Privacy Policy

FIG ME Privacy Policy is established by the Personal Data Protection Law (PDPL, n° 13.709/2018). As addressed by this current Brazilian legislation, this policy acts as a controller (whether individual or legal entity, of public or private law, who are responsible for decisions regarding the processing of personal data) regarding the processing of personal data collected, which are information provided by the app users. FIG ME subjects to PDPL and commits, at the terms of this Law, to protect its collection of data.

Summary of main points

• When the user consent is required, FIG ME will request their permission before: (i) send news and promotional contents; (ii) access information stored on the user’s device regarding their use or participation within the app and crash reports; and (iii) analyze the user content. It is possible to withdraw the consent to these activities at any time.
• This policy explains when FIG ME processes personal information for its legitimate interests. The user may request FIG ME to stop processing this information.
• FIG ME provides interactive features integrated with social networks websites, such as Instagram.
• The collected data will be used to improve performance, interactivity and experience between FIG ME and the app users.
• What are the user’s rights and how they can exercise them.

What this privacy policy comprises?

This Privacy Policy describes how FIG ME will use your information in the following contexts:

• Application for mobile devices, that includes reference to this Policy; and
• Marketing, sales and advertising practices.

What information does FIG ME collect about the user?

Registration and customer support

When you register to use FIG ME application, create an account, or contact us for support, FIG ME collects identification information. That includes:

• Name;
• Date of birth;
• Email address;
• Country and city (optional);
• Gender;
• IP address;
• Mobile device ID;
• Content of customer support communications.

FIG ME collects information on how you use the application, including when you use some resource that makes an online connection (such as displaying a picture list, profile photo synchronization, etc). These information may be associated with your device or account, and includes:

• IP address;
• Operating system of the smartphone used;
• User content analysis (such as photos, activity logs and direct user feedback), that are sent or received while using an application’s online resource, and stored on the servers.

Emails from FIG ME

The emails that FIG ME sends you may include a technology (called web beacon) that informs if you received or opened the email, or clicked a link on it. If you do not wish this information collected, disable the email delivery sent by FIG ME.

FIG ME online advertising

FIG ME advertises online in many ways, such as displaying FIG ME advertisements to users in websites, apps and social networks, like Facebook and Instagram. FIG ME collects information like:

• Which ads are displayed;
• Which ads receive clicks; and
• Where the ad was displayed.

Buttons, tools and other companies' contents

FIG ME app may include buttons, tools or contents and links for other companies’ services. Read the company’s Privacy Policy for more information.

FIG ME app may implement Google reCAPTCHA Enterprise to prevent spam and abuse. reCAPTCHA Enterprise collects hardware and software information, such as the device and application data, and send it to Google to provide, maintain and improve reCAPTCHA Enterprise, as well as for general security purposes. The usage of reCAPTCHA Enterprise it subjected to its Privacy Policy [https://policies.google.com/privacy?hl=en-US] and to Google Terms of Service [https://policies.google.com/terms?hl=en-US].

How FIG ME uses your collected information and what are the legal bases for this usage?

FIG ME uses your collected information for the following purposes:

• To fulfill contractual obligations or to take action linked to a contract: this is relevant when you use FIG ME app (whether being the paid or free version). This includes:
  • To offer you apps and sites;
  • To send you communications (for instance, about payments or subscription expiration); and
  • To provide support or customer services.
• As necessary for FIG ME to conduct its business and exercise legitimate interests, specifically:
  • To analyze your usage and measure the effectiveness of its websites and apps, in order to better understand how they are being used, and to improve them;
  • To send you information about FIG ME products and services, special offers and similar material;
  • To analyse your usage of the app and its content, and your interaction with its communications, aiming to adjust and customize the application and its marketing communications (when user consents is not required);
  • To analyse your content using techniques, as machine learning, to improve the app services and your experience (when user consents is not required);
  • To diagnose problems at the application;
  • To detect, prevent or, otherwise, solve fraud, technical or security issues, as well as to protect against damage to the rights, property or safety of FIG ME, its users or the public;
  • To conduct researches and market researches about the app clients, their respective interests, the effectiveness of their marketing campaigns and customer satisfaction (if FIG ME needs consent to conduct these surveys, they will only be conducted with the user's permission);
  • To investigate and respond to user submitted comments or complaints; and
  • Along with legal claims and for compliance, regulatory and investigative purposes as needed (including the disclosure of information related to litigation or legal proceedings, upon request of government agencies).

When FIG ME processes the user’s information according to its legitimate interests, the user may object to this process under certain circumstances. In these cases, the processing of information is interrupted, unless FIG ME has sufficient legal bases to continue or if necessary for legal reasons.

• When necessary, when you provide your consent or it is, otherwise, consistent with your choices:
  • To send you information about FIG ME products and services, special offers and similar material;
  • To access information stored on your device, which is allowed to be received through settings on your device (for instance, photos), and to provide some functionality in our app; and
  • To analyze your content, using techniques as machine learning, to improve services and your experience.

On other occasions when FIG ME asks for your consent, it will use your information for the purposes explained at the time of request. In cases where your consent is required to process information, you may withdraw your consent at any time.

• For legal reasons:
  • To respond to requests from the government or law enforcement authorities to conduct an investigation.
  • To detect, prevent or, otherwise, resolve fraud, technical or security issues, and software piracy (for example, to confirm that software is genuine and properly licensed), helping to protect the user and FIG ME.

When processing and disclosure are not strictly required by law, FIG ME will act in its legitimate interests.

Does FIG ME share my personal data?

FIG ME does not share your collected personal data with third parties. However, in case there is a legal or regulatory requirement or to comply with orders issued by public authority, it is possible that FIG ME will share users' personal information.

Is my personal information secure?

FIG ME actively works to protect your personal information. It adopts administrative, technical and physical security controls as needed, such as encryption.

Where does FIG ME store my personal information?

Your personal information and files are stored on the servers of companies hired to provide these specialized services for FIG ME.

What rights does the user have regarding their personal information and how to exercise them?

According to some jurisdictions, the user may have the right to request FIG ME for a copy of their personal information; as well as the correction, exclusion or restriction of active processing of their personal information.

In addition, the user may object to the processing of their personal information in some circumstances (for example, regarding the user's country, city and gender).

These rights may be limited, for instance, if the fulfillment of the user's request reveals personal information about another person or if the user requests the exclusion of information that FIG ME is obligated to maintain, or that is necessary for FIG ME to defend itself against possible allegations. In addition, most browsers have a “Do Not Track” feature that helps the user to inform websites that they do not want their online activities tracked. Currently there is no accepted pattern of how companies should respond to browser “Do Not Track” signals. This way, FIG ME applications and websites currently do not recognize or respond to browser “Do Not Track” signals. Nonetheless, the user can learn more about FIG ME's advertising practices and user's privacy choices at [https://www.figmeapp.com/privacy/index.html]..

To exercise any of these rights (including account deactivation), you can contact FIG ME or the data protection department through the communication channels provided in the title "Who can I contact if I have questions or concerns?". In addition, the user can change the personal information provided, at any time, through the Settings Menu. As well, they can log in.

In case of unresolved concerns, the user has the right to report them to the local privacy regulator or data protection authority and, when applicable, they have the right to file a complaint with the main supervisory authority of FIG ME.

In order to register with FIG ME, create an account and use the services offered, the provision of some information is mandatory: if the relevant information is not provided, FIG ME will not be able to administer an account for the user nor provide the application, products or services requested. Any further provision of information is optional. Providing optional information will help FIG ME provide a better user experience in using the services provided.

How long does FIG ME retain user information?

When the user registers with the application, FIG ME processes and maintains most of their personal information as long as they are an active user of the app. When the user closes their account, FIG ME begins deleting certain personal information which retention will no longer be necessary.

Can this privacy policy be changed?

Occasionally FIG ME may update this Privacy Policy to include new technologies, industry practices, regulatory requirements, or for other purposes. In this case, the "last updated" date at the top of this document will be changed, and the revised policy will be posted on this page so that the user is aware of what information is collected, how it is used, and under what circumstances it may be disclosed. FIG ME encourages you to review periodically this FIG ME Privacy Policy for the latest information regarding our privacy practices. In some cases (for example, when there are material changes), you will be notified of the changes and, if required by applicable law, FIG ME will obtain your consent.

Who can I contact if I have questions or concerns?

If you have any questions, concerns or requests about privacy, send an email to [contact@figmeapp.com].