Site may contain cookies. Aggregate cookie and tracking information may be shared with third parties. Also, we may display certain advertising offers on our Site to allow service providers, advertisers, or other third parties to advertise on our Site. Most browsers are set up to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Faselis PR Platform.
(f) DISCLOSURE TO PROTECT LAWFUL INTERESTS. We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on Company or its parent company, subsidiaries or affiliates, (2) protect and defend the rights or property of Company or the users of the Site, or (3) act under exigent circumstances to protect the safety of the public or users of the Site.
(g) SALE OF INFORMATION. In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through this Site. If Company or substantially all of its assets are acquired; customer information will be one of the assets transferred to the acquirer.
(h) RETENTION PERIOD. We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as you are using Faselis PR Platform.

4. YOUR RIGHTS

(a) CORRECTING YOUR INFORMATION. The accuracy of your information is important to us. We are working on make it easier for you to review and correct the information we hold about you. If you change email address, or you think any of the other information we hold is inaccurate or out of date, please email us at: info@faselis.com.
(b) RIGHT TO PORTABILITY. You have the right to receive personal data you have provided to us in a structured, commonly used and machine readable format. You also have the right to request that we, as the controller, transmit this data directly to another controller. You may only exercise this right with respect to the personal data you have provided to us with your consent or for the performance of a contract. The right to data portability only applies to personal data. This means that it does not apply to genuinely anonymous data. If you wish to exercise your right to portability, free of charge, please contact us at info@faselis.com. We will respond to your request within 30 (thirty) days.
(c) ACCESS TO INFORMATION. You have the right to ask for a copy of the information we hold about you, free of charge, and we will respond to your request within 30 (thirty) days.
(d) MARKETING. You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by checking or unchecking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: info@faselis.com. Faselis PR Platform, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
(e) DELETION OF INFORMATION. If you believe children under 16 provided us information, without parent/guardian consent. You may request that we remove all information about you from our database by contacting us in accordance with Section 10 below, by contacting us at: info@faselis.com. Additionally, we are working on providing you a way of deleting the information we hold about you, if you no longer wish to use Faselis PR Platform. We will update this accordingly, and we will also notify you when we make a change to this policy. If you have any questions regarding how we are working on providing you a way to delete your information from our servers, please contact us at: info@faselis.com.
(f) RIGHT TO FILE A COMPLAINT. If you are residing in EU and/or Netherlands: If you have any concerns and/or complaints regarding our information privacy practices, please contact us at info@faselis.com, we will help resolving your question, concern or complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, after you contacted us, you have the right to file a complaint with Dutch Data Protection Authority: https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us
(g) For Republic of Turkey Customers. If you are a customer or user of ours (i.e. an Agency, Agency’s Users, Faselis LITE User, Corporate User using our Faselis PR Platform or a Journalist/Blogger receiving press releases and invitations from Faselis), you have certain rights under Law of Personal Data Protection No. 6698, you have the rights outlined below:
  • Right to be informed whether your personal information is processed;
  • If your personal information is processed, right to request information pertaining thereto;
  • Right to be informed about the purpose of processing personal information, and whether if your personal data is being processed according to that purpose;
  • Right to be informed whether your personal information is being shared with third parties internationally, and domestically;
  • If your personal information is processed wrong, or incomplete, the right to request correction;
  • If the lawful basis for processing your personal basis is terminated, the right to request deletion or destruction;
  • Right to request the deletion or destruction of personal information stated above to be relayed to the third parties;
  • Right to object to the negative results of analyzing of processed personal information exclusively with automated systems;
  • Right to demand damages, if suffered, arising out of the unlawful processing of the personal information according to Law No. 6698.
You may exercise your rights as outlined above, free of charge by contacting us at info@faselis.com. You may also control the information you share with us, from your Faselis Account at www.faselis.com page, by enabling or disabling sharing certain categories of information. If you would like to exercise your rights to deletion or destruction, you may do so by logging in to your Faselis Account, and through www.faselis.com portal to delete your information from our systems. If you chose to exercise your rights indicated above, by contacting us from info@faselis.com, we will respond to your request within 30 (thirty) days. Right to File a Complaint with Personal Information Institute. If your request to exercise the rights above are denied, our response found insufficient or not receiving a response within the time frame indicated above, you may file a complaint to Personal Information Institute, within 30 (thirty) days of receiving our response; and in any case within 60 (sixty) days from the date of receipt of your request by Faselis:

Kişisel Verileri Koruma Kurumu
Nasuh Akar Mahallesi 1407. Sok. No:4, 06520 Çankaya/Ankara
Tel: 0312 216 50 00
www.kvkk.gov.tr

5. TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE

Faselis’ servers are located in U.S. As part of the services offered to you through Faselis PR Platform, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our or third-party providers’ servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the EU. To see a full list of our third party sub-processors, please see our Sub-Processors List. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

6. IDENTIFYING THE DATA PROCESSOR AND DATA CONTROLLER

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, you are the controller of your data. In general, Faselis is the processor of your data. Different Faselis entities provide the Services in different parts of the world. Faselis B.V., a Dutch company based in Amsterdam, Netherlands, is the controller of information other than your personal information and a processor of your data relating to Agencies and other Users established for Customers outside of the U.S. Faselis, Inc., a US company based in San Francisco, California is the controller of information other than your personal information and a processor of your data relating to Agencies and other Users who use Services established for Agencies and other Users in the US.

7. DATA SECURITY

We have administrative, technical, and physical security measures in place to help prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration. Any information disclosed online can potentially be intercepted and used by unauthorized parties. Please see our Security Policy, for more detailed information on how we keep your information secure.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have information about your online browsing activities monitored or collected. Our Services do not track your browsing activities across third party websites and we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your preference not to be tracked online. No uniform technology standard for recognizing and implementing DNT signals has been finalized. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to DNT signals which may be sent from your computer, mobile device, or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will provide information about that practice in a revised version of this Policy.

9. THIRD PARTY SERVICES

The Site may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

10. NOTICE CONCERNING THE INFORMATION OF CHILDREN

Faselis is not directed to children. In connection with our Services, we do not knowingly solicit information from or market to children under the age of 16. Please contact us if your child has provided personal information to us and we will take reasonable measures to promptly delete the information from our records; however, please be aware that the information may not be completely or comprehensively removed from our databases, if it is kept in a deidentified manner and if we are not able to link that information to the individual.

11. CONTACT INFORMATION AND POLICY UPDATES


CONTACTING US. If you have any questions about this Policy, our practices related to this Site, or if you would like us to remove your information from our databases please feel free to contact us at:
info@faselis.com.
Faselis, Inc.
995 Market St, Floor 2,
San Francisco, CA 94103

UPDATES AND CHANGES. We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.