Privacy Policy
Effective date: August 8, 2023
The DeFO application is used to connect to official DeFO server and third-party DeFO servers. This privacy policy describes how official DeFO server ("DeFO","defo.xyz", "we", "us") collects, protects and uses the personally identifiable information you may provide. The policy also describes the choices available to you regarding our use of your personal information and how you can access and update this information. Each third-party DeFO server comes equipped with its own privacy policy that can be viewed through the app or through that server's website.
At DeFO, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing DeFO in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of DeFO is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve DeFO, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on our website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of DeFO, and you are still responsible for reading and understanding them. If you use DeFO after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use DeFO. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.
Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data: |
|---|---|---|
Profile or Contact Data | •Profile picture • Bio | • Service Providers • Analytics Partners • Parties You Authorize, Access or Authenticate |
Device/IP Data | • IP address • Device ID • Type of device/operating system/browser used to access DeFO | • Service Providers • Analytics Partners |
Web Analytics | • Web page interactions • Referring webpage/source through which you accessed DeFO • Non-identifiable request IDs • Statistics associated with the interaction between device or browser and the Services | • Service Providers • Analytics Partners |
Geolocation Data | • IP-address-based location information | • Service Providers • Analytics Partners |
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
When you provide such information directly to us.
When you create an account or use DeFO.
When you voluntarily provide information in free-form text boxes through DeFO or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.
When you use DeFO and such information is collected automatically.
Through Cookies.
If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you with DeFO, such as information regarding when you are logged on and available to receive updates or alert notices.
Vendors
We may use analytics providers to analyze how you interact and engage with DeFO, or third parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles.
Social media networks
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
Providing, Customizing and Improving DeFO
Creating and managing your account or other user profiles.
Providing you with the products, services or information you request.
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for DeFO.
Improving DeFO, including testing, research, internal analytics and product development.
Personalizing DeFO, website content and communications based on your preferences.
Doing fraud protection, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA"), as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about DeFO.
Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
Protecting the rights, property or safety of you, DeFO or another party.
Enforcing any agreements with you.
Responding to claims that any posting or other content violates third-party rights.
Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers.
These parties help us provide DeFO or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
Analytics providers.
Support and customer service vendors.
Product fulfillment and delivery providers.
Parties You Authorize, Access or Authenticate
Third parties you access or interact with through DeFO. For example, you are sharing your Personal Data with a third party when you join a DeFO organization or forum and then share your Personal Data with other members or administrators of that organization or forum.
Social media services
Google Applications
Notwithstanding anything else in this Privacy Policy, if you provide DeFO with access to the following types of your Google user data, our use of that data will be subject to these additional restrictions:
We will only use access to read, write, modify or control Google data to provide DeFO and will not transfer this Google user data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
We will not use this Google user data for serving advertisements.
We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above. Additionally, if you share Personal Data through a DeFO organization, the organization may be permitted to share your Personal Data pursuant to their litigation discovery policies.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve DeFO and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools, Advertising, and Opt-Out
DeFO uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use DeFO, analyze trends, learn about our user base and operate and improve DeFO.
Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access DeFO. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, DeFO does not support "Do Not Track" requests sent from a browser at this time.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you as necessary to provide you with DeFO or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in a de-identified or aggregated and de-identified form where that information would not identify you personally. If you have any questions about data security or retention, please contact us at [email protected]. If you share Personal Data through a DeFO organization, that shared Personal Data will be retained by the third-party administrator in accordance with that organization’s data retention policies.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at [email protected].
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the "Exercising Your Rights" section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Data that official DeFO server have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
Email us at: [email protected]
You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales
We will not sell your Personal Data, and have not done so over the last 12 months.
Personal Data Sharing
Under the CPRA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We will not share your Personal Data for cross-contextual behavioral advertising, and have not done so over the last 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age for purposes of cross-contextual behavioral advertising.
We Will Not Discriminate Against You for Exercising Your Rights Under the CPRA
We will not discriminate against you for exercising your rights under the CPRA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CPRA. However, we may offer different tiers of DeFO as allowed by applicable data privacy laws (including the CPRA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at [email protected].
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at [email protected] with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
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