Privacy Policy

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Effective as of [January 2023]

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This Privacy Policy (the “Policy”) describes how Folloze, Inc. and its affiliated companies (“Folloze,” “we,” “us,” and “our”) collect, use, and disclose personal data, including of users of Folloze.com and any other websites owned by Folloze, and any other services we offer (together with our websites, the “Services”). This Policy also applies to personal data we collect about you offline, such as when you contact us by phone or communicate with us in person. Capitalized terms not defined in this Policy have the meanings given in our Terms of Service. 

Folloze provides various products, tools and services through our Services as part of our online platform that enables users to curate, organize and share information, documents, links, files and other digital content with other users within and outside of their organizations. This Policy does not apply to information we process as a data processor or service provider on behalf of our customers. Folloze does not control how customers use information Folloze processes on their behalf, and you should consult with the applicable customer to understand how they use information they receive from Folloze.

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By accessing or using the Services or otherwise providing us with information, you acknowledge the applicability of this Policy. If you do not agree to this Policy, please do not access or use the Services or provide us with information.

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1. What Information We Collect, How We Get It

We collect data about you as described below when we provide our Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain aspects of the Services. 

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1. Information you provide directly to us

We may collect information that you provide directly to us through user entry. We collect personal data that you voluntarily provide to us. You may provide us this information when you create a user account; order a product or service; request subscription content, including when you register for trial accounts; send us a question via e-mail; or communicate with us in person, such as through conferences or events; or otherwise contact us. 

Information you provide directly to us may concern you and others and may include, but is not limited to:

• Contact Information and Identifiers. You may provide us with contact information or other personal identifiers, such as your name, email address, mailing address, or telephone number.
• Financial Information. We may collect payment information for our Services, such as when we engage payment processors to collect your payment information.
• Business Information. We may collect general information about your employment or business, such as a business title, business phone, business email address, business product and service offerings, and other information you provide us when communicating with us.
• Transaction Information. We may collect information about transactions with you, such as purchases, purchase amount, and date of purchase;
• Communications. We may collect your communications with us, such as when you submit questions, communicate with our customer support, or otherwise communicate with Folloze.
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2. Information from affiliates and non-affiliated parties

We may collect information about you or others through our affiliates or through non-affiliated parties. We may also collect information about you from other users. For example, users may provide us with information about colleagues or other prospective users of our Services, including name, e-mail and other contact information.

We may combine information that we collect from you through the Services with information that we obtain from such other parties and information derived from other products or Services we provide.

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3. Information we collect automatically

Device/Usage Information. We and our vendors, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. We also receive technical information from metadata. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); (i) version of our Services you’re using; and (j) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application. We use this information (including the information collected by our vendors) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to evaluate the success of our Services and advertising campaigns, offer you any other or additional services that can be helpful to you or our users or identify the most efficient path for getting you to the content that interests you, and as otherwise described in this Policy.

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Cookies and Other Electronic Technologies. “Cookies” are small data files that are placed on your browser by a website. The cookies help provide additional functionality to the Services and help us analyze usage more accurately. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies to further personalize our Services. “Metadata” is usually technical data that is associated with user content. For example, metadata can describe how, when and by whom a piece of user content was collected. Google Analytics helps us understand how users use our Services by collecting information sent by your browser, including your IP address, and utilizing cookies. Google Analytics receives and stores information generated by your browser or device about your use of the Services and their use of the information is governed by their privacy policy. For more information, see http://www.google.com/policies/privacy/partners/ and http://www.google.com/policies/privacy/.

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You can typically remove and reject cookies from our online services with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how the Services work for you. As we adopt additional technologies, we may also gather additional information through other methods. 

Google Connectivity. We may enable our customers to connect our Services with their Google Gmail account. If offered, you will have the option to connect your Folloze account with Gmail. If you elect to connect your Folloze account with Gmail, you grant us access to certain features available via the Gmail Application Programming Interface. By enabling the Gmail Application Programming Interface and authorizing our access, Folloze will have: (1) read-only access to your email message metadata, such as headers and labels, but not the email body; (2) the ability to send emails from your Gmail account; and/or (3) other permissions you explicitly grant to us. Folloze processes such data to enable customers to create email campaigns from their Gmail account, and we also use the data on behalf of customers to track replies to such email campaigns. Notwithstanding anything to the contrary herein, Folloze further processes such data in accordance with Google’s Limited Use Requirements.

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Other Social Networking and Third Party Companies. For your convenience, we may enable you to sign in to Folloze using your account credentials from other social networking and third-party services (e.g., username and password from LinkedIn, etc.) as well as connect with such services during your usage of Folloze. When you sign in or connect with such third-party services we may receive information about you directly from such services, subject to your settings with the third-party service. This information is part of Your Content. We do not endorse any of the social networking and third-party services. Your relationship with such services and their collection, use and transmission of information are governed by such services’ privacy policies and practices, and we disclaim any and all liability for a service’s actions, links, websites, services and products.

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We do not currently recognize or respond to browser-initiated Do Not Track (DNT) signals. Please note that DNT is different from the Global Privacy Control referenced in Section 12 below.

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Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address). 

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2. How We Use the Data We Collect

We use your information for business and commercial purposes, such as:

• To provide you with the Services;
• To respond to your questions and inquiries, including to provide customer support and technical assistance;
• To communicate with you, including to send you emails about our products and services;
• To communicate about upcoming events, promotions and other news about products and services offered by us and our partners and provide products and services customers request;
• To send service notices;
• To process transactions with you;
• To analyze and improve the Services or any other products and services we provide;
• To verify your identity;
• To comply with our legal obligations or as permitted by law;
• To protect the safety and/or integrity of our users, employees, other parties, members of the public, and/or our Services;
• To conduct analysis and develop insights that enable us to operate, protect, make informed decisions and report on our business;
• To prevent enforce our legal terms; 
• to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity or otherwise as permitted by law; and
• To administer and troubleshoot the Services.

We may link or combine user information with other information we collect about you.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also disclose such data to other parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

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3. When We Disclose Data We Collect

We may disclose the information we collect in the following circumstances:

Affiliates and Subsidiaries. We may disclose information to our affiliates and subsidiaries.

Vendors. We disclose your information to select vendors who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.

Communities and Analytics. The power of Folloze’s Services is that it enables users to create communities within and across which to share information. When you create or join a community, your Personally Identifiable Information may be available to other members of that community, in addition to Your Content and any contacts that you choose to share with that community. Information, including Personally Identifiable Information, is also shared across communities among users of our Services. As part of the Services, Folloze provides an analytics function so that users can determine and keep track of which of their content is of interest to other users, when and how often it is being viewed, and how it is being used. These analytics may in some circumstances be associated with your Personally Identifiable Information so that users know who is interested in their content. For clarity, this type of data sharing does not apply to your use of the Google Connectivity feature, as we process that data in accordance with Google’s Limited Use Requirements.

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Safety and Protection of Folloze and Others. We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of Folloze or other parties, including to defend or enforce this Policy, our Terms of Service, or any other contractual arrangement or (ii) respond to your requests for customer service; and/or (iii) protect the rights, property or personal safety of Folloze, its agents and affiliates, its employees, users and/or the public. 

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Business Transfers. As our business develops, we might sell or buy businesses or assets. Should we undergo or negotiate a merger, acquisition, sale or transfer of part of our business or assets or purchase of another business or asset, financing or other corporate event, we may provide your relevant information to the relevant entity and reserve the right to do so.

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Legal Requirements. In some circumstances, we may need to disclose your information (a) in response to a subpoena or law-enforcement procedure or as we otherwise reasonably believe we are required to do so bylaw, regulation or governmental authority, (b) to preserve our rights or property, or (c) to protect the personal safety of someone in an emergency, and we reserve the right to do so.

Consent/At Your Direction. We may disclose your information to nonaffiliated parties based on your consent to do so. For example, you may direct us to disclose information about you when you refer us or our Services to your colleagues or other acquaintances.

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4. Online Analytics and Tailored Advertising

1. Analytics

We may use third-party web analytics services on the Services, such as those of Google Analytics. These vendors use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

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2. Tailored Advertising

We may also allow third-party advertising technologies to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our websites. We also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may disclose to a vendor in hashed, non-human-readable form.

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If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content may not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit these opt-out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective. 

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5. Your Choices

1. Rights and choices

You have certain rights and choices with respect to your information such as:

• Profile Information: You can update certain of your profile information through the “My Settings” page.
• Marketing Communications: You can unsubscribe from marketing emails by following the directions in those emails. Please note that if you unsubscribe from marketing emails, we may still send you administrative emails regarding the Services, including, for example, notices of updates to our Terms of Service or this Policy.
• Cookies & Analytics: You can opt out of certain cookie-related and analytics processing by following the instructions in this Policy.

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Your local law may provide you certain rights with respect to your personal data. Depending on your jurisdiction, you may request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for certain marketing purposes;
• update information which is out of date or incorrect; and
• delete certain information that we are holding about you.

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Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To exercise any of these rights, please contact us as described in the “Contact Us” section below.

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2. Additional rights of residents of California

Please see the Supplementary Notice for California Residents in Section 12 below for notices and additional information for residents of California.

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3. Additional rights of residents of Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to unaffiliated parties. You can exercise this right by contacting us as described in the “Contact Us” section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address. We do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

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6. Children’s Privacy

The Services are not directed towards children under 18. If you learn that your minor child has provided us with personal data, please contact us at legal@folloze.com.

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7. Security

We take commercially reasonable steps consistent with industry practice to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration or destruction. No measure of security is foolproof, so please keep this in mind when providing us with information. We do not promise and cannot guarantee the security of your personal data or communications.

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8. Data Retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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9. Third-Party Links

We are not responsible for the privacy practices or the content of other websites that may be linked to or from our Services. All third-party collection and use of your information is governed by the privacy policy of the applicable third party, and we disclaim any and all liability for a third party’s actions, links, websites, services and products.

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10. Consent to Transfer

Your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of information may be less stringent than the laws in your country. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.

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11. Changes to this Policy 

We may change this Policy to reflect changes in the law, our information practices or the features of the Services. We will indicate the date of the most recent update in the Policy. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy. 

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12. Supplementary Notice for California Residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) requires us to provide some additional information to California residents. This Section 12 only applies to you if you are a California resident. This Section 12 does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants.

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1. Categories of information we collect

Section 1 above describes the information we collect from and about you, Section 2 describes the purposes for which we use this information, and Section 3 describes when and to whom we disclose data. The CCPA requires us to list the personal information we collect by category along with the purposes of its use and the unaffiliated parties to which it is disclosed. 

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Categories of information (see Section 1 above for more information)

Purpose of use

Categories of other parties to whom we disclose the information for business and operational purposes (see Section 3 above for more information)

Identifiers

such as name, address, and email address, and telephone number; and information about your browser or device such as IP address and device IDs

• Provide the Services
• Respond to your questions and inquiries, including to provide customer support
• Communicate with you, including to send you emails about our products and Services
• Send you service notifications
• Process transactions with you
• Analyze and improve the Services or any other products and services we provide
• Verify your identity
• Comply with our legal obligations and as permitted by law
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services
• Conduct analysis and develop insights that enable us to operate, protect, make informed decisions and report on our business
• Prevent fraud and enforce our terms
• Administer and troubleshoot the services
• Advertising and market our products and services

• Affiliates and subsidiaries
• Vendors and service providers
• Ad networks and advertising partners
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent

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Commercial information

such as information about your transactions with us, for example, products or services you have purchased

• Provide the Services 
• Communicate with you, including to send you emails about our products and Services
• Send you service notifications
• Process transactions with you
• Analyze and improve the Services or any other products and services we provide
• Comply with our legal obligations and as permitted by law
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services
• Prevent fraud and enforce our terms
• Advertising and analytics

• Affiliates and subsidiaries
• Vendors and service providers
• Ad networks and advertising partners
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent

Financial information

such as credit card information stored by our payment processors on our behalf

• Provide the Services 
• Process transactions with you
• Comply with our legal obligations and as permitted by law
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services

• Prevent fraud and enforce our terms

• Service providers for payment processing purposes
• Entities for legal and security purposes

Internet network and device activity data

such as information about your device hardware (e.g., device type) and software (e.g., operating system and browser type) and browsing and usage information (e.g., how often you visit our Services, the pages you visit, referring pages, and the version of the Services you’re using) 

• All the same purposes for which we may use Identifiers (see above)

• Affiliates and subsidiaries
• Vendors and service providers
• Ad networks and advertising partners
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent

Professional or employment-related information 

such as your employer and job title

• All the same purposes for which we may use Identifiers (see above), except for advertising and analytics.

• Affiliates and subsidiaries
• Vendors and service providers
• Ad networks and advertising partners
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent

Geolocation information

such as your approximate location based on IP address

• All the same purposes for which we may use Identifiers (see above), except for advertising and analytics.

• Affiliates and subsidiaries
• Vendors and service providers
• Ad networks and advertising partners
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent

Audio or visual information

such as when you call customer service

• Provide the Services 
• Communicate with you, including to send you emails about our products and Services
• Process transactions with you
• Comply with our legal obligations and as permitted by law
• Protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services
• Prevent fraud and enforce our terms

• Affiliates and subsidiaries
• Vendors and service providers
• Entities for legal and security purposes
• Others with your consent

Other information

any other information you provide to us that directly or indirectly identifies you, such as information you include in emails or other communications to us

• Purposes of use will depend on the additional information you provide

• Disclosure will depend on the additional information you provide

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We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; (3) affiliates; and (4) other parties such as marketers and other users.

2. Your CCPA rights

If you are a California resident, the CCPA may permit you to request that we:

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• Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your personal information; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” personal information; and the categories of personal information we “sell.”
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.
• Correct inaccurate personal information that we maintain about you.

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You also have the right to opt out of “sales” and “sharing” of personal information, as described in subsection c below. You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

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If would like to exercise any of these rights, please submit a request using one of the methods in Section 13, “Contact Us,” below. You may be required to verify your identity before we fulfill your request, and we may request additional information from you in order to do this. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

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3. Sales and sharing of personal information

We may disclose your personal information to third parties for purposes of analytics and advertising. We provide information to analytics providers to better understand how consumers use the Services so we can improve the Services and create new products and services. We may also provide personal information to third-party advertising providers for targeted advertising purposes, so we can provide you with more relevant and tailored ads regarding our services. Under the CCPA, disclosing personal information to these third parties may be considered a “sale” of personal information or the “sharing” of personal information for purposes of “cross-context behavioral advertising.”

The following chart lists the categories of personal information we have sold or shared over the last 12 months and the categories of third parties to which we have sold or shared:

Category of personal information

Categories of Third Parties to Which we Have “Sold” this PI

Categories of Third Parties to Which we Have “Shared” this PI

Identifiers

Ad networks and advertising partners; analytics providers

Ad networks and advertising partners

Commercial information

Ad networks and advertising partners; analytics providers

Ad networks and advertising partners

Internet network and device activity data

Ad networks and advertising partners; analytics providers

Ad networks and advertising partners

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To opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” or “sharing,” please click here. You can also submit a request to opt out of our offline disclosures of information that are subject to applicable opt out rights by clicking here or by emailing us at legal@folloze.com. 

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.

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We do not knowingly “sell” or “share” the personal information of children under 16.

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The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

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4. Retention 

Please see Section 8 above (“Data Retention”) for how we retain your personal information.

13. Contact Us

If you have any questions or concerns about this Policy, please contact us at:

Folloze, Inc.

Attention: Legal

P.O. Box 50965

Palo Alto, CA, 94303, USA

legal@folloze.com