PRIVACY POLICY
Last Modified: August 27, 2024
Introduction
Fairly Inc. and its affiliates (“Fairly”, “we”, “us”, “our”) are committed to protecting your privacy. This Privacy Policy (the “Policy”) describes how we collect, use, disclose, and safeguard information about you (“Personal Information”), as well as your rights and choices regarding such Personal Information.
Applicability
This Policy applies to when you access and use the Fairly website, www.fairly.com, the associated web and mobile web application (the “Fairly Platform”), our e-mails, advertisements and any other location, online or offline, where you interact with our business, and all content and functionality associated with the foregoing (collectively, the “Services”).
The Services may contain links to third party websites or services that are not operated by us. We are not responsible for the privacy practices of these third party sites, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure of Personal Information. You should closely review the third party’s privacy notice prior to accessing or using the third party website or services.
Please read this Policy carefully before you start to use the Services. By using or accessing the Services, you agree to this Policy. If you do not agree to this Policy, do not use the Services.
Personal Information We Collect
We collect the following types of Personal Information: (i) information that you directly provide to us in connection with your use of the Services; and (ii) information that we automatically collect from you in connection with your use of the Services.
Information That You Directly Provide to Us. When you use the Services, we may ask that you provide certain Personal Information directly to us. If you do not want us to collect this information, please do not provide it. However, some of the Personal Information we ask that you directly provide is required in order to use the Fairly Platform.
Information Needed to Use the Fairly Platform. We collect certain Personal Information about you when you use the Fairly Platform. If you refuse to provide this Personal Information, we may not be able to provide all services requested. This information includes:
Account profile information such as your name, phone number, e-mail, postal address, and profile photo.
Identity information such as your date of birth, tax identification number, government identification number, and related copies or images.
Payment and lodging tax and license information, including bank account details and tax and license numbers.
Additional Information You Choose to Give Us. You can choose to provide us with additional Personal Information, including:
Additional profile information such as gender, a personal description, additional home details, and tax and vendor account details and invoices.
Information about others, such as contact information of another person. By providing us with Personal Information of others, you acknowledge that you have permission to provide that information to Fairly for the purposes described in this Policy.
Other information such as when you fill out a form, add information to your account, respond to surveys, communicate with Fairly, or communicate with other users through the Fairly Platform.
Information Automatically Collected. We generate, collect, and derive certain Personal Information automatically when you use or interact with the Services. This Personal Information includes:
Usage data related to your interactions with the Services, including pages visited, time spent on a particular website or using the services, login data, and the dates/times of access.
Device data, including browser type, operating system, and device identifiers such as IP address and advertising identifier.
Location data, including an approximate geolocation derived from your IP address.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
Web Beacons. Certain pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Fairly, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Some content or applications, including advertisements, on the Fairly Platform and associated Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Fairly Platform and associated Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
Section 6 below also describes our use of certain ad tracking technologies and analytics services.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices section below.
Information We Collect from Third Parties. To the extent permitted by applicable law, we may obtain information about you from third parties such as social media platforms, referrals from other Fairly Platform users, marketing partners, public databases, government agencies, and other data providers.
How We Use Your Information
We use the information we collect for various purposes, including to:
To provide the Services to you and to enable you to access and use the Services, including to make and receive payments.
Enable you to communicate with others on the Fairly Platform.
Verify information provided by you, including identity information required to use the Fairly Platform.
Communicate with you, including responding to your comments, questions, and requests, and providing customer support.
Resolve disputes among users of the Fairly Platform.
Personalize and customize your experience based on your interactions with the Fairly Platform.
Improve the Services by conducting research, performing analytics, and refining models.
Send promotional materials, newsletters, and other information.
Detect, prevent, assess, and address fraud and security risks.
Comply with applicable law, respond to legal requests, enforce our Terms of Service, and protect the health and well-being of the users of the Services.
To fulfill any other purpose for which you provide it.
For any other purpose with your consent.
How We Share Your Information
We may share the information we collect in connection with the Services with third parties, including:
Other users of the Fairly Platform such as a guest, homeowner, caretaker, or advisor, to the extent necessary to deliver the Services.
Third parties that are integrated within the Fairly Platform, including channel listing partners, to the extent necessary to deliver the Services.
Vendors, suppliers, and other service providers that Fairly engages with to support delivery of the Services and fulfill other operational, marketing, and administrative activities. For example, we use Google Maps to provide certain functionality in connection with the Fairly Platform. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
Affiliates and subsidiaries of Fairly.
Other parties in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Fairly to another company.
Other parties in response to subpoenas, court orders, or to protect our rights.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
Analytics and Targeted Advertising
We use tracking technologies and analytics services such as Meta Pixels and Google Analytics to help us understand how users access and use our website, the Fairly Platform, and other aspects of the Services. These technologies may track your activities across different services and devices to deliver relevant ads and content to you. The data collected by these services may be used to analyze website traffic and user behavior, measure the effectiveness of our marketing campaigns, and optimize our advertising strategies across different platforms. We may also work with advertising and technology service providers to place ads on other websites and platforms.
For more information about the privacy practices of Meta, please visit the Meta Privacy Policy web page: https://www.facebook.com/privacy/policy/.
Google may share data collected through Google Analytics with other Google services. Google also may use the collected data to contextualize and personalize the ads of its own advertising network. For more information, please visit the Google Privacy & Terms web page linked to in Section 5.c. above.
You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
Again, we do not control third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Use of Information Outside of Your Country of Residence
The Services are directed to users located in the United States. If you are located outside of the United States and choose to use the Services or provide your information to us, we may transfer your information to the United States and process it there. Your consent to this Policy followed by your submission of information to us in connection with the Services represents your agreement to the transfer of your information to the United States.
Security
We have implemented commercially reasonable administrative, technical, and physical measures to secure your Personal Information from unauthorized access, use, alteration, and disclosure. While no company can guarantee absolute security, Fairly’s cybersecurity team has taken efforts to help ensure the protection of all data stored and processed by Fairly. In the event of a personal data security incident that might impact user’s rights and interests, Fairly will notify all individuals in accordance with applicable data protection laws and regulations. Fairly will also report any relevant incidents to local or federal authorities as required by applicable laws and regulations. It is the expectation of Fairly that all users of the Services must also do their part in protecting the data, systems, networks, and service they are utilizing.
No Use by Children
Our Services are not intended for children and to our knowledge we do not collect Personal Information for children under 13. If you become aware that a child has provided us with personal information, please contact us at [email protected]. If we become aware that we have collected Personal Information from a child under 13, we will take steps to delete such information from our records.
Retention
We collect and store Personal Information for the purposes described in this Policy. We retain Personal Information for as long as we continue to have a business or operational purpose to retain it and may also retain it for longer periods to comply with legal and regulatory obligations, resolve disputes, prevent fraud, or enforce our rights. Legal and regulatory requirements might prevent immediate deletion of Personal Information upon your request. Once the retention period ends, we will delete or de-identify your Personal Information according to our policies.
Your Choices
You may have the option to limit automatic information collection, targeted advertising, and communications from us. If you opt to limit these items, it could negatively impact our ability to deliver the Services.
Cookies and Web Beacons. You can set your browser settings to block or delete cookies, or to alert you when cookies are being sent. Note that disabling cookies may limit some features of our Services.
Targeted Advertising. You may be able to opt-out of the collection and use of information for targeted advertising, either through your browser settings or by contacting us.
Communications. We provide the opportunity to opt out of receiving communications from us at the point where we request information about you. In addition, you may unsubscribe or opt out of receiving communications from us by clicking the unsubscribe link on any email marketing communication you receive. Note that if you opt out from receiving communications from us, it may influence our ability to deliver the Services.
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Fairly Platform and visiting your account profile page.
You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your Fairly Platform user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California’s Shine the Light Law
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits any users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.
Do Not Track Signals
Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track”requests are sent to the websites you visit. IF YOU DO NOT WANT US TO AUTOMATICALLY COLLECT INFORMATION FROM YOU WHEN YOU USE THE SERVICES, EITHER NOW OR FOR FUTURE BROWSING SESSIONS, REFRAIN FROM USING THE SERVICES. WE DO NOT CURRENTLY RESPOND TO DO NOT TRACK (“DNT”) SIGNALS.
Changes
We may update this Policy at any time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Policy on our website and updating the effective date. If you disagree with the revised Policy, you can discontinue your use of the Fairly Services. If you continue to use the Services after the date of the revised Policy, your continued access to or use of the Services will be subject to the revised Policy.
Contact Us
If you have any questions about this Policy or our data practices, please contact us via e-mail at [email protected] or by mail at:
Fairly Inc.
Attn: Chief Financial Officer
1120 SE Madison St.
Portland, OR 97214