PRIVACY POLICY
Last updated March 12, 2024
This privacy notice for Fulton ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you
use our services ("Services"), such as when you:
- Visit our website at fultonapp.com, or any website of ours that links to this privacy
notice
- Download and use our mobile application (Fulton),
or any other application of ours that links to this
privacy notice
- Engage with us in other related ways, including any sales,
marketing, or events
Questions or concerns?Reading this privacy notice
will help you understand your privacy rights and choices. If you do
not agree with our policies and practices, please do not use our
Services. If you still have any questions
or concerns, please contact us at jeremy@fultonapp.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you
can find out more details about any of these topics by clicking the
link following each key point or by using our
table of contents below to find the section you are looking for.
What personal information do we process? When you visit,
use, or navigate our Services, we may process personal information depending
on how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about
personal information you disclose to us.
Do we process any sensitive personal information? We may process sensitive personal
information when necessary with your consent or as otherwise permitted
by applicable law. Learn more about
sensitive information we process.
Do we receive any information from third parties? We do not receive any information
from third parties.
How do we process your information? We process your information
to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your consent. We process your information
only when we have a valid legal reason to do so. Learn more about
how we process your information.
How do we keep your information safe? We have organizational and technical processes and procedures
in place to protect your personal information. However, no electronic transmission
over the internet or information storage technology can be guaranteed to
be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able
to defeat our security and improperly collect, access, steal, or modify your
information. Learn more about
how we keep your information safe.
What are your rights? Depending on where you are located
geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about
your privacy rights.
How do you exercise your rights? The easiest way to exercise
your rights is by submitting adata subject access request, or by contacting us. We will
consider and act upon any request in accordance with applicable data
protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us
when you register on the Services,
express an interest in obtaining information about us or our
products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information
that we collect depends on the context of your interactions with us and
the Services, the choices you make, and the products and features you use.
The personal information we collect may include the following:
- contact or authentication data
Sensitive Information. When necessary, with your consent or
as otherwise permitted by applicable law, we process the following
categories of sensitive information:
- information revealing race or ethnic origin
- data about a person's sex life or sexual orientation
- information revealing political opinions
- information revealing religious or philosophical beliefs
- information revealing trade union membership
Social Media Login Data.We may provide you with the
option to register with us using your existing social media account
details, like your Facebook, Twitter, or other social media account.
If you choose to register in this way, we will collect the information
described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use our application(s), we also
may collect the following information if you choose to provide us with access
or permission:
- Geolocation Information. We may request access or permission
to track location-based information from your mobile device, either continuously
or while you are using our mobile application(s), to provide certain location-based
services. If you wish to change our access or permissions, you may do so
in your device's settings.
- Mobile Device Access. We may request access or permission to
certain features from your mobile device, including your mobile device's
camera, social media accounts, and other features. If you
wish to change our access or permissions, you may do so in your
device's settings.
- Mobile Device Data. We automatically collect device information
(such as your mobile device ID, model, and manufacturer), operating system,
version information and system configuration information, device and application
identification numbers, browser type and version, hardware model Internet
service provider and/or mobile carrier, and Internet Protocol (IP) address
(or proxy server). If you are using our application(s), we may also collect
information about the phone network associated with your mobile device,
your mobile device’s operating system or platform, the type of mobile device
you use, your mobile device’s unique device ID, and information about the
features of our application(s) you accessed.
- Push Notifications. We may request to send you push notifications
regarding your account or certain features of the application(s). If you
wish to opt out from receiving these types of communications, you may turn
them off in your device's settings.
This information is primarily needed to maintain the security and
operation of our application(s), for troubleshooting, and for our
internal analytics and reporting purposes.
All personal information that you provide to us must be true,
complete, and accurate, and you must notify us of any changes to such
personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short:We process your information to provide, improve, and
administer our Services, communicate with you, for security
and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons,
depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise
manage user accounts.
We may process your information so you can create and log in
to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user.
We may process your information to provide you with the
requested service.
- To respond to user inquiries/offer support to users.
We may process your information to respond to your inquiries
and solve any potential issues you might have with the requested
service.
- To send administrative information to you.We may
process your information to send you details about our products and
services, changes to our terms and policies, and other similar
information.
- To enable user-to-user communications.We may
process your information if you choose to use any of our offerings
that allow for communication with another user.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short:
We may share information in specific situations described in this
section and/or with the following third parties.
We may need to share your
personal information in the following situations:
- Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
- When we use Google Maps Platform APIs. We may share
your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We obtain and store on your device ("cache") your location. You may revoke your consent
anytime by contacting us at the contact details provided at the end
of this document.
- Other Users. When you share personal information (for example, by posting comments, contributions,
or other content to the Services) or otherwise interact with public areas of the Services, such personal
information may be viewed by all users and may be publicly made available
outside the Services in perpetuity. If
you interact with other users of our Services and register for our Services
through a social network (such as Facebook), your contacts on the social
network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be
able to view descriptions of your activity, communicate with you within our
Services, and view your profile.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short:
We may use cookies and other tracking technologies to collect and
store your information.
We may use cookies and similar tracking technologies (like web beacons
and pixels) to access or store information. Specific information about
how we use such technologies and how you can refuse certain cookies is
set out in our Cookie Notice.
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short:If you choose to register or log in to our Services using a social
media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or Twitter
logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile
information we receive may vary depending on the social media provider
concerned, but will often include your name, email address, friends
list, and profile picture, as well as other information you choose to
make public on such a social media platform.
We will use the information we receive only for the purposes that are
described in this privacy notice or that are otherwise made clear to you
on the relevant Services. Please note that we do not control, and are
not responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their
privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences on
their sites and apps.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:We keep your information for as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this privacy notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information
for longer than three (3) months past the termination of the user's account.
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize such information, or, if this
is not possible (for example, because your personal information has been
stored in backup archives), then we will securely store your personal information
and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to
protect the security of any personal information we process. However, despite
our safeguards and efforts to secure your information, no electronic transmission
over the Internet or information storage technology can be guaranteed to
be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able
to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Services is at your
own risk. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short:
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18
years of age. By using the Services, you represent that you are at least
18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at jeremy@fultonapp.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
Withdrawing your consent: If we are relying
on your consent to process your personal information, which may be express and/or implied
consent depending on the applicable law, you have the right to
withdraw your consent at any time. You can withdraw your consent
at any time by contacting us by using the contact details provided
in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of
the processing before its withdrawal nor, when applicable law allows, will it affect the processing
of your personal information conducted in reliance on lawful processing
grounds other than consent.
Opting out of marketing and promotional communications:You can unsubscribe from our marketing
and promotional communications at any time by clicking on the unsubscribe link in
the emails that we send, or by contacting us using the details
provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be
removed from the marketing lists. However, we may still communicate
with you — for example, to send you service-related messages that are
necessary for the administration and use of your account, to respond
to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information
in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate
or delete your account and information from our active databases.
However, we may retain some information in our files to prevent
fraud, troubleshoot problems, assist with any investigations,
enforce our legal terms and/or comply with applicable legal
requirements.
If you have questions or comments about your privacy rights, you may
email us at jeremyaherzog@gmail.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature
or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and
collected. At this stage no uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not
currently respond to DNT browser signals 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 inform you about that practice in a revised version
of this privacy notice.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short:If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted
specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information
in the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address,
telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address,
email address, and account name |
|
B. Personal information as defined in the California
Customer Records statute | Name, contact information, education, employment,
employment history, and financial information |
|
We will use and retain the collected personal
information as needed to provide the Services or
for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category C - As long as the user has an account with us
- Category G - As long as the user has an account with us
- Category I - As long as the user has an account with us
We may also collect other personal information outside of
these categories through instances where you interact with us
in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond
to your inquiries.
How do we use and share your personal information?
C. Protected classification
characteristics under state or federal law | Gender and date of birth |
|
D. Commercial information | Transaction information, purchase history, financial
details, and payment information |
|
E. Biometric information | Fingerprints and voiceprints |
|
F. Internet or other
similar network activity | Browsing history, search history, online behavior,
interest data, and interactions with our and
other websites, applications, systems, and
advertisements |
|
G. Geolocation
data | Device location |
|
H. Audio,
electronic, visual, thermal, olfactory, or
similar information | Images and audio, video or call
recordings created in connection with our
business activities |
|
I.
Professional or employment-related
information | Business contact details in order to
provide you our Services at a business
level or job title, work history, and
professional qualifications if you apply
for a job with us |
|
J. Education Information | Student records and directory
information |
|
K. Inferences drawn from
collected personal information | Inferences drawn from any of the
collected personal information
listed above to create a profile or
summary about, for example, an
individual’s preferences and
characteristics |
NO |
| L. Sensitive
personal Information | |
NO
|
Will your information be shared with anyone else?
We may use your personal information for our own business purposes,
such as for undertaking internal research for technological development
and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to
third parties for a business or commercial purpose in the preceding
twelve (12) months. Wewill
not sell or share personal information in the future belonging to
website visitors, users, and other consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California
residents to request and obtain from us, once a year and free of charge, information
about categories of personal information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of all third parties
with which we shared personal information in the immediately preceding calendar
year. If you are a California resident and would like to make such a request,
please submit your request in writing to us using the contact information provided
below.
If you are under 18 years of age, reside in California, and have a
registered account with the Services, you have the right to request removal
of unwanted data that you publicly post on the Services. To request removal
of such data, please contact us using the contact information provided below
and include the email address associated with your account and a statement
that you reside in California. We will make sure the data is not publicly
displayed on the Services, but please be aware that the data may not be
completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California
Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a
temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere
to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask
us to delete your personal information, we will respect your request and
delete your personal information, subject to certain exceptions provided
by law, such as (but not limited to) the exercise by another consumer of
his or her right to free speech, our compliance requirements resulting
from a legal obligation, or any processing that may be required to
protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or
disclosed for a business purpose;
- the categories of third parties to whom the personal information was
sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or
sharing personal information; and
- the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or
delete consumer information that is de-identified in response to a
consumer request or to re-identify individual data to verify a consumer
request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy
Rights
We will not discriminate against you if you exercise your privacy
rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to
determine you are the same person about whom we have the information in
our system. These verification efforts require us to ask you to provide
information so that we can match it with information you have previously
provided us. For instance, depending on the type of request you submit,
we may ask you to provide certain information so that we can match the
information you provide with the information we already have on file, or
we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also
use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to
verify your identity or authority to make the request. To the extent
possible, we will avoid requesting additional information from you for
the purposes of verification. However, if we cannot verify your identity
from the information already maintained by us, we may request that you
provide additional information for the purposes of verifying your
identity and for security or fraud-prevention purposes. We will delete
such additionally provided information as soon as we finish verifying
you.
Other privacy rights
- You may object to the processing of your personal information.
- You may request correction of your personal data if it is incorrect
or no longer relevant, or ask to restrict the processing of the
information.
- You can designate an authorized agent to
make a request under the CCPA on your behalf. We may deny a request from
an authorized agent that does not submit
proof that they have been validly authorized to act
on your behalf in accordance with the CCPA.
- You may request to opt out from future selling or sharing of your
personal information to third parties. Upon receiving an opt-out
request, we will act upon the request as soon as feasibly possible,
but no later than fifteen (15) days from the date of the request
submission.
or by referring to the contact details at the bottom of this document. If you
have a complaint about how we handle your data, we would like to hear from
you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado
Privacy Act (CPA), you have the rights listed below. However, these rights
are not absolute, and in certain cases, we may decline your request as
permitted by law.
- Right to be informed whether or not we are processing your personal
data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with
us
- Right to opt out of the processing of your personal data if it is used
for targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects ("profiling")
To submit a request to exercise these rights described above, please email jeremyaherzog@gmail.com orsubmit a
data subject access request.
If we decline to take action regarding your request and you wish to
appeal our decision, please email us at jeremyaherzog@gmail.com. Within forty-five (45) days of receipt of an
appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for
the decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut
Data Privacy Act (CTDPA), you have the rights listed below. However, these
rights are not absolute, and in certain cases, we may decline your request
as permitted by law.
- Right to be informed whether or not we are processing your personal
data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with
us
- Right to opt out of the processing of your personal data if it is used
for targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects ("profiling")
To submit a request to
exercise these rights described above, please
email jeremyaherzog@gmail.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to
appeal our decision, please email us at jeremyaherzog@gmail.com. Within sixty (60) days of receipt of an
appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for
the decisions.
Utah Residents
This section applies only to Utah residents. Under the Utah Consumer
Privacy Act (UCPA), you have the rights listed below. However, these
rights are not absolute, and in certain cases, we may decline your request
as permitted by law.
- Right to be informed whether or not we are processing your personal
data
- Right to access your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with
us
- Right to opt out of the processing of your personal data if it is used
for targeted advertising or the sale of personal data
To submit a request to
exercise these rights described above, please
email jeremyaherzog@gmail.com or submit a data subject access request.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a
resident of the Commonwealth acting only in an individual or household context.
It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked
or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified
data or publicly available information.
"Sale of personal data" means the exchange of personal
data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere
to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
- Right to be informed whether or not we are processing your personal
data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with
us
- Right to opt out of the processing of your personal data if it is used
for targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects ("profiling")
Exercise your rights provided under the Virginia VCDPA
If you are using an authorized agent to exercise your rights,
we may deny a request if the authorized agent does
not submit proof that they have been validly authorized to act on your
behalf.
Verification process
We may request that you provide additional information reasonably
necessary to verify you and your consumer's request. If you submit the
request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in
all cases, within forty-five (45) days of receipt. The response period may
be extended once by forty-five (45) additional days when reasonably
necessary. We will inform you of any such extension within the initial
45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you
of our decision and reasoning behind it. If you wish to appeal our
decision, please email us at jeremyaherzog@gmail.com. Within sixty (60) days of receipt of an
appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for
the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short:Yes, we will update this notice as
necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated
version will be indicated by an updated "Revised" date and the
updated version will be effective as soon as it is accessible. If we make
material changes to this privacy notice, we may notify you either by prominently
posting a notice of such changes or by directly sending you a notification.
We encourage you to review this privacy notice frequently to be informed
of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at jeremy@fultonapp.com orcontact us by post at:
Fulton
562 Wilson Ave
2L
Brooklyn, NY 11207
United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA
WE COLLECT FROM YOU?
You have the right to request access to the personal
information we collect from you, change that information, or
delete it. To
request to review, update, or delete your personal
information, please fill
out and submit a
data subject access request.