Privacy Policy

PRIVACY STATEMENT

 

Family & Co respects your privacy. Family & Co SAS, with headquarters at 16, rue Théodore de Banville, 75017, Paris, France, including its affiliates ("Family & Co") provides this Privacy Statement (the "Statement") to help you understand how Family & Co collects and uses the Personal Information and Non-Personal Information (each as defined below) you submit to or which is collected by Family & Co via Family & Co’s service called FamilyWall at www.familywall.com or through FamilyWall mobile applications (the "Service"), including any club or forum offered through the Service or that is collected when you visit the Service. "You" means an individual who accesses or uses the Service. This Statement only governs the collection, storage, use and disclosure of information collected through the Service. It does not apply to information collected by Family & Co in other ways (for example, from third parties) or through other Family & Co websites or services, and it does not modify or alter other agreements you may have, or enter later, with Family & Co.

For example, if Family & Co collects information about you from third party sources, the collection, storage, use and disclosure of that information will be governed by Family & Co’s agreement with you or the third party source, unless the privacy statement of a third party source indicates that this Statement will govern Family & Co’s use of the information that the third party source provides to Family & Co.

Also, if you provide Personal Information to Family & Co through other means, such as when you call customer service or send Personal Information related to promotions or product registrations via postal mail, this Statement does not apply to that information.

You acknowledge and agree that this Statement has the same effect as a written consent. By accessing or using the Service or providing information to Family & Co through the Service, you acknowledge that you have reviewed the content of this Statement and consent to the practices described in this Statement.

1. Information that Family & Co Collects

When you visit the Service, Family & Co collects certain Personal Information, as well as Non-Personal Information.

Personal Information

In this Statement, “Personal Information” means any information about an identifiable individual, as further defined under applicable laws. Family & Co collects Personal Information when you submit it to the Service (for example when you sign up for or when you email invite other members). The Personal Information collected may include your name, birth date, address, mobile, phone, or fax number, email address, IP address, account information (such as account and online registration), online activities, and other specific personal information. In some cases, if Family & Co asks you to provide Personal Information, the provision of that information will be mandatory to participate in a particular activity, service or promotion. If you do not provide this Personal Information, your participation in that activity, service or promotion may be limited or prohibited. For example, if you choose not to provide your Personal Information in a required field when you sign-up for a club membership, you may not become a club member of Family & Co.

Non-Personal Information

Family & Co also collects certain “Non-Personal Information,” which means data in a form that does not include direct or indirect association with an identifiable individual, such as gender, language, zip code, area code, unique device identifier, location and time zone where an Family & Co product or service is used, and information about customer activities on the Service, to allow Family & Co to better understand customer behavior and improve Family & Co’s services, products and advertising. Family & Co collects some of this Non-Personal Information automatically when you visit the Service (Ad ID, IDFA, Google Advertising ID). If Non-Personal Information is combined with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

Voluntary Disclosure

Where you voluntarily disclose additional personal information without being prompted by Family & Co and Family & Co is not made aware that it should take special care in handling such information, then Family & Co will not be held liable for that information under this Privacy Statement unless and to the extent that Family & Co is obliged to use and protect such information pursuant to and in accordance with applicable law.

Location Services

Family & Co and its partners may collect, use, transmit, process, store and share your precise location through GPS, WiFi, or wireless network triangulation for the purposes of providing our Service. This information may include but is not limited to your device ID and name, device type and real-time geographic location of your device. You may also be able to submit to Family & Co location data such as “Places,” and other information. Family & Co may also supplement the information it collects with information obtained from other companies. Family & Co does not share geographic location data with application providers. By enabling or using the location-based services or features (such as displaying your phone location, posting Footprints, etc.) and applications that depend on location-based information, you agree and consent to Family & Co collecting, using, transmitting, processing, storing and sharing information related to your account and the devices registered to your account for purposes of providing such location-based services or features to you. You may withdraw this consent by turning off the "Locate" function in the location settings (as applicable) on your device. The "Family Map" feature is intended for your personal use only to locate the last explicit position of the family members. The location-based services are not intended or suitable for use as an emergency locator system as the location display may be imprecise or not valid anymore.

2. Family & Co’s Use of Information

Family & Co will only use Personal Information for the purposes set out in this Statement, with your consent or as required or permitted by law. Consent may be express or implied, and given in writing, by using or not using a check-off box, electronically, orally, or by your conduct, such as by visiting the Service and by using services or products offered through the Service. You agree that the consent given electronically should have the same effect as that given in writing. In some jurisdictions implied consent is not sufficient, in which case, express consent will be required.

Family & Co processes and uses the Personal Information it collects for the following purposes:

  • to enable the features you are using;
  • to operate, develop and improve its web sites, business, products, services, content and advertising;
  • to inform you of Family & Co’s latest product announcements, software updates and services
  • to provide you with more effective customer service
  • to analyze Family & Co’s business, products and other services
  • to detect fraud and abuse, and as otherwise described in the Service Terms and Conditions, and if you have an Family & Co device, your End User License Agreement.

Family & Co may also process, access, use, store and disclose Personal Information to enforce the terms and policies governing your use of the Service (including investigation of any potential violation), to detect or prevent security breaches, fraudulent activity or technical issues, to protect the rights or property of Family & Co and its customers.

Also, Family & Co may use your Personal Information to communicate with you; Family & Co may send service communications such as welcome emails, information on technical service issues, and security announcements, as well as information about changes to our terms, conditions and policies.

Family & Co may also occasionally send you product surveys or promotional mailings to inform you about other products or services available from Family & Co, and to fulfill promotions. Personal information collected through the Service may be stored and processed in the EEA, USA and any other country in which Family & Co or its service providers maintain facilities. By using the Service, you consent to the transfer, recording and storage of information outside of the country where you reside.

While in another jurisdiction for processing, the information may be accessed by the courts, law enforcement and national security authorities. Family & Co may use your Personal Information from the day you submit it to the day it is deleted, whether as a result of deletion due to a request by you to delete it, or for another reason.

Family & Co retains your Personal Data until it is no longer necessary to provide you with the Service, or until your account is deleted.

3. Sharing Personal Information

Except as described in this Statement or otherwise as permitted by law, Family & Co’s practice is to not disclose Personal Information about you outside of Family & Co and its affiliates without your consent. You hereby consent to the disclosure of your Personal Information as outlined in this Statement. Family & Co may disclose the Personal Information described in Section 1 of this Statement to its third party service providers so they may complete transactions or perform services on Family & Co’s behalf, transactions on your behalf, or transactions related to providing services to you. For example, Family & Co may contract with third parties to host the Service, collect and provide product reviews, provide promotions or surveys, send Family & Co’s emails, and fulfill product orders and promotions.

Family & Co will use contractual agreements to protect Personal Information disclosed to third party services providers. Family & Co may also access, use, store and disclose Personal Information to comply with the law and lawful requests or legal process, enforce the terms and policies governing your use of the Service including investigations of any potential violation, to detect or prevent security, fraud or technical issues, to protect the rights or property of Family & Co and its customers, and when Family & Co believes in good faith that the disclosure is necessary to protect the personal safety of Family & Co, its employees and customers, or the public. Also, Family & Co may disclose Personal Information in connection with (but not limited to) the following circumstances:

  • Certain Business Transfers. Family & Co may disclose personal information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets (including for due diligence purposes for a proposed commercial business transaction). Family & Co may also disclose Personal Information in the event of insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of the business assets in the transaction.
  • Promoted Services. Some services in connection with the Service may be proposed and offered together with another company. If you register for or use these services, both Family & Co and the other company may receive your Personal Information collected in connection with the promoted services.
  • Monitoring and Usage Analysis. Family & Co may transfer aggregated data to third party partner to Monitor the effectiveness of our Service and our marketing campaigns, to Monitor aggregate metrics like total number of visitors, users, traffic, and demographic patterns, to Diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs.
  • Promoted Services.Some other services may be proposed and offered in the Service by Family & Co. If you register for or use these Services, you will be bound by the Terms and Privacy Policies of the Promoted Service.
  • Monitoring and Usage Analysis Family & Co may transfer aggregated data to third party partner to Monitor the effectiveness of our Service and our marketing campaigns, to Monitor aggregate metrics like total number of visitors, users, traffic, and demographic patterns, to Diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs.
  • Other Purposes. Family & Co may disclose Personal Information as consented to by you from time to time, including to fulfill any other purposes that are identified when the Personal Information is collected.

Family & Co will use measures as required by law to protect the security of the Personal Information transferred. Some jurisdictions only allow disclosure of account information and content (including the content of communications) if it is provided by law or pursuant to court order, so the above section may not apply to you.

4. Cookies and Other Technologies

Family & Co’s websites, services, interactive applications, email messages and advertisements may use “cookies” and other mechanisms such as pixel tags, Flash cookies and web beacons.

A "cookie" is a small data file that the Service transfers to your computer for storage to allow Family & Co’s server to “store” or "remember" specific information. These technologies help Family & Co to better understand user behavior and use of the Service which allow Family & Co to analyze trends and also to administer the Service. Family & Co may use "cookies" and other tracking mechanisms to help support the integrity of registration processes on the Service and to track marketing efforts.

Family & Co also allows third party service providers to collect information to help Family & Co track and aggregate individual use of the Service. Family & Co treats most information collected by cookies and other technologies as Non-Personal Information. However, to the extent that any information is considered Personal Information by local law, Family & Co will treat it as Personal Information.

Family & Co and its partners may also use cookies and other technologies to remember Personal Information when you use our Service, services and applications, in order to retain changes that you make and to improve your user experience.

We use the following cookies:

  • Strictly necessary cookies: Some cookies are strictly necessary to make our Services available to you; for example, to perform your login functionality and for user authentication and security. We cannot provide you with the Services without this type of cookies;
  • Functional cookies: These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region);
  • Analytical or performance cookies. We also use cookies for analytics purposes in order to operate, maintain, and improve our Services. We use third party analytics providers, including Google Analytics and Firebase, to help us understand how users engage with the Services. Google Analytics and Firebase use first-party cookies to track user interactions which helps show how users use our Services. This information is used to compile reports and to help us improve our Services. The reports disclose Website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our Website by going to https://tools.google.com/dlpage/gaoptout or via Google's Ads settings.

By providing your contact information and information about your device you are able to register your products with Family & Co and enables Family & Co to provide you with an improved service. You do not have to choose to accept cookies and in certain jurisdictions cookies that are not strictly necessary to provide you with services that you have explicitly requested cannot be used without your prior consent, however if you choose not to accept all types of cookies certain Service features and functionality may no longer work properly, or at all. It may be possible to disable some cookies by modifying your browser preferences. Please refer to https://www.allaboutcookies.org/ for further information about cookies and how to disable them.

5. Children’s Personal Information

The Service does not target and is not intended for children under the age of 13. Family & Co does not want to collect personal information from anyone under the age of 13. If you are under 13, you should not access the Service and should not provide Family & Co any information about yourself, including your name, address, telephone number, or email address (directly, or on site bulletin boards, blogs, etc.). If you are 13 years of age or older but under the age of majority according to local law (18 in most countries), before you decide whether or not to access this Service and to share Personal Information with Family & Co, you should review this Privacy Statement with your parent or guardian to make sure that you and your parent or guardian understand it. Parents or guardians are advised to supervise their children while using the Internet and mobile and other devices.

6. Communication Preferences

If you have consented to receive marketing communications, Family & Co may send you emails to inform you about products, services or other marketing materials, which Family & Co considers may be of interest to you, or that you have otherwise agreed to receive. You may opt-out of receiving future marketing communications from Family & Co by following the instructions in the relevant communication. If you opt-out of receiving future marketing emails, Family & Co may still send you service communications such as (but not limited to) support, software and security updates and product recall information.

7. Your rights to access and update to Personal information

You may be able to access, copy, update, and delete your Personal Information, to the extent it is not otherwise required to be retained by law, through the Service by changing registration information you provide in connection with the Service. You will be required to sign in with your user name and password. Family & Co may keep records of changes to your Personal Information (including deletions). You can delete your account via an email request to Family & Co. Family & Co will respond to your request and stop processing your information 28 days after receiving such request.

EEA or UK residents.

If you are based in the EEA or the UK, you have certain rights in relation to your Information. You will find more information below on when which rights can apply. To exercise your rights, please contact us (see section 12). Before fulfilling your request, we may ask you to provide reasonable Information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, known as 'GDPR') and Law No. 78-17 of 6 January 1978 relating to data processing, files, and freedoms, you can withdraw your consent to the processing of your Personal Data at any time, and you have the rights of access, rectification, opposition, and erasure of your Personal Data. You can exercise these rights by making a request to the following address: support@familyandco.com. In case of reasonable doubt about your identity, Family & Co reserves the right to request a copy of your signed identity document before responding to the exercise of your rights.

If you reside in France, and believe, after having contacted us, that your rights regarding the protection of your Personal Data are not being respected, you can file a complaint with the CNIL.

Other rights

You also have the following rights:

  • Portability. You have the right to receive a copy of Information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such Information is transferred to a third party.
  • Correction. You have the right to correct any Information held about you that is inaccurate.
  • Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.
  • You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work or where an incident took place.

California Privacy Rights.

California law may entitle California residents to certain additional protections regarding Personal Information. For purposes of this sub section alone, “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

We collect the categories of Personal Information as described in the section 2 “Family & Co Use of Information” above. We collect, use, and disclose Personal Information in the ways described above in this Privacy Policy. We do not sell Personal Information to third parties. California residents have the following rights to the extent granted by applicable law:

  • To request and receive information regarding your Personal Information we have collected in the past 12 months (including the categories of Personal Information we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
  • To request and receive information about whether we have disclosed your Personal Information to third parties in the past 12 months (and if so, which categories of information we have disclosed, and which categories of third parties we have disclosed it to);
  • To request and receive a copy of your Personal Information collected by us in the past 12 months; and
  • To request specific treatment relating to the processing of Sensitive Personal Information elements described above.
  • Our timely response to your request that your Personal Information be deleted.

We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this Privacy Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request, including if we determine that our business does not fall within the scope of the California statutes. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Information, you may be charged a fee to the extent permitted by law.

8. Security of Personal Information

Family & Co is committed to protecting the security of your Personal Information. Family & Co and the third party service providers that provide hosting services for the Service use a variety of security technologies and administrative procedures to help protect your Personal Information from unauthorized access, use or disclosure with security measures appropriate to the sensitivity of the information. For example, your Personal Information is stored on computer systems located in controlled facilities with limited access. Family & Co restricts access to the Personal Information to employees who have a need to use the Personal Information.

9. Third Party Services and Services

The Service may contain links to third-party websites, products and services, such as social networking sites and third parties who may offer additional products and services through the Service. The third parties use of the data they collect will be governed by the third parties’ privacy practices. Please review these before providing any Personal Information to any third party.

10. International Data Transfers

All information processed by us may be processed and stored anywhere in the world, including, but not limited to, the EEA, UK or the United States or other countries, which may have data protection laws that are different from the laws where you live. If you use our services, you consent to the transfer of your information from any country to any other country.

11. Changes to this Statement

This Statement is effective as of the effective date at the bottom of this Statement. Family & Co may periodically update this Statement to reflect changes in its practices or applicable laws or regulations. If Family & Co updates this Statement, Family & Co will post the updated version of this Statement and it will change the “effective date” at the top of this Statement. If the updated version of the Statement contains material changes to how Family & Co collects, uses, or shares your personal information, Family & Co will post a prominent notice of the updated version on the Service. To the extent permitted by applicable law, your continued use of the Service constitutes your binding acceptance of the updated Statement.

12. How To Contact Family & Co

If you have any questions, comments, or concerns about this Statement or about Family & Co’s privacy practices, please direct your privacy-related comments or questions support@familyandco.com or to the applicable address below:

Family & Co
16, Théodore de Banville Street
75017 PARIS

This document has been updated October 10, 2019