We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
1. WHO WE ARE
FROME Inc., 144 BAY TERR, STATEN ISLAND NY 10306
3. INFORMATION WE COLLECT
We cannot help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, as well as information from third parties, like when you access our services through a social media account. Here is some additional information about that:
Information you give us
You choose to give us certain information when using our services. This includes:
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
You may be able to use your social media login (such as Facebook Login) to create and log into your FROME account to make one less user name and password to remember, and allows you to share some information from your social media account with us.
We may receive info about you from our partners, for instance where FROME ads are published on a partner’s websites and platforms.
Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
We collect information from and about the device(s) you use to access our services, including:
Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. However, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).
4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including FROME, do not currently respond to DNT signals.
5. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Below is a detailed explanation of how we use your information, her with practical examples.
To administer your account and provide our services to you
To help you connect with other users
To ensure a consistent experience across your devices
To provide new FROME services to you
To serve you relevant offers and ads
To improve our services and develop new ones
To prevent, detect, and fight fraud or other illegal or unauthorized activities
To ensure legal compliance
To process your information as described above, we rely on the following legal bases:
6. HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, and in some cases, legal authorities. Read on for more details about how your information is shared with others.
With other users
You share information with other users (and in the case of any sharing features available on FROME, the individuals or apps with whom a FROME user may choose to share you with) when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you are comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.
If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your chosen settings.
With our service providers and partners
As noted herein, we use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
All of our service providers and partners must agree to strict confidentiality obligations.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law
We may disclose your information if reasonably necessary: (a) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (b) to assist in the prevention or detection of crime (subject in each case to applicable law); or (c) to protect the safety of any person.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
7. YOUR RIGHTS
You have the following tools available to you to protect your own rights:
We want you to be aware of your privacy rights. Here are a few key points to remember:
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
We reserve the right to reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
8. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here.
9. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
10. CHILDREN’S PRIVACY
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
As we are always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. Any material updates to this policy will be preceded by a notification to you, the user, before implementation.
12. HOW TO CONTACT US
If you live in the United States:
FIRST ROUND IS ON ME LLC.,
144 BAY TERR
Staten Island NY, 10306